The collection, use, disclosure and retention of personal information are all regulated by law in British Columbia. Curl BC collects and uses personal information primarily to provide the programs, services, products and information required by members of Curl BC. To enable Curl BC to manage and develop its operations from local to international levels, Curl BC may share your personal information with its members and Curling Canada, and also with selected third parties who are acting on our behalf as our agents, suppliers or service providers. From time to time, Curl BC may contact our members directly or may include information from corporate sponsors whose products, services or information may be of interest to our members. If you do not want to be included on the Curl BC mailing list, please advise the Curl BC Privacy Officer.
Ten Principles of Privacy
At Curl BC, we value our relationship with our members and respect their privacy according to the following ten principles:
1) Curl BC is accountable and responsible for the safeguarding of personal information in our custody or under our control. Curl BC has appointed a Privacy Officer who is responsible for privacy issues within Curl BC. Curl BC has implemented procedures for the handling of personal information, and has developed a complaint process for members with personal information concerns.
2) Curl BC collects personal information only for the following purposes:
- to establish and maintain a responsible relationship with our members and to provide ongoing service to all areas of curling within British Columbia;
- to support and assist our member facilities in delivering programs and services at the local level;
- to support and assist Curling Canada in delivering programs and services at the national and international levels;
- to manage and develop our operations and help us plan for future growth; and
- to meet legal and regulatory requirements.
3) Curl BC will obtain your consent to collect, use or disclose personal information (except where authorized or required by law to do so without consent). Consent can be express, implied, or given through an authorized representative such as parent or guardian, lawyer or agent.
You have the right to refuse or withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. You may have your name removed from our telephone, mail or email lists. However, withdrawal of consent may limit our ability to communicate with and serve you.
4) Curl BC will limit the amount and type of personal information collected to that which is reasonable and necessary to fulfill its stated purposes.
5) Curl BC uses your personal information only for the purposes for which it is collected. Your personal information may also be disclosed by Curl BC for the following reasons.
- Curl BC may disclose a member’s personal information to a person who, in the reasonable judgment of Curl BC, is seeking the information as an agent of that member.
- Curl BC may disclose a member’s personal information to a public authority or agent of a public authority if, in the reasonable judgment of Curl BC, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information.
- In conjunction with special offers or programs, Curl BC may disclose members’ personal information to our partners and associates or to third-party agents responsible for administering such offers or programs. Any such disclosure is made with the member’s consent and on a confidential basis and is limited to the information needed for the stated purpose.
- Curl BC will keep personal information used to make a decision about an individual for a minimum of one year. After one year, Curl BC will destroy, erase or render anonymous personal information as soon as retention is no longer necessary.
6) Curl BC will make every reasonable effort to ensure that personal information it is using or disclosing is accurate and complete.
7) Curl BC will protect the personal information in its custody or control by making security arrangements to prevent unauthorized access, collection or use. Curl BC will protect the confidentiality of your personal information when dealing with other organizations.
8) Curl BC is open about the policies and procedures it uses to protect your personal information. Information about our policies and procedures is available in writing and electronically.
9) Members have the right to access their own personal information through the Curl BC Privacy Officer. Unless prevented by law, Curl BC will provide you with information regarding your personal information and give you the opportunity to correct any errors of fact.
10) Curl BC has developed a complaint handling process. Curl BC will investigate all complaints received and take appropriate measures to correct information and handling practices as required. Individuals may appeal any Curl BC decision to the Information and Privacy Commissioner of British Columbia.
Questions or Concerns
Curl BC Privacy Officer
The Curl BC Privacy Officer is the Chief Executive Officer (CEO).
The Curl BC Assistant Privacy Officer is the Participation Manager.
If you have any questions or concerns about your personal information in the control or custody of Curl BC, please contact the Privacy Officer or Assistant Privacy Officer.
Appointment of Privacy Officer
The Chief Executive Officer is appointed by the Board of Governors as the Curl BC Privacy Officer.
The Privacy Officer must be familiar with the legislation and should be knowledgeable about Curl BC’s personal information management practices. The Curl BC Privacy Officer is responsible for:
- encouraging compliance with provisions of the Personal Information Protection Act;
- responding to requests for access to and correction of personal information and general issues concerning personal information;
- working with the Information and Privacy Commissioner during an investigation of a privacy complaint against Curl BC; and
- managing Curl BC’s complaint process.
