PRIVACY POLICY
Index of Policy Sections
- Definition of Personal Information
- Our Commitment to Privacy
- Collecting and Retaining Personal Information – Membership
- Collecting and Retaining Personal Information – Networking, Education and Training
- Collecting and Retaining Personal Information – Purchase of CAMA Merchandise, Products and Services
- Collecting and Retaining Personal Information – CAMA Website
- Exchange of Personal Information with Other Organizations
- Disclosure of Personal Information – Special Circumstances
- Maintaