PRIVACY POLICY

Committed to serving you

Our Commitment

Boys and Girls Clubs of Kamloops is committed to protecting the privacy of the personal information of its employees, members, donors, volunteers, and other stakeholders. This policy has been developed to comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). Boys and Girls Clubs of Kamloops (herein referred to as “BGCK”) values the trust of the public and those we deal with and recognizes that maintaining this trust requires that we be transparent and accountable in how we treat the information that you choose to share with us. 

 

Consent

During the course of our various projects and activities, BGCK may gather and use personal information. Anyone from whom we collect such information should expect that it will be carefully protected and that any use of or other dealing with this information is subject to consent. BGCK will keep personal information only as long as necessary to satisfy the purposes or legal requirements. Consent may be obtained in writing, in person, electronically, by phone, by fax, or by email. For an individual who is a minor, seriously ill, or mentally incapacitated consent may be obtained from a legal guardian, or person having power of attorney. Waiver and consent forms will be kept as needed to ensure that we have written consent from parents/legal guardians/caregivers to support service delivery.  

 

BGCK may disclose personal information without the individual’s knowledge or consent only:

  • To a lawyer representing the Club

  • To collect a debt the individual owes to the Club.

  • To comply with a subpoena, warrant or an order made by a court or other body with appropriate jurisdiction.

  • A law enforcement agency in the process of a civil or criminal investigation.

  • A government agency or department that has requested the information, identified its lawful authority and indicates that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law; or suspects that the information relates to national security or the conduct of international affairs; or is for the purpose of administering any federal or provincial law.

  • If made by an investigative body for the purpose related to the investigation of a breach of an agreement or a contravention of a federal or provincial law.

  • In an emergency threatening an individual’s life, health or security.

  • 20 years after the individual’s death or 100 years after the record was created.

  • If it is publicly available.

  • If required by law.

 

 

Defining Personal Information

Personal information is any information that can be used alone or in combination with other information to distinguish, identify, or contact a specific individual. This information can include an individual’s opinions or beliefs, as well as facts about or related to the individual. Examples of personal information include SIN #, age, marital status, medical concerns, language, etc. Exceptions: Business contact information and certain publicly available information such as names, addresses, and telephone numbers as published in telephone directories, are not considered personal information. Where an individual uses his or her home contact information as business contact information as well, BGCK considers that the contact information provided is business contact information and is therefore not subject to protection as personal information. Further, BGCK does not trade, license, rent or sell your personal information in any manner.

 

Privacy Practices

Personal information gathered by BGCK is kept in confidence. BGCK personnel are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent it from being lost or destroyed. We collect, use, and disclose personal information only for purposes that a reasonable person would consider appropriate considering the circumstances. 

 

Contact Information 

  • Full Name 

  • Address

  • Postal Code

  • Phone Number(s)

  • Email address

 

We collect this information through our website contact boxes; online donation form; and volunteer, society, or membership registration and application forms to complete a sale or donation, deliver a program or service, manage member relations, handle complaints or emergencies, email newsletters or Club information, and administer scholarships or recognition. This information may be used by many staff members. An original hard copy of this contact information (where applicable) is secured in a locked office and/or filing cabinet and may be transferred to password protected, secure online databases, Sharevision and/or Amilia, for ease of use and reporting. Email addresses provided may also be added to staff address books using Microsoft Outlook or stored on our Wix website and/or MailChimp website (third-party email service provider) for direct communication. You are welcome to opt-out of email correspondence at any time by unsubscribing or emailing resource@bgckamloops.com to be removed from our mailing list. Your email will never be shared or sold to another organization.

