Camp Simpresca will comply with: (i) Personal Information Protection and Electronic Documents Act (“PIPEDA”), a federally enacted act which protects personal information that is collected, used or disclosed; (ii) other acts which protect personal information and privacy; and (iii) any future provincial protection of privacy legislation as it relates to the rights of campers. For the purposes of this policy, personal information means information about an identifiable individual but does not include the name, title or business address or telephone number of an employee of an organization. Any reference to a camper within this policy is in reference to personal information and not business information (“Camper”).
Camp Simpresca has implemented policies and procedures to give effect to
the 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 Camp Simpresca
- Training staff and communicating information to staff about Camp Simpresca’s policies and procedures
- Developing information to explain Camp Simpresca’s policies and procedures to Campers and/or a Camper’s guardian
Camp Simpresca is responsible for the personal information under its control and has designated a Privacy Officer to be accountable for Camp Simpresca’s compliance with PIPEDA.
2. Identifying Purpose
Camp Simpresca will identify and document the purposes for which it collects personal information. Only personal information that is necessary for those identified purposes will be collected. If Camp Simpresca 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 Camper or in the case of a minor, a Camper’s guardian to which the personal information relates prior to using such personal information. Camp Simpresca shall only collect, use and disclose personal information about Campers for the following purposes:
a. To assist Camp Simpresca in the collection of fees and other charges owing with respect to Camp Simpresca
b. To assist Camp Simpresca in the assignment of cabin placements
c. To assist Camp Simpresca in the treatment of known medical conditions or unknown medical conditions that may arise during their time while in the care of Camp Simpresca
d. To assist Camp Simpresca in communication with users of the Camp for the purpose of promoting the use of the Camp (including the use of photographs on our website and brochures)
Camp Simpresca does not collect and use personal information about
Campers for the following purposes:
a. To sell Camper lists to third party agencies. Camper or in the case of a minor, a Camper’s guardian inquiries regarding the purposes for the collection, use, and disclosure of personal information will be addressed by Camp Simpresca or referred to the Privacy Officer.
The knowledge and consent of Campers, or in the case of a minor, a Camper’s guardian, is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law. Camp Simpresca will seek consent for the collection of personal information at the time of collection, wherever possible. Camp Simpresca will make a reasonable effort to ensure that Campers, or in the case of a minor, a Camper’s guardian 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 Campers, or in the case of a minor, a Camper’s guardian to reasonably understand how their personal information will be used or disclosed by Camp Simpresca.
Consent may be obtained in a variety of ways, for example, through an application form, orally by telephone or by electronic media (e-mail), 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 Campers, or in the case of a minor, a Camper’s guardian will be considered when obtaining consent. For example, where Campers, or in the case of a minor, a Camper’s guardian provide their names and addresses for mailing and billing purposes, they should reasonably expect that this information would also be used for sending out Camper Satisfaction Surveys, where the choice to respond is the Campers’, or in the case of a minor, a Camper’s guardian.
In certain circumstances, personal information can be collected, used or disclosed without the knowledge or consent of the Camper, or in the case of a minor, a Camper’s guardian. 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 threatening the Camper’s life, health or security, or where the Camper is a minor, seriously ill or mentally incapacitated.
Although information may be publicly available, Camp Simpresca will treat this in accordance with PIPEDA principles. Moreover, Camp Simpresca may provide personal information to its lawyers, advisors, agents and/or third parties to 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.
Consent may be withdrawn by a Camper, or in the case of a minor, a Camper’s guardian by providing reasonable notice to Camp Simpresca to the Privacy Officer. Camp Simpresca will inform the Camper, or in the case of a minor, a Camper’s guardian of any implications of such a withdrawal.
4. Limiting Collection
The collection of personal information will be limited to that which is appropriate in the circumstances.
The Camp Simpresca Website does not use or capture cookies; a technology that installs a small amount of information on a visitor’s computer to permit the Website to recognize future visits from that computer. The only information collected through the Website, other than that provided by the Camper, or in the case of a minor, a Camper’s guardian voluntarily to initiate a transaction, is browser information used only to solve errors on processing transactions, when these occur.