Assistant Privacy Officer
The Participation Manager is appointed by the Board of Governors as the Curl BC Assistant Privacy Officer. The Privacy Officer and/or Assistant Privacy Officer are responsible for managing the necessary changes to Curl BC’s information management practices and procedures, staff training, member relations, and implementation of privacy policies and procedures. The Privacy Officer and/or Assistant Privacy Officer will provide assistance when a more detailed knowledge of Curl BC’s responsibilities is required. The Assistant Privacy Officer will act as a resource to the Privacy Officers designated by Curl BC’s member facilities and member associations.
Curl BC will make all reasonable effort to ensure that the purposes for personal information collection are stated at the time collection takes place.
Curl BC will review and revise its forms to include a statement of purpose. As appropriate, forms will also include a provision for an individual to opt out of providing some personal information. This includes written and electronic forms.
Consent is not required to disclose information (including photos and videos) obtained by observation at a public event or Curl BC event in which an individual voluntarily participates. However, as a courtesy, Curl BC will endeavour to obtain consent to use personal information in its publications, in communications materials such as posters and press releases and on its web site.
Refusal or withdrawal of consent
An individual has the right to refuse consent to use personal information or to withdraw consent at any time.
Curl BC will give individuals the opportunity to opt out at time of collection of information. The individual’s choice will be respected. This may mean that the individual does not receive general Curl BC communications or any special offers or information on behalf of Curl BC’s partners and associates.
An individual may withdraw consent for use of personal information at any time upon 30 days written notice to the Privacy Officer. The notice may be given by post, fax or email. The Privacy Officer must notify the individual of any consequences of this withdrawal of consent, and must also advise the individual when Curl BC has complied with their request.
Curl BC is responsible for personal information that has been collected and transferred to another organization. This may be a member facility, the Canadian Curling Association, a partner, a sponsor, an agent, or a service contractor. In all cases, when transferring information, Curl BC will clearly state what requirements must be met to comply with the legislation and with Curl BC’s personal information management practices.
Curl BC is also responsible for personal information collected on our behalf by another organization. British Columbia organizations collecting information on behalf of Curl BC must clearly state the purpose for collection and all such information will be treated by Curl BC according to the legislation and our personal information management practices.
Organizations outside British Columbia, such as the Canadian Curling Association are not subject to the BC Personal Information Protection Act legislation.
Accessing and Correcting Information
An individual has the right to access their personal information and to correct errors of fact.
Accessing your personal information
Requests for access to personal information must be made in writing to the Privacy Officer. The request must include sufficient detail to enable the Privacy Officer to identify the information requested.
The Privacy Officer must respond to the request for access within 30 business days. The response must include, if requested, the ways in which the personal information has or is being used, and a list of organizations to whom the information has been disclosed.
The Act identifies certain circumstances where information may be withheld. If the Privacy Officer withholds information, he or she must give the reason and identify the Section of the Act under which the information is being withheld.
Correcting your personal information
If personal information held by Curl BC is incorrect, an individual may request correction by writing to the Privacy Officer. The individual must provide sufficient documentation to show that the correction is justified. Any original documentation supplied through this process by an individual will be returned, although copies will be taken for the file.
The Privacy Officer will ensure that the appropriate corrections are made and that any incorrect information that has been disclosed within the year prior to the request is corrected.
An individual may not correct opinions, but may annotate their file. This is done by writing to the Privacy Officer. The Privacy Officer will ensure that such annotation is included in the individual’s file.
An individual may not request original documents held by Curl BC but may request copies. Curl BC will provide copies to the individual at minimal or no cost. These documents must relate solely to the individual’s personal information and may not include information of a personal nature about any other individual.
Handling Complaints about Personal Information
Complaints about Curl BC’s management of personal information may be instigated verbally or in writing and should be directed to the Curl BC Privacy Officer. Whether verbal or written, the complaint should follow the guideline of the Curl BC Personal Information Complaint Form to ensure that the concern is documented thoroughly and with all relevant details. Initial complaints may be directed to members of staff, management, or to a representative of the Board of Governors who will pass them to the Privacy Officer or Assistant Privacy Officer as appropriate.
