SASKATCHEWAN HOCKEY ASSOCIATION PRIVACY POLICY

Background

Saskatchewan Hockey Association is the sole governing body for amateur hockey in Saskatchewan. In co-operation with its eight Zones, and various leagues and associations, Saskatchewan Hockey Association operates Hockey Programming across the Province. Hockey Programming means making all arrangements for amateur hockey leagues, teams and games including choosing and training coaches and officials, deciding which players may participate at which level, establishing appropriate rules and regulations for amateur hockey. As part of their Hockey Programming activities, Saskatchewan Hockey Association and its aforementioned partners also take responsibility for determining if transfer regulations may apply, scouting, gauging the success of certain programs in order that might improve upon them, facilitating emergency contact, providing educational opportunities, career opportunities, research and to maintaining regular electronic updates/contact with participants.

Purpose of this Policy

Saskatchewan Hockey Association has developed this Privacy Policy for implementation beginning January 1, 2005. This Policy describes the way that Saskatchewan Hockey Association collects, uses, retains, safeguards, discloses and disposes of the personal information of prospective members, members, and others including players, coaches, officials, managers and volunteers.

This Policy describes the way that Saskatchewan Hockey Association will subject to applicable legal requirements, adhere to all relevant federal and provincial legislative privacy requirements. The Policy follows the 10 Canadian Standards Association (CSA) principles identified in the federal Personal Information Protection and Electronic Documents Act (PIPEDA). The Policy describes each principle and the method of implementing each. Saskatchewan Hockey Association will strive to meet or exceed federal and provincial legislative requirements and will ensure that it remains current with changing technologies and laws. Any and all changes will immediately be posted to the Saskatchewan Hockey Association web site.

1. Accountability

1.1 Saskatchewan Hockey Association will appoint a (the "Privacy Officer") whose responsibilities will include those of the implementation and monitoring of the Saskatchewan Hockey Association Privacy Policy. The Privacy Officer will be responsible for Saskatchewan Hockey Association’s compliance with privacy principles. This person will also be responsible for responding to access requests in accordance with this Policy. The Privacy Officer will report to the Chairperson and the ultimate responsibility for Privacy issues will rest with the Saskatchewan Hockey Association Board of Directors. The Privacy Officer may at his/her discretion enlist assistance from staff members and/or volunteers within the organization. This will not in any manner mitigate his/her responsibility for Privacy issues.

1.2 The Privacy Officer’s identity will be fully disclosed and publicly accessible to Saskatchewan Hockey Association members and the public in general. Saskatchewan Hockey Association’s Privacy Officer is Kelly McClintock and can be reached at kellym@sha.sk.ca or by phone at 306-789-5101.

1.3 Saskatchewan Hockey Association’s Privacy Officer will ensure that Saskatchewan Hockey Association manages all personal information in its possession in accordance with this Policy including that, which may be transferred to a third party. Third party organizations who handle information on behalf of Saskatchewan Hockey Association shall be contractually obligated to adhere to the standards of Saskatchewan Hockey Association.

1.4 Saskatchewan Hockey Association will implement internal policies which will facilitate adherence to this Privacy Policy including but not limited to the following:

  • Security measures at all levels designed to protect personal information in our possession.
  • Implementing procedures designed to respond to complaints and/or inquiries.
  • Staff training in all facets of information management, including awareness of Saskatchewan Hockey Association’s Privacy Policy and policies and procedures developed in accordance with the Policy.

2. Identifying Purposes, Type of Information Collected and Website

2.1 Saskatchewan Hockey Association shall only collect the information reasonably necessary to conduct Hockey Programming. Access to our Privacy policies and procedures will be readily available. Similarly, the process by which challenges may be made to Saskatchewan Hockey Association’s compliance and/or adherence to the legislation in question shall be readily available and transparent. To obtain further information, contact Saskatchewan Hockey Association’s Privacy Officer. Saskatchewan Hockey Association’s Privacy Officer is Kelly McClintock kellym@sha.sk.ca or by phone at 306-789-5101.

2.2 Saskatchewan Hockey Association collects personal information from prospective members, members, coaches, officials, managers and volunteers for the purposes of conducting Hockey Programming. Specifically:

