Section No. 2.00: ORGANIZATIONAL | Policy No. 2.05: Privacy of Information |
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Approval Date: June 2020 | Revised: |
POLICY
All members of CZWKA will comply with the provisions for maintaining confidentiality of information.
PROCEDURES
The CZKWA Board of Directors will protect the personal information of its members with appropriate security safeguards. These will include protecting the confidentiality of personal information when dealing with other organizations. Provincial legislation and guidelines for the protection and release of personal information will be adhered to.
CZWKA will not collect, use or disclose personal information except for the purposes and in the time frames that it is collected. Personal information refers to factual or subjective information that might identify an individual. It does not include publicly available information about the names of members, titles and business contact information. Personal information can be in written, oral, or electronic form.
Personal information will be accurately maintained and updated as necessary. Members may request access in writing to their personal information at any time.
CZWKA club instructors will inform its members and their families of practices regarding policies for privacy of information during orientation to clubs or services.
All members have the right to refuse any disclosure of their personal information by informing the Membership Director in writing.
Collection and Use of Personal Information
Personal information will be collected by fair and lawful means. CZWKA will limit the collection and use of personal information from individuals to that which is required by law, and to that which is required to effectively plan and provide services.
Personal information will be collected directly from members via their instructors. Member registration will be on an electronic platform called Martial Member.
A member may withdraw consent to the collection, use or disclosure of personal information at any time. Such withdrawal of consent may be subject to legal or contractual restrictions and reasonable notice. CZWKA will inform the member of the consequences of a withdrawal of consent in a way that is relevant and meaningful to the member. CZWKA will inform the member that the withdrawal of consent may result in the possible termination of services provided by CZWKA because of the inability of the organization to administer its contractual or service delivery responsibilities.
CZWKA will only collect information for purposes such as:
- To determine the suitability of services for members and to evaluate access to services,
- To understand the needs and objectives of club members and instructors,
- To plan and/or deliver services to club members and instructors,
- To fulfill the CZWKA requirement to provide service outcomes outlined in its contracts with funders,
- To keep individuals, members and other stakeholders informed of CZWKA activities.
Disclosure of personal information to third parties
Personal information about members will not be disclosed to third parties without express consent from the member. Members will be informed of the purpose for disclosing the information and its implications in an appropriate manner.
The member will also be invited to participate in disclosures if they are interested in doing so.
CZWKA will not disclose information that it deems unnecessary or irrelevant to the stated purpose of information requests.
Disclosures to Family Members
CZWKA recognizes the role that family members play in the lives of children and youth but also values their right to have their information kept private and disclosed only with their consent.
CZWKA may share information with family members when it is in the best interests of the members and obtain written informed consent from an adult individual when required.
CZWKA club instructors will disclose information to family members if they feel that the health and safety of a member might be at risk.
Protection of personal information
The Board of Directors will assign the Membership Director as the Privacy Officer for the organizations who will oversee all CZWKA practices, procedures and decisions related to information privacy.
CZWKA takes reasonable steps to protect personal information in all formats against theft, unauthorized access, disclosure, copying, use, modification or disposal.
Consents
Written consent is required for the use and disclosure of personal information to third parties. CZWKA accepts written consent to the use of personal information in the form of emails, letters, designated forms, or facsimiles from members and club instructors.
Consent will be specific with respect to the information that can be disclosed and to whom the information can be disclosed.
Consent for Minors
A parent or legal guardian must provide consent for the participation of children or youth who are considered as minors for all programs, activities and events.
Use of photography or publication
Authorization and consent must be obtained from children and youth to use any videotapes, audiotapes, motion pictures, photographs or other materials involving their likeness and voice. This will be documented on the “Authorization and Consent for Use of Photographs and Publication” form (See Appendix).
Circumstances where consent is not required
CZWKA may lawfully collect, use or disclose information without the knowledge or consent of the individual where:
- Information is clearly in the interests of the member and timely consent cannot be obtained
- Required and considered reasonable for purposes of an investigation or legal incident,
- Required and considered reasonable for investigation of a law that might have been or is about to be broken
- Information is publicly available
- Required or authorized by law (e.g. to comply with a subpoena, warrant or order issued or made by a court, person or body with valid jurisdiction)
- To respond to an emergency that threatens the life, health or security of a member
Accuracy of Records
CZWKA will make every reasonable effort to ensure that the personal information it collects and uses is accurate and complete. Electronic files and records will be held secure and confidential, except with respect to authorized access through policy or by statutory authority.
Club instructors are responsible for updating member information as soon as it changes. Members may request changes to applicable records when they believe that the information is inaccurate. CZWKA must be satisfied that incorrect information already exists before replacement with new information.
Access to Records
CZWKA will limit access to member data on a “need to know” basis. The Board of Directors have access to member information. A member has the right to view their own data. Reasonable effort will be made to provide members with information when requested.
The Martial Member Administrator will have access to compile, classify, interpret, read, retrieve, transfer or destroy data as directed by the Board of Directors.
Responsibility of: Board of Directors
Monitored by: Privacy Officer
References:
Policy:
Appendix: 2.05 Authorization for the Use of Photographs and Publications Form