 

Demographics

  • Date of birth/age

  • Gender

  • Weight/Height

  • Hair/Eye Colour

  • School 

  • Grade

  • Swimming ability

  • Household Income

  • Language

  • Ethnicity

  • Medications

  • New Canadian/Refugee/Indigenous/Military 

  • Custody

  • Household relations/relations to member

  • Type of childcare needed, when, and at what times

  • Other (as shared by individual)

 

We may collect this information from our staff, our membership registration forms, and childcare subsidy/arrangement forms to deliver a program or service, manage employment, relations, and safety, and respond to an emergency or incident. This information may also be used when applying for a variety of grants, providing statistics to the Government of Canada, filing reports, or completing the Boys and Girls Club of Canada Fact Book. This information is considered sensitive and is only shared with specific staff on a need-to-know basis. An original hard copy of this information is secured in a locked office and/or filing cabinet and some or all the information may be transferred to password protected, secure online databases, Sharevision and/or Amilia, for ease of use and reporting. All BGCK staff are required to read, understand, and follow strict confidentiality and privacy policies.  

 

Financial Information

  • Payment card number

  • Payment card expiry date

  • Banking information

  • Income

  • Tax receipts

 

We collect this information for program and service accounting and donor management. Financial information provided using our online donation form is stored by secure third-party providers, CanadaHelps and Amilia (coming January 2019). BGCK does not have access to or store this information. Any financial information collected by parents/caregivers of our members is secured in a locked office/filing cabinet and/or electronically on a secure, password protected computer accessed by a few, specific staff with clearance to do so. BGCK strives to maintain and honour the privacy and safety of our members and donors with the utmost care. 

 

Other Information

  • Health/medical information

  • Photos

  • Social insurance number

  • Driver's license

  • Opinions/testimonials

  • Customer satisfaction

  • Criminal records

 

We may collect this information from our members, staff, donors, scholarship recipients, and volunteers for accounting/payroll, health and safety, program evaluation, marketing and promotion, and employment standards. This information is stored in a locked office and filing cabinet and on secure, password-protected computers or databases, Sharevision and/or Amilia. Safeguards are in place to ensure that information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. All employee, member, and volunteer files follow strict confidentiality and privacy policies. When collecting sensitive or potentially sensitive information, BGCK will obtain expressed consent and take due care to answer any questions or concerns about the information gathered (e.g., use, privacy, reasons for collection). 

 

Websites, Third-Party Sites, and Electronic Commerce

Boys and Girls Clubs of Kamloops uses a variety of service providers requiring password protocols and encryption software to protect personal and other information (e.g., Wix, Facebook, Twitter, MailChimp, Survey Monkey, Google Forms, Sharevision, Amilia, and Canada Helps). We take great care to choose third-party service providers with reputable practices, policies, and procedures. All such third-party service providers must be in compliance with PIPEDA and have an established and published privacy policy available for all users. However, you should be aware that operators of these linked websites may also collect your personal information (including information generated using cookies). BGCK is not responsible for how such third parties collect, use or disclose your personal information, so it is important to familiarize yourself with their privacy policies before providing your personal information.

 

Data Protection

Individuals users of the BGCK website(s) shall have sole responsibility for the adequate protection (including protection against computer viruses) and backup of any data and/or equipment used in connection with the BGCK website and shall not make a claim against BCGK for lost data, re-run time, data corruption, communication interception, inaccurate output, work delays or lost profits resulting from any use of the websites.

 

Cookies and Web Analytics

A cookie is a harmless, small file of letters and numbers that are placed on your browser or the hard drive of your computer. BGCK website(s) use cookies to make your experience safer and better, to gain a greater understanding of user preferences and their interaction with our websites, and to generally improve the services and features.

 

BGCK uses web analytics services including Google Analytics to help analyze the use of our websites. These tools use cookies to collect and generate information about your visits to our sites (including your IP address) that is transmitted to their servers in an anonymous form for processing. We study patterns of our websites activity, so we can improve the experience of visitors to our sites. The use of these tools does not allow us or our analytics service providers to identify individuals. You can opt-out of using cookies by setting your browser to notify you when a cookie is sent and block cookies if desired. Please consult your browser's Help Menu for instructions. Visiting our website with cookies disabled might impact some of the features of your browsing experience.

