Excerpt from the Alberta Gymnastics Policy and Procedure Guidelines

The privacy of individuals connected with the sport of gymnastics, including athletes, coaches, parents and website visitors is of great importance to the Alberta Gymnastics Federation (“AGF”). Keeping personal information in strict confidence is an important aspect of our organization. Regardless of how the range of products and services we offer our members expands, and the technology we use changes, we will always strive to protect the privacy of personal information, subject to any consent an individual has provided for its use.

This policy describes the principles on which AGF and its member clubs will protect the privacy of personal information. The policy is based on the Canadian Standards Association Model Code for the Protection of Personal Information. This policy is part of AGF’s commitment to ensure that all personal information of individuals in its possession is protected and used in accordance with the law. Privacy laws across Canada are evolving, and therefore this policy is subject to change.

Personal Information is any information about an identifiable person, other than the name, title, business address and business telephone number of a person. It includes such things as a person’s home address, date of birth, social insurance number, medical and financial information. With respect to athletes, such information is collected primarily in connection with services provided by AGF. Clubs may be asked to provide such information to AGF in connection with matters relating to their membership. In all cases, AGF is committed to protecting the privacy of individuals and the integrity of their personal information.

Accountability

AGF is responsible for personal information under its control, including any personal information disclosed to third parties for handling or administrative purposes. AGF has designated a Privacy Officer who is accountable for AGF’s compliance with this Policy and with privacy legislation.

While ultimate accountability for AGF’s compliance with the Policy rests with the Privacy Officer and the staff of AGF.

With respect to personal information that has been transferred to a third party for processing, AGF will use contractual or other means, which may include the examination of such third party’s practices with respect to personal information, to safeguard personal information while it is being handled by a third party.

AGF has implemented internal guidelines and practices to give effect to this Policy, including:

1. establishing procedures to protect personal information;
2. establishing procedures to receive and respond to complaints and inquiries;
3. developing information to explain AGF’s policies and procedures; and
4. training staff and communicating to staff information about AGF's policies and procedures.

AGF has implemented practices to effectively monitor compliance with this policy across its business, including the appointment of a Privacy Officer.

Identifying the Purposes for which Personal Information is Collected

The purposes for which personal information is collected will be identified by AGF at or before the time the information is collected, unless such purposes are obvious.

AGF will ensure that the purposes for which personal information is collected and the way in which the information may be used are clear to the individual. In some cases, the purpose will be clear from the context of the interaction, in other circumstances, a written or verbal explanation may be required.

Consent

AGF will not collect, use or disclose the personal information of a person without the individual’s knowledge and consent, except in certain limited circumstances permitted by law, such as where immediate health of a person is at risk, or in connection with the breach of an agreement or a law.

AGF will obtain consent, either express or implied, for the use or disclosure of personal information at the time of the collection of the information. In certain circumstances, consent with respect to use or disclosure will be sought after the information has been collected but before use, particularly if AGF wants to use the information for a purpose not previously identified to the individual.

AGF is committed to obtaining meaningful consent to the collection, use and disclosure of personal information. To achieve this aim, the purposes for which the information will be used, if not obvious, will be explained in such a manner that the individual can reasonably understand how the information will be used or disclosed.

AGF will not, as a condition of the supply of a product or service, unreasonably require an individual to consent to the collection, use, or disclosure of information beyond what is required in the circumstances.

The way in which AGF seeks consent may vary, depending on the circumstances and the type of information collected. In determining the type of consent that may be required, AGF will consider the nature of the information, the use to which the information will be put, applicable laws and the type of interaction in which the information is provided.

Consent may be express or implied, given orally, electronically or in writing and provided by an action or inaction. Consent may be given through a legally appointed representative or a legal guardian.

An individual, subject to legal or contractual limitations, may withdraw his or her consent at any time on sufficient notice to AGF. Withdrawal of consent may result in AGF becoming unable to provide or continue to provide the person with certain services, or membership and the individual will be given notice of the implications of the withdrawal of his or her consent.

Limits on the Collection of Personal Information by AGF

The collection of personal information by AGF will be limited to that which is necessary for the purposes identified by AGF. At all times, AGF will collect personal information by fair and lawful means.

Limits on the Use, Disclosure and Retention of Personal Information by AGF

Personal information will not be used or disclosed by AGF for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information will be retained only as long as reasonably necessary for the fulfillment of those purposes or as required by law.

