The Starr Gymnastics Privacy Code

Our Privacy Commitment to You

Starr Gymnastics (hereinafter"Starr") is demonstrating its commitment to protecting the privacy of its clients and employees by developing and implementing this Privacy Commitment for the Protection of Client and Employee Information.

The Starr Privacy Commitment complies with, or exceeds, the federal Personal Information Protection and Electronic Documents Act (hereinafter "PIPEDA"). This Privacy Commitment applies to the collection, storage, use, disclosure, protection, and accuracy of personal information collected and controlled by Starr. The policy is organized according to the principles of the Canadian Standards Association's Model Code, which forms the base of PIPEDA.

We invite you to address any questions you may have about personal information and about our policy to our Office Administrator.

Starr will continue to review its Privacy Code to ensure it is relevant and remains current with changing technologies and laws. Most importantly, Starr wants to ensure that it continues to meet the evolving needs of its clients and staff.

Definitions

Personal information - information about an identifiable individual. It includes, but is not limited to, age, name, home address and phone number, work phone number, email addresses, identification numbers, evaluations, employee files, and health records.

Under PIPEDA, personal information does not include a job title, business telephone number or business address.

Consent - voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require inference on the part of Starr. Implied consent arises where consent may reasonably be inferred from the action or inaction of the client or employee.

The Principles

1. Accountability

   Starr is responsible for personal information under its control. Starr shall use appropriate means to provide a comparable level of protection when information is being processed by a third party.

   Our Office Administrator is responsible for our privacy policies for both clients and staff information. She trains all our staff in how to handle the personal information of clients. She will also be happy to provide any information about your information, including copies of your personal information if we have that information. She can be reached at 613-721-4868, fax 613-721-6646, or email info@starrgymnastics.com. You may also write the Office Administrator at Starr Gymnastics, 1140 Morrison, Ottawa, Ontario.

2. Identifying Purposes

   At or before the time the information is collected, Starr shall identify the purposes for which personal information is collected.

   We gather client information only for the following purposes:

   • to serve the clients needs including for the provision of services, information and programs;
   • to send four newsletters per year which update clients with respect to registration;
   • to understand client needs, preferences and any health concerns;
   • to disclose personal information about its clients for normal personnel and accounting as well as for any legal proceedings;
   • to process payments, electronic receipts and to collect unpaid invoices; and
   • to manage and develop Starr's business and operations, including personnel and employment matters and to maintain good client and employee records.

   Starr shall specify orally, electronically or in writing the identified purposes to the client or employee at or before the personal information is being collected. Upon request, the person collecting the information shall explain these identified purposes or refer the individual to the Office Administrator within Starr who shall explain the purposes.

   Unless required by law, Starr shall not use or disclose for any new purpose personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the client or employee.

3. Consent

   The knowledge and consent of a client or employee is required for collection, use or disclosure or personal information, except where inappropriate.

   We do not gather information from anyone but our clients and employees, and we tell you when we are asking for information what it will be used for. In the event that an individual moves from his or her current address, we reserve the right to seek the new address or phone numbers.

   In certain circumstances, personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, Starr may collect or use personal information without the knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely fashion, such as when the individual is seriously ill, or in the case of an emergency where the life, health or the security of the individual is threatened.

   Starr may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement, a contravention of a federal or provincial law, or to comply with a subpoena, warrant or other court or tribunal order or as may be otherwise authorized by law.

   In determining the appropriate form of consent, Starr shall take into account the sensitivity of the personal information and the reasonable expectations of its clients and employees.

   Initially, when a new client is asked to complete an application form, express consent shall be sought when reasonably feasible. This will usually be done by clicking on the consent link on our on-line application form. Similarly, where registration is completed by telephone, a Starr representative will specifically request consent from the client and shall record the consent accordingly. In general, for existing clients, the use our facilities after having been informed of our privacy policy constitutes implied consent for Starr to collect, use and disclose personal information for all identified purposes.

   A client or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

4. Limiting collection

   Starr shall only use or disclose personal information in furtherance of that which is necessary for the purposes identified by it. Starr shall collect personal information by fair and lawful means.

   As indicated above, we limit the information we collect to that which is necessary to deliver services to the clients and to carry out standard billing and accounting practices. We keep on our client applications, registrations and file, if any, your name, address, phone and fax numbers and email address, any relevant health information and any information you may have given us with respect to your work environment.

5. Limiting Use, Disclosure and Retention

   Starr shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Starr shall retain personal information only as long as necessary for the fulfillment of those purposes.

   We use our information only for the purposes outlined above, and we do not sell or lend out information to anyone else.

   Law enforcement agencies have a right under various pieces of legislation to get information that may be necessary for investigations, however, we insist on warrants and lawful instruments before we provide any such information.

   We have a record of your applications and registrations and any employment related concerns an employee has filed and we keep these records in our computer database for ten years after the last active entry. If you ask us, we will keep these records in perpetuity; otherwise, we will purge the files at that time. We keep the records this long because accurate records of what happened during your membership in our club or employment can help immeasurably should any issue arise many years later.

6. Accuracy

   Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

   These documents are held securely and are not altered unless you ask us or we identify errors. If you have concerns about the accuracy of our records, please speak to our Office Administrator and she will be happy to assist you.

7. Safeguards

   Starr shall protect personal information by security safeguards appropriate to the sensitivity of the information.

   We keep all our membership and employee files on our computer database, which is controlled by the Office Administrator. Exceptionally, if a record needs to be taken from the database, Starr shall protect personal information disclosed to third parties by stipulating the confidentiality of the information and the purposes for which it is to be used. All our client information kept on disc or hard drive shall be protected through reasonable and appropriate security measures.

8. Openness

   Starr shall make readily available to clients and staff specific information about its policies and practices relating to the management of personal information.

   This policy is freely available. Any requests should be addressed to our Office Administrator.

9. Individual Access

   Starr shall inform a client or employee of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A client or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

   We will be happy to provide all clients or employees with a reasonable opportunity to review the personal information in their registration or file, if any. Personal information shall be provided in an understandable form within a reasonable time, and at a minimal cost, if any, to the individual. All such inquiries shall be made to our Office Administrator. In addition, if you feel that the information on your registration or file is inaccurate, you are invited to bring it to the attention of our Office Administrator and ask for it to be amended. In rare instances, we may not agree to amend the information, but we will be happy to add your notations about the information in the file.

   In certain circumstances, Starr may not be able to provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Starr may not provide access to information if disclosure would reveal confidential information if the information is solicitor-client privileged, if the information was generated in the course of a formal legal process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law.

   If access cannot be provided, Starr shall provide the reasons for denying access.

10. Challenging Compliance

    A client shall be able to address a challenge concerning compliance with the above principles.

    We are anxious to ensure that our privacy policy meets your concerns and responds to your needs. Our Office Administrator is available to receive your enquiries and complaints. Starr shall undertake to investigate all complaints and respond within ninety days. If the complaint is found to be justified, Starr shall take appropriate measures to resolve the complaint, including, if necessary, amending its policies and practices.

    If you are unhappy with the results of these discussions, you may complain to the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A 1H3.