Oshawa Ski Club o/a Brimacombe has implemented the following:
- Procedures to protect personal information.
- Procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information by Oshawa Ski Club o/a Brimacombe.
- Training Staff and communicating information to Staff about Oshawa Ski Club o/a Brimacombe’s policies and procedures.
- Developing information to explain Oshawa Ski Club o/a Brimacombe’s policies and procedures to Guests.
Oshawa Ski Club o/a Brimacombe is responsible for the personal information under its control and has designated a Privacy Officer to be accountable for Oshawa Ski Club o/a Brimacombe’s compliance with PIPEDA. ( Personal Information Protection and Electronic Documents Act)
Oshawa Ski Club o/a Brimacombe will identify and document the purposes for which it collects personal information. Only personal information that is necessary for those identified purposes will be collected. If Oshawa Ski Club o/a Brimacombe intends to use the personal information that has been collected for a new purpose, this new purpose will be identified and consent for such new purpose will be obtained from the Guest to which the personal information relates prior to using such personal information.
Oshawa Ski Club o/a Brimacombe shall only collect, use and disclose personal information about Guests for the following purposes:
- To facilitate return visits.
- To advise Guests of goods and services.
- To improve the offering of goods and services to Guests.
- To assist Oshawa Ski Club o/a Brimacombe in the collection of fees, and other charges owing with respect to services rendered by Oshawa Ski Club o/a Brimacombe.
- To assist Oshawa Ski Club o/a Brimacombe in revenue management with respect to accounts payable and receivable.
- To assist Oshawa Ski Club o/a Brimacombe in communication with users of the Club for the purpose of promoting the use of the Club.
- To facilitate regular courses of business including but not limited to season passes, lessons, group and corporate bookings, rentals, and service work.
- Oshawa Ski Club o/a Brimacombe does not sell or trade personal information about Guests to any third party agencies.
Guest inquiries regarding the purposes for the collection, use and disclosure of personal information will be addressed by Oshawa Ski Club o/a Brimacombe and referred to the Chief Privacy Officer.
The knowledge and consent of Guests is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law. Oshawa Ski Club o/a Brimacombe will seek consent for the collection of personal information at the time of collection, wherever possible. Oshawa Ski Club o/a Brimacombe will make a reasonable effort to ensure that Guests are advised of the purposes for which the personal information being collected will be used, and will state the purposes in a manner that will allow Guests to reasonably understand how their personal information will be used or disclosed by Oshawa Ski Club o/a Brimacombe.
Consent may be obtained in a variety of ways, for example, through contracts and registration forms, orally by telephone or by electronic media, depending on the circumstances and the type of personal information being collected, and in particular, on the sensitivity of the personal information. The reasonable expectations of Guests will be considered when obtaining consent.
In certain circumstances, personal information can be collected, used or disclosed without the knowledge or consent of the Guest. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. Seeking consent my be impossible or inappropriate when there is an emergency threatening the Guest’s life, health or security, or where the Guest is a minor, seriously ill or mentally incapacitated.
Although information may be publicly available, Oshawa Ski Club o/a Brimacombe will treat it in accordance with PIPEDA principles. Moreover, Oshawa Ski Club o/a Brimacombe may provide personal information to its lawyers, advisors, agents and/or third parties to collect a debt, comply with a subpoena, warrant or other court order, to a government institution requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.
The use of Oshawa Ski Club o/a Brimacombe will be considered consent to collect, use and disclose personal information for stated purposes.
A Guest may withdraw consent by providing reasonable notice to the Privacy Officer of Oshawa Ski Club o/a Brimacombe. Oshawa Ski Club o/a Brimacombe will inform the Guest of any implications of such withdrawal. Any withdrawal of consent will still allow Oshawa Ski Club o/a Brimacombe to use and disclose a Guest’s personal information in order to collect or enforce payment of amounts owing as a result of a Guest’s previous or continuing use of the Club.
Subsequent use of Oshawa Ski Club o/a Brimacombe will automatically provide consent for the collection, use, disclosure and retention of personal information.
The collection of personal information will be limited to that which is appropriate in the circumstances.
LIMITED USE, DISCLOSURE & RETENTION
Oshawa Ski Club o/a Brimacombe will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the Guest or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.
Oshawa Ski Club o/a Brimacombe may disclose a Guest’s personal information to third parties retained by Oshawa Ski Club o/a Brimacombe for the purposes of billing such a Guest for the use of Oshawa Ski Club o/a Brimacombe and to collect and enforce payment of amounts owing by such Guests.