 

Donations

Online donations can be processed via our website www.bgckamloops.com using the embedded CanadaHelps fundraising and donation platform. CanadaHelps is a secure third-party site that follows strict privacy and protection policies which can be found at www.canadahelps.org.

 

Donors’ privacy and requests to remain anonymous will be respected. Any donor records that are maintained by the BGCK will be kept confidential to the greatest extent possible. Donors have the right to see their own donor record and to challenge its accuracy. BGCK will not exchange, rent or otherwise share its fundraising list with other organizations.

 

BGCK will respond promptly to a complaint by a donor or prospective donor about any matter that is addressed in its Ethical Fundraising and Financial Accountability Code. A designated employee member or volunteer will attempt to satisfy the complainant’s concerns in the first instance. A complainant who remains dissatisfied will be informed that they may appeal in writing to the BGCK’s Board of Directors or its designate and will be advised in writing of the disposition of the appeal. A complainant who is still dissatisfied will be informed that they may notify Imagine Canada, formally known as the Canadian Centre for Philanthropy in writing.

 

Openness and Transparency
Please submit all requests for personal information and/or complaints in writing and signed to our Privacy Officer (address below). Please allow 30 days for your request. This time frame may be extended if:

  • Responding to the request within the original 30 days would unreasonably interfere with activities of BGCK.

  • Additional time is necessary to conduct consultations.

  • Additional time is necessary to convert personal information to an alternate format.

 

BGCK will inform the individual if additional time is required. There will be a minimal or no cost for requests for personal information. If a minimal cost does apply the individual will be notified before processing their request. If access is refused, the individual submitting the request will be informed in writing, outlining the reasons and any recourse available.

 

BGCK must refuse an individual access to information if:

  • It would reveal personal information about another individual unless there is consent or a life-threatening situation.

  • BGCK has disclosed information to a government institution for law enforcement or national security reasons. In this case, upon request, the government institution may instruct BGCK to refuse access and not to reveal that the information has been released. BGCK must refuse the request and notify the Privacy Commissioner. BGCK cannot inform the individual of the disclosure to the government institution, or that the institution was notified of the request, or that the Privacy Commissioner was notified of the refusal.

 

BGCK may refuse an individual access to information if:

  • The information falls under solicitor-client privilege.

  • The information is confidential commercial information (if this information can be removed, the Club will release the remaining information.)

  • Disclosure could harm an individual’s life or security (if this information can be removed, the Club will release the remaining information.)

  • It was collected without the individual’s knowledge or consent to ensure its availability and accuracy, and the collection was required to investigate a breach of an agreement or contravention of a federal or provincial law, in this case, the Privacy Commissioner must be notified.

  • It was generated in the course of a formal dispute resolution process.

 

Accuracy

Personal information that is collected by BGCK will be kept as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Personal information will be updated only when necessary to fulfil the specific purposes. A written request to update or change inaccurate information can be submitted to BGCK. Any information that is inaccurate will be corrected and\or amended if it is found to be deficient.

 

Updating of Privacy Policy

BGCK regularly reviews and updates its privacy policy as required. Any revisions to our privacy policy will be made available on our website. In the absence of policy, we will follow the guidelines and regulations set out by PIPEDA and respective legal requirements.

 

Contact Information

Any questions, concerns, requests, or complaints on the treatment of personal information should be sent to the BGCK Privacy Officer:

 

Traci Anderson

Executive Director

150 Wood St. 

Kamloops, BC

V2B 0G6 

exdir@bgckamloops.com

(250)-554-5437 ext. 205
 

Further information on privacy and your rights in regard to your personal information may be found on the website of the Privacy Commissioner of Canada.

 

 

Last updated: August 9, 2018

 

Copyright © 2018 Boys and Girls Club of Kamloops