Seasons Centre for Grieving Children’s Policy on Privacy of Supporters or Participants’ Personal Information
Seasons Centre for Grieving Children (SCGC) will comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), a federally enacted act to protect personal information that is collected, used, or disclosed. For the purposes of this Policy, personal information means information about an identifiable individual, exceeding what is normally on a business card or in a telephone book, i.e. name, title, business address or telephone number. Any reference to a guest within this Policy is in reference to personal information and not business information.
PIPEDA is based on ten (10) fundamental and internationally recognized principles, as follows:
II. Identifying Purpose
IV. Limiting Collection
V. Limiting Use, Disclosure & Retention
IX. Individual Access
X. Challenging Compliance
Seasons Centre has implemented policies and procedures to give effect to these principles, including:
- Implementing procedures to protect personal information.
- Establishing procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information by Seasons Centre for Grieving Children.
- Training staff and communicating information to staff about Seasons Centre for Grieving Children policies and procedures.
- Developing information to explain Seasons Centre for Grieving Children’s policies and procedures to Supporters or Participants.
These principals are explained in more detail below:
SCGC is responsible for the personal information under its control and has designated a Privacy Officer to be accountable for SCGC’s compliance with PIPEDA.
II. Identifying Purpose
SCGC will identify and document the purposes for which it collects personal information. Only personal information that is neccessary for those identified purposes will be collected. If Seasons Centre intends to use the personal information that has been collected for a new purpose, this new purpose will be identified and consent for such new purpose will be obtained from the guest to which the personal information relates prior to using such personal information. SCGC shall only collect, use and disclose personal information about Supporters or Participants for the following purposes:
- to facilitate return visits and, wherever possible, to meet Supporters or Participants’ personal preferences
- to advise Supporters or Participants of goods and services by or by arrangement with the company
- to improve the offering of goods and services to Supporters or Participants
- to assist SCGC in the collection of fees and other charges owing with respect to services rendered by Seasons Centre
- to assist Seasons Centre in revenue management with respect to the centre
- to assist SCGC in communication with users of the Resort for the purpose of promoting the use of the Centre
- to assist an entity with whom SCGC has an agreement relating to the collection of fees and other charges in connection with the use of the Resort
Seasons Centre for Grieving Children does not sell or trade personal information about Supporters or Participants to any third party agencies.
Guest inquiries regarding the purposes for the collection, use and disclosure of personal information will be addressed by SCGC or referred to the Chief Privacy Officer
The knowledge and consent of Supporters or Participants is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law. SCGC will seek consent for the collection of personal information at the time of collection, wherever possible. Seasons Centre will make a reasonable effort to ensure that Supporters or Participants are advised of the purposes for which the personal information being collected will be used, and will state the purposes in a manner that will allow Supporters or Participants to reasonably understand how their personal information will be used or disclosed by SCGC.Consent may be obtained in a variety of ways, for example, through contracts and registration forms, orally by telephone or by electronic media, depending on the circumstances and the type of personal information being collected, and in particular, on the sensitivity of the personal information. The reasonable expectations of Supporters or Participants will be considered when obtaining consent. For example, where Supporters or Participants provide their names and addresses for mailing and billing purposes, they should reasonably expect that this information would also be used for sending out Guest Satisfaction Surveys, where the choice to respond is the Guest’s.In certain circumstances, personal information can be collected, used, or disclosed without the knowledge or consent of the Guest. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. Seeking consent may be impossible or inappropriate when there is an emergency threathening the Guest’s life, health, or security, or where the Guest is a minor, seriously ill or mentally incapacitated.Although information may be publicly available, SCGC will treat this in accordance with PIPEDA principals. Moreover, SCGC may provide personal information to its lawyers, advisors, agents and/or third parties to collect a debt, comply with a subpoena, warrant or other court order, to a government institution, requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.
The use of SCGC will be considered consent to collect, use and disclose personal information for stated purposes.
A Supporter or participant may withdraw consent by providing reasonable notice to Seasons Centre’s Privacy Officer. SCGC will inform the Guest of any implications of such withdrawal. Any withdrawal of consent will still allow SCGC to use and disclose a supporter or participant’s personal information in order to collect or enforce payment of amounts owing as a result of a Supporter or participant’s previous or continuing use of the Centre. Subsequent use of the Centre will automatically provide consent for the collection, use, disclosure and retention of personal information.
IV. Limiting Collection
The collection of personal information will be limited to that which is appropriate in the circumstances.SCGC collects some information about prospective Supporters or Participants using technology, so it may not be readily apparent to prospective Supporters or Participants that it is being collected. For instance,Seasons Centre collects some information about prospective Supporters or Participants using technology, so it may not be readily apparent to prospective Supporters or Participants that is being collected. For instance, when a prospective Supporter or Participant visits our website, their IP address is collected so that we know how many visits we have had by separate individuals. An IP address is often associated with the place from which a prospective Supporter or Participant enters the Internet like their Internet Service Provider (ISP), their firm or company or their university. This information is not personally identifiable.