Certain employees of Oshawa Ski Club o/a Brimacombe and third party agents may be given access to a Guest’s personal information collected by Oshawa Ski Club o/a Brimacombe in so far as their duties require access for the purposes outlined. Oshawa Ski Club o/a Brimacombe employees and such third party agents are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated purposes.
Personal information that has been used to make a decision about a Guest will be retained in accordance with Oshawa Ski Club o/a Brimacombe document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. Oshawa Ski Club o/a Brimacombe retains the personal information of a Guest only for as long as it is required for Oshawa Ski Club o/a Brimacombe’s business purposes or as required by federal and provincial laws, or by legal Council.
Oshawa Ski Club o/a Brimacombe will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Oshawa Ski Club o/a Brimacombe will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. Oshawa Ski Club o/a Brimacombe will take steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is accurate and up-to-date.
Access to a Guest’s personal information on record with Oshawa Ski Club o/a Brimacombe may be requested by that Guest in order to review and amend their personal information, as appropriate. In circumstances where personal information has been provided by a third party, Oshawa Ski Club o/a Brimacombe will refer the Guest to that party. It is the responsibility of the third party to maintain accuracy of the personal information that is provided by them. To access your personal information, refer to “How to contact us”.
Oshawa Ski Club o/a Brimacombe will take reasonable steps to protect personal information through security safeguards appropriate to the sensitivity of the personal information. Oshawa Ski Club o/a Brimacombe Staff and Volunteers who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
Oshawa Ski Club o/a Brimacombe will make readily available to Guests specific information about its policies and guidelines relating to the management of personal information.
Oshawa Ski Club o/a Brimacombe will be open about its policies and procedures with respect to the management of personal information, and Guests will be able to acquire information about these policies easily and in a form that is generally understandable. These policies and any related information is available at all times at Oshawa Ski Club o/a Brimacombe office. To contact Oshawa Ski Club o/a Brimacombe refer to “How to contact us”.
Oshawa Ski Club o/a Brimacombe will inform a Guest of the existence, use and disclosure of their personal information (including to third parties) and will provide access to that personal information, upon written request. Oshawa Ski Club o/a Brimacombe will assist a Guest in the preparation of a request for access when such a Guest requests assistance. Oshawa Ski Club o/a Brimacombe will inform the Guest whether or not it holds personal information about them, and will indicate the source of any such personal information, when possible.
There may, however, be situations in which Oshawa Ski Club o/a Brimacombe will not be able to provide access to all the personal information that it holds about a Guest, although these situations will be limited and specific, and permitted or required by law. For example, Oshawa Ski Club o/a Brimacombe will not be able to provide access to a Guest’s personal information where giving such access would likely reveal personal information about a third party, unless that third party’s personal information can be severed from the Guest’s personal information. If Oshawa Ski Club o/a Brimacombe refuses a request for access, the Guest will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Guest of their recourse.
Oshawa Ski Club o/a Brimacombe will require that Guests requesting access to their personal information will provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit Oshawa Ski Club o/a Brimacombe to provide an account of the existence, use and disclosure of the Guests’ personal information.
Oshawa Ski Club o/a Brimacombe will be as specific as possible in providing an account of third parties to which personal information has been disclosed, and will provide a list of organizations to which personal information may have been disclosed when it is not possible to provide a list of the organizations to which specific personal information have actually been disclosed.
Oshawa Ski Club o/a Brimacombe will respond to a Guest’s request to access their personal information within a reasonable time, and not later than 30 days after receipt of the request. Oshawa Ski Club o/a Brimacombe may be entitled to a 30 day extension to respond, in limited circumstances, in which case the Guest will be notified of such an extension, the new time limit, the reasons for extending the time limit, and their right to make a complaint to the Privacy Commissioner with respect to the extension.
A Guest will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or addition of information, and the amended information will be transmitted to third parties having access to the personal information, where appropriate.
A Guest will be able to address a challenge concerning compliance with the above principles to the Chief Privacy Officer. Oshawa Ski Club o/a Brimacombe will handle all complaints or inquiries about the policies and procedures relating to the handling of personal information in line with the processes that are in place.
Oshawa Ski Club o/a Brimacombe will inform Guests who make inquiries or lodge complaints of the existence of the relevant complaint procedures. Oshawa Ski Club o/a Brimacombe will investigate all complaints, and if a complaint is justified, Oshawa Ski Club o/a Brimacombe will take appropriate measures, including amending policies and procedures.
HOW TO CONTACT US:
Brimacombe Privacy Officer:
phone: (905) 983-5983 Fax: (905) 983-6051
4098 Regional Rd. #9 Orono, ON L0B 1M0