Accuracy of Personal Information held by AGF. AGF will make reasonable efforts to ensure that personal information of individuals is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Personal information will not be updated without the consent of the individual and it will only be updated if it is necessary for the continued use of the personal information.

AGF will make reasonable efforts to obtain information from individuals in order to update information on hand if required to fulfill the purposes for which the information was collected. Once informed by a person that personal information held by AGF about them is inaccurate, AGF will update the information as soon as possible.

Safeguarding Personal Information

AGF will protect personal information by the use of security safeguards appropriate to the sensitivity of the information.

AGF will employ security safeguards that will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which the information is held.

The nature of the safeguards used by AGF will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage of the information. A higher level of protection will safeguard more sensitive information.

The methods of protection used by AGF will include:

1. physical measures, for example, locked filing cabinets and restricted access to offices;
2. technological measures, for example, the use of passwords and encryption.

AGF will ensure that its employees who are in contact with personal information are trained in the appropriate protection of personal information and that they are aware of the importance of maintaining the confidentiality of personal information. Employees are required to abide by this Policy.

Openness

AGF will make available to individuals information about its policies and practices relating to the management of personal information. AGF is open about the policy it has to ensure the protection of personal information.

AGF will make this information readily available to individuals. The information will be made available in a form that is generally understandable.

AGF may make information on its policies and practices available in a variety of ways, depending on the nature of the personal information.

Individual Access to Personal Information

Upon the receipt by AGF of a written request, an individual will be informed, within a reasonable time following such request, of the existence, use, and disclosure of his or her personal information and will be given access to that information. In certain limited circumstances, as permitted by law, certain information, such as that collected and held in the context of an investigation may not be disclosed to the individual. AGF has established procedures for an individual to follow in order to access their personal information.

Subject to applicable laws, upon receipt of a written request from an individual, AGF will inform him or her whether or not AGF holds personal information about the individual and make reasonable efforts to indicate the source of the information. In addition, AGF will, upon written request, provide a summary of the use that has been made or is being made of this information.

An individual may be required to provide sufficient information to permit AGF to provide an account of the existence, use, and disclosure of personal information. The information provided will only be used for this purpose.

Upon receipt of a written request, AGF will provide an individual the identities of third parties to which it may have disclosed personal information about the individual and the purpose for which the information may have been disclosed to the third party.

AGF may charge a reasonable fee to cover its cost of providing the information, provided that AGF will inform the individual of the approximate cost of providing the information prior to doing so and will afford the individual the opportunity to withdraw his or her request.

If an individual successfully demonstrates the inaccuracy or incompleteness of personal information held by AGF, AGF will amend the information as required. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.

AGF may decline to provide an individual access to his or her information in accordance with applicable laws. If such a refusal is made, AGF will inform the individual of the reasons why such access has been denied, except when AGF is prohibited from doing so by law.

Confidentiality

Where the behaviour reported in a Report of Violation may constitute harassment, or is of a similar highly sensitive nature, AGF shall keep all proceedings under this policy confidential, except where disclosure is directed by the Panel as part of a sanction, is required by law or is in the best interests of the public.

Throughout the process of this policy, every effort will be made to maintain confidentiality and information relating to the complaint, including contact of meeting interviews, results of investigations, and other relevant material. Disclosure will only occur if it is directed by the Panel as part of a sanction, is required by law or is in the best interests of the public.

Complaints and Questions

A person about whom personal information is kept may challenge AGF concerning its compliance with this Policy.

Complaints and questions regarding AGF’s compliance with this Policy may be made in writing to the AGF President/CEO at #207-5800-2 St. S.W., Calgary, Alberta or by phone at 403-259-5500 or by e-mail at abgym02@abgym.ab.ca

AGF has procedures in place to receive and respond to inquiries or complaints about this Policy and its practices relating to the handling of personal information. These procedures will be provided upon request and are easily accessible on AGF’s website, www.abgym.ab.ca, and in other published material with respect to privacy.

If an individual is not satisfied with a response by AGF to a complaint or is otherwise not satisfied with AGF’s policies and practices with respect to its handling of personal information, a complaint may be made to the provincial privacy commissioner of the province where the personal information of the individual is kept, or to the Federal Privacy Commissioner at 112 Kent Street, Ottawa, Ontario, K1A 1H3, 1-800-282-1376.

More information can be obtained at the federal privacy commissioner’s website, www.privcom.gc.ca.