5. Limiting Use, Disclosure & Retention
Camp Simpresca will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the Camper, or in the case of a minor, a Camper’s guardian or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.
Certain Camp Simpresca employees may be given access to a Camper’s personal information collected by Camp Simpresca in so far as their duties require access for the purposes outlined.
Personal information that has been used to make a decision about a Camper will be retained in accordance with the Camp Simpresca document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. Camp Simpresca retains personal information of a Camper only for as long as it is required for Camp Simpresca’s business purposes or as required by federal and provincial laws.
Camp Simpresca 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.
Camp Simpresca will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. Camp Simpresca will take reasonable steps to ensure that personal information that is used on an ongoing basis is accurate and up-to-date.
Access to a Camper’s personal information on record with Camp Simpresca may be requested by that Camper, or in the case of a minor, a Camper’s guardian in order to review and amend their personal information, as appropriate. To access your personal information, refer to “How to contact us”.
Camp Simpresca will take reasonable steps to protect personal information through security safeguards appropriate to the sensitivity of the personal information. Employees of Camp Simpresca who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
Camp Simpresca will make readily available to Campers, or in the case of a minor, a Camper’s guardian specific information about its policy and guidelines relating to the management of personal information.
Camp Simpresca will be open about its policy and procedure with respect to the management of personal information, and Campers, or in the case of a minor, a Camper’s guardian will be able to acquire information about these policies easily and in a form that is generally understandable. This policy and any related information is available at all times on Camp Simpresca web site, www.simpresca.net under Privacy.
9. Individual Access
Camp Simpresca will inform a Camper, or in the case of a minor, a Camper’s guardian 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. Camp Simpresca will assist a Camper, or in the case of a minor, a Camper’s guardian in the preparation of a request for access when such a Camper requests assistance. Camp Simpresca will inform the Camper, or in the case of a minor, a Camper’s guardian 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 Camp Simpresca will not be able to provide access to all the personal information that it holds about a Camper, although these situations will be limited and specific, and permitted or required by law. For example, Camp Simpresca will not be able to provide access to a Camper’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 Camper’s personal information. If Camp Simpresca refuses a request for access, the Camper, or in the case of a minor, a Camper’s guardian will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Camper, or in the case of a minor, a Camper’s guardian of their recourse.
Camp Simpresca will require that Campers, or in the case of a minor, a Camper’s guardian requesting access to their personal information will provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit Camp Simpresca to provide an account of the existence, use and disclosure of the Campers’ personal information.
Camp Simpresca 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.
Camp Simpresca will respond to a Camper’s, or in the case of a minor, a Camper’s guardian request to access their personal information within a reasonable time, and not later than 30 days after receipt of the request. Camp Simpresca may be entitled to a 30 day extension to respond, in limited circumstances, in which case the Camper, or in the case of a minor, a Camper’s guardian 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.
Camp Simpresca may charge a reasonable fee for responding to a request. This fee will be determined based on the request and any request specific administrative or system costs that may be incurred, and will advise the Camper, or in the case of a minor, a Camper’s guardian in advance, of the approximate cost. The personal information requested would be provided in a form that is generally understandable.
A Camper, or in the case of a minor, a Camper’s guardian 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.
10. Challenging Compliance
A Camper, or in the case of a minor, a Camper’s guardian will be able to address a challenge concerning compliance with the above principles to the Privacy Officer. Camp Simpresca will handle all complaints or inquiries about the policies and procedures relating to the handling of personal information in line with the processes that are in place.
Camp Simpresca will inform Campers, or in the case of a minor, a Camper’s guardian who make inquiries or lodge complaints of the existence of the relevant complaint procedures. Camp Simpresca will investigate all complaints, and if a complaint is justified, Camp Simpresca will take appropriate measures, including amending policies and procedures.