SCGC may use “cookie” technology to obtain non-personal information from its online visitors for certain purposes. The cookie is stored on their computer to allow them to get back into certain areas of the website with as minimal delay as possible. We do not extract personal information in this process nor do we disclose this information. Cookies are tools that allow us to update and improve our sites.
V. Limited Us, Disclosure & Retention
Seasons Centre will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the Supporter or Participant or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.SCGC may disclose a Supporter or Participant’s personal information to third parties retained by Seasons Centre for the purposes of billing such a Supporter or Participant for the use of Seasons Centres properties and/or facilities, and to collect and enforce payment of amounts owing by such Supporters or Participants.Certain Seasons Centres employees and third party agents may be given access to a Guest’s personal information collected by Seasons Centre in so far as their duties require access for the purposes outlined above. SCGC employees and such third party agents are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated purpose.
Person information that has been used to make a decision about a Supporter or Participant will be retained in accordance with the SCGC document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. SCGC retains personal information of a Supporter or Participant only for as long as it is required for SCGC’s business purposes or as required by federal and provincial laws.
Seasons Centre will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.SCGC will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. SCGC will take reasonable steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is accurate and up-to-date.Access to a Supporter or Participant’s personal information on record with SCGC may be requested by that Supporter or Participant in order to review and amend their personal information, as appropriate. In circumstances where personal information has been provided by a third party, Seasons Centre will refer the Supporter or Participant to that party. It is the responsibility of the third party to maintain accuracy of the personaly information that is provided by them. To access your personal information, refer to “how to contact us” located at the bottom of this page.
Seasons Centre for Grieving Children will take reasonable steps to protect personal information through security safeguards appropriate to the sensitivity of the personal information. Team Members of Seasons Centre who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. As a condition of employment, all new employees/agents must sign the SCGC Confidentiality Agreement. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Care will be used in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.
SCGC will make readily available to Supporters or Participants specific information about its policy and guidelines relating to the management of personal information. Seasons Centre will be open about its policy and procedure with respect to the management of personal information, and Supporters or Participants will be able to acquire information about these policies easily and in a form that is generally understandable.
IX. Individual Access
Seasons Centre will inform a Supporter or Participant of the existence, use and disclosure of their personal information (including to third parties) and will provide access to that personal information, upon written request. SCGC will assist a Supporter or Participant in the preparation of a request for access when such a Supporter or Participant requires assistance. SCGC will inform the Supporter or Participant whether or not it holds personal information about them, and will indicate the source of any such personal information, when possible.There may, however, be situations in which SCGC will not be able to provide access to all the personal information that it holds about a Supporter or Participant, although these situations will be limited and specific, and permitted or required by law. For example, Seasons Centre will not be able to provide access to a Supporter or Participant’s personal information where giving such access would likely reveal personal information about a third party, unless that third party’s personal information can be severed from the Supporter or Participant’s personal information. If Seasons Centre refuses a request for access, the Supporter or Participant will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Supporter or Participant of their recourse.Seasons Centre will require that Supporters or Participants requesting access to their personal information provide the appropriate verification information reqiured to obtain access to such personal information. This information will not be used for any purpose other than to permit Seasons Centre to provide an account of the existence, use and disclosure of the Supporters or Participants’ personal information.
Seasons Centre for Grieving Children will be as specific as possible in providing an account of third parties to which personal information has been disclosed, and will provide a list of organizations to which personal information may have been disclosed when it is not possible to provide a list of the organizations to which specific personal information have actually been disclosed.
Seasons Centre will respond to a Supporter or Participant’s request to access their personal information within a reasonable time, and not later than 30 days after receipt of the request. Seasons Centre may be entitled to a 30 day extension to respond, in limited circumstances, in which case the Supporter or Participant will be notified of such an extension, the new time limit, the reasons for extending the time limit, and their right to make a complaint to the Privacy Commissioner with respect to the extension.
SCGC may charge a reasonable fee for responding to a request. This fee will be determined based on the request any any request specific administrative or system costs that may be incurred, and will advise the Supporter or Participant, in advance, of the approximate cost. The personal information requested would be provided in a form that is generally understandable.
A Supporter or Participant will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or addition of information, and the amended information will be transmitted to third parties having access to the personal information, where appropriate.
X. Challenging Compliance
A Supporter or Participant will be able to address a challenge concerning compliance with the above principles to the Chief Privacy Officer. Seasons Centre will handle all complaints or inquires about the policies and procedures relating to the handling of personal information in line with the processes that are in place.
SCGC will inform Supporters or Participants who make inquires or lodge complaints of the existence of the relevant complaint procedures. Seasons Centre will investigate all complaints, and if a complaint is justified, Seasons Centre will take appropriate measures, including amending policies and procedures.
How to Contact Us:
- By telephone at 705.721.5437
- By Email at email@example.com
- In writing to the Chief Privacy Officer, Season Centre for Grieving Children, 38 McDonald Street, Barrie, Ontario L4M 1P1.
- or in person at 38 McDonald Street, Barrie, Ontario
If the issue is still not resolved to your satisfaction, you may file a complaint with the Privacy Commissioner of Canada at firstname.lastname@example.org or by calling 1.800.282.1376.