Complaints may not be investigated by any person who may be named in the complaint.
The Privacy Officer or Assistant Privacy Officer (the -Investigator”) will investigate all complaints received. The Investigator will acknowledge receipt of the complaint promptly, and may contact the individual to clarify the complaint if necessary.
The Investigator will be given access to all records, employees and others who handled the personal information or access request.
Where the complaint is justified, the Investigator will take appropriate measure to rectify the situation, including correcting information handling practices and policies where necessary and communicating those changes to relevant staff and volunteers. The Investigator will follow up to verify that the required changes have been implemented.
The Investigator will notify individuals of the results of an investigation clearly and promptly, informing them of relevant steps taken.
The Investigator will record all decisions to ensure consistency in applying the Act.
Requesting a review
Should an individual not be satisfied with the handling of their complaint, the Privacy Officer or Assistant Privacy Officer will inform them of the recourse they have to request a review by the Information and Privacy Commissioner of British Columbia. The Privacy Officer or Assistant Privacy Officer will provide the required contact information to a complainant wishing a review.
Security of Personal Information
Personal information in Curl BC custody or under Curl BC control will be safeguarded with the appropriate level of security, according to whether the information is regarded as -low sensitivity,” -medium sensitivity,” or -high sensitivity.” Security measures may include locked file cabinets, restricted access to offices, safety deposit boxes, and for computers: user ids and password-protected electronic files.
Retention of Personal Information
The Act requires Curl BC to hold personal information for one year. For various legal purposes, Curl BC holds all personal information for a minimum of two years. During that period, an individual has access to his or her personal information through the Privacy Officer and may correct errors of fact or lodge a complaint through Curl BC’s standard personal information complaint procedures. Selected personal information may be retained indefinitely. All retained personal information is subject to the rules and regulations of the Act regarding use, security and disclosure.
Personal information may be retained indefinitely in the form of statistics for purposes of research and program and organizational development, and to support and assist partners and associates in their development programs. Personal information may also be retained indefinitely in the form of anonymous anecdotal information for research, training and organizational development.
Destruction of Personal Information
Personal information no longer necessary to the purposes of Curl BC will be destroyed, erased, or rendered anonymous.
Curl BC will periodically clear its files of personal information that no longer needs to be retained. Written records or documentation containing personal information to be destroyed will be shredded or burnt. Computer files containing personal information to be destroyed will be erased, and a file search conducted to ensure that all copies of the information are erased.
Where existing personal information is corrected, updated or replaced, the previous version will be dated and archived in a locked file cabinet for a minimum of one year.
Providing Employment or Personal References
No member of the Curl BC management and staff or representative of the Curl BC Board of Governors may provide a personal or employment reference for an individual without the consent of the individual. In the absence of consent, Curl BC will only confirm an employment; i.e. -yes, that individual worked/volunteered for us” or -no, that individual did not work/volunteer for us.”
Consent is given by an individual’s request to Curl BC for a written reference or for use of a Curl BC representative’s name. In the absence of such a request from the individual, Curl BC or one of its representatives must have satisfactory confirmation of consent before providing an employment or personal reference. That confirmation may be a fax of a resume listing Curl BC or its representative as a reference. It is not Curl BC’s responsibility to seek consent.
Collecting Information without Consent
According to the Act, Curl BC may collect, use or disclose personal information without the consent of the individual. Curl BC will forgo obtaining consent on the following occasions.
- When collecting or disclosing the information clearly benefits you or is necessary for medical treatment and your consent cannot be obtained in a timely way.
- When the information is needed for a proceeding or an investigation and getting consent might compromise the availability or accuracy of the information.
- When the information is used for journalistic purposes and for no other purpose.
- When the information is collected by observation at a competition or other public event in which the individual voluntarily participates.
- When the information is necessary to determine the individual’s suitability to receive an honour or award or be selected for an athletic purpose.
- When the collection of information is required or authorized by law (such as criminal record checks).
- When the information is necessary to facilitate collection of a debt owed to Curl BC.