  • A player’s name, address and date of birth are collected to determine that the player’s geographical, division of play and level of play information are consistent with Saskatchewan Hockey Association regulations.
  • Historical information concerning past teams played for is collected in order to determine if any Saskatchewan Hockey Association transfer regulations may apply.
  • Information as to a player’s parents’ name, address, telephone numbers and email addresses may be collected in order to facilitate emergency contact information as well as to ensure compliance with Saskatchewan Hockey Association residency regulations.
  • Educational information may be collected in order to ensure all Saskatchewan Hockey Association residency regulations have been adhered to.
  • E-mail addresses may be collected for the purposes of facilitating membership communication related to upcoming events and programs.
  • Personal information collected for the purposes of hockey registrations may also be used for hockey specific research purposes including but not necessarily limited to hockey demographic type research.
  • Saskatchewan Hockey Association has numerous associations and leagues, which offer hockey programs under the auspices of Saskatchewan Hockey Association. These include the eight Zones and their associations, the Saskatchewan Junior League, Saskatchewan Major Junior League, and Saskatchewan Junior B, Senior Female, Senior Male, Junior Female and the Saskatchewan AAA leagues. Saskatchewan Hockey Association discloses the personal information described in paragraph 2.2 to all of these organizations in order to facilitate Hockey Programming and ensure compliance with rules and regulations.
  • Potential and actual insurance claims and the subsequent investigation thereof.
  • Appeals and regulations challenges as well as information collected to defend Saskatchewan Hockey Association against legal action brought against Saskatchewan Hockey Association.

2.3 Saskatchewan Hockey Association will endeavor through its member partners, associations/leagues to advise potential registration candidates of the purpose for the collection of the data requested at the time of registration or by reference to our web site at www.sha.sk.ca. We will further endeavor to ensure that all collectors of the personal information are familiar with the potential use of the personal data. All personal data collected by Saskatchewan Hockey Association shall be maintained in our main office.

2.4 Saskatchewan Hockey Association will request individually permission for the use of any personal data collected which is extraneous to that which has been identified above, unless said usage is authorized by law.

2.5 Saskatchewan Hockey Association may also use information about an individual who accesses secure areas of

www.sha.sk.ca. Information you are asked to provide during your use of our web site may include your name, address, e-mail address, age, sex [and the other types of personal information listed in paragraph 2.2]. All such personal information will be treated within the same parameters as other personal information collected by Saskatchewan Hockey Association through other means. It is always your choice to provide information in certain fields although failure to complete certain sections may inhibit your ability to fully access all areas of the web site. Our web site also collects non-identifiable information about users such as the users IP address, the sections of the website visited and the information downloaded. Saskatchewan Hockey Association may use this non-identifiable information and disclose it to service providers, for system administration purposes and to improve the web site.

3. Consent

3.1 Saskatchewan Hockey Association will use the personal information for the uses specified above in section 2 and in Sections 3.2 and 3.3 below. By consenting to provide your information to Saskatchewan Hockey Association, you are deemed to consent to our use of the information for the purposes of Hockey Programming listed in Section 2 of this Privacy Policy and to disclosure of the information to other associated organizations for the same purpose.

3.2 In addition to using personal information for Hockey Programming purposes, Saskatchewan Hockey Association may from time to time wish to use member name, address and contact information for the purposes of providing promotional opportunities, including by providing the information to Saskatchewan Hockey Association’s leagues and associations and/or other third parties, whom Saskatchewan Hockey Association believes provide services or goods that may be of interest to you. Saskatchewan Hockey Association and any such third parties may contact you with promotions [or to provide further hockey specific communications and association/league information updates]. Saskatchewan Hockey Association will provide an opportunity for the member to consent to these opportunities during the registration process. If you consent but later wish to opt out of this use of information later, you may do so by contacting us as described at Section 3.4 below.

3.3 Saskatchewan Hockey Association recognizes that hockey by its nature is a contact sport and injuries are to a certain extent inherent in the game. We believe medical records, medical history and medical forms of the individual may be of assistance in an emergency situation and therefore we may request them. While our members and prospective members are under no obligation whatsoever to supply this information and may refuse to do so without penalty, Saskatchewan Hockey Association will consider receipt of this information as consent for its subsequent use in an emergency medical situation.

3.4 If at any time you wish to withdraw your consent to the use of your information for any purposes, you may do so by contacting the Privacy Officer for Saskatchewan Hockey Association. We will do our best to accommodate your request in a timely fashion without diminishing the services we provide to you. We will explain to you the impact of your withdrawal on any services we provide to you.

3.5 Saskatchewan Hockey Association may collect personal information without consent where reasonable to do so and where permitted by law.

4. Limiting Collection

4.1 All information shall be collected fairly and lawfully within the criteria as set forth in our Privacy Policy.

4.2 Saskatchewan Hockey Association shall not indiscriminately collect information. The amount and type of information we collect shall be limited to that which is required to fulfill our identified purposes.

4.3 Saskatchewan Hockey Association will not use any form of deception in gaining personal information from its members.

5. Limiting Use, Disclosure and Retention

5.1 Subject to applicable legislation, Saskatchewan Hockey Association shall limit use of personal information it collects to purposes that we have disclosed in Sections 2 (Identifying Purposes) and 3.2, Consent.

5.2 Saskatchewan Hockey Association shall maintain documents for certain periods of time dependent upon necessity. More specifically:

  • We will normally maintain registration data for a three year period after an individual has left our programs in the event that an individual chooses to return to our programs after leaving.
  • Parental/family information will be normally maintained for a similar three year period after a member has left our programs.
  • Affiliates. Saskatchewan Hockey Association has numerous organizations, which offer hockey programs under the auspices of Saskatchewan Hockey Association. As explained above, Saskatchewan Hockey Association may from time to time share information with these, associations, and leagues in order to facilitate Hockey Programming and ensure compliance with rules and regulations.
  • Saskatchewan Hockey Association may from time to time enlist the services of third party vendors in order to provide hockey programs, technical and support services. Prior to enlisting the services of these firms we will contractually commit them to treat your personal information consistent with the Privacy Policy of Saskatchewan Hockey Association.
  • Saskatchewan Hockey Association may at some point be involved in the sale, merger, transfer or reorganization of its activities. We may disclose personal information to the other party in such a transaction. Saskatchewan Hockey Association will ensure that we contractually obligate the other party to treat this information in a manner consistent with our Privacy Policy.
  • Saskatchewan Hockey Association may disclose your personal information to a government authority that has asserted its lawful authority to obtain the information or where the association has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court, person, or body with jurisdiction to compel the production of the information or otherwise as permitted by applicable law.
  • Saskatchewan Hockey Association may at its discretion release personal information for the purposes of collecting debts, which may be owed to Saskatchewan Hockey Association.

5.3 Certain documents may be subject to legislated retention periods either federally or provincially and these will be respected at all times by Saskatchewan Hockey Association.

6. Accuracy

6.1 Saskatchewan Hockey Association shall strive to ensure to the extent it can that the information entrusted to us is maintained in an accurate manner. We shall try to maintain the interests of the individual and attempt to ensure that decisions are not made for or about an individual based on personal information that is flawed.

6.2 Saskatchewan Hockey Association shall only update information in the event of a renewal or registration and/or an update.

7. Safeguards

7.1 Security safeguards have been implemented to ensure your personal information is protected from theft as well as unauthorized access, disclosure, copying, use or modification thereof.

7.2 The level of safeguards employed shall be directly related to the level of sensitivity of the personal information collected. The more sensitive the information, the higher the level of security employed.

7.3 Methods of protection and safeguards to be employed shall include but in no way be necessarily limited to locked files, offices and storage areas, security clearances and need to know access as well as technological measures such as passwords and encryption.

8. Openness

8.1 Saskatchewan Hockey Association publicly discloses the methods by which we handle your personal information. This information is readily available through our Privacy Policy, on our web site or upon request by contacting the Saskatchewan Hockey Association Privacy Officer is Kelly McClintock and can be reached at kellym@sha.sk.ca  or by phone at 306-789-5101.

8.2 The information available includes:

  • The name address and phone number of the Saskatchewan Hockey Association Privacy Officer.
  • The forms (attached) which you may use to access your information or change your information.
  • A description of the type of personal information held by Saskatchewan Hockey Association and our general uses thereof. This includes: registration information, including name, date of birth, address, past teams played on, medical information and e-mail addresses
  • Information used for scouting, potential sponsorship opportunities, donors, alumni and information retained for the purposes of Saskatchewan Hockey Association business contacts.
  • Information that may be made available to related organizations, associations, leagues and/or third party service providers, in accordance with the provisions of this Privacy Policy.

9. Individual Access

9.1 Subject to applicable legislation, upon request by the individual concerned Saskatchewan Hockey Association shall disclose whether or not it actually holds personal information on an individual. We shall disclose the source of this information when requested and provide an account of third parties to whom the information may have been disclosed.

9.2 Saskatchewan Hockey Association may request sufficient information to confirm your identity before releasing your personal information to you.

9.3 Subject to applicable legislation, Saskatchewan Hockey Association shall endeavor to provide this information within 30 days of receipt of the information requested and only charge nominal fees for the purpose of off-setting its expenses incurred in supplying the requested information. This information shall be provided in an understandable format at the time you make a request.

9.4 Any inaccurate information that is brought to our attention shall be corrected by Saskatchewan Hockey Association as quickly as possible and any pertinent third parties shall be appraised of the corrections in due course.

10. Challenging Compliance

10.1 Saskatchewan Hockey Association has in place procedures for the resolution of grievances in the administration of its Privacy Policy.

10.2 Upon receipt of a complaint Saskatchewan Hockey Association shall make available the complaint procedures which will be simple and easy to access.

10.3 Saskatchewan Hockey Association shall investigate all complaints. If the complaint is deemed justified Saskatchewan Hockey Association shall take the appropriate steps to ensure that compliance is achieved and will make changes to its policies to allow for compliance in the future.

10.4 All complaints shall be addressed to the Saskatchewan Hockey Association Privacy Officer Kelly McClintock and can be reached at kellym@sha.sk.ca or by phone at 306-789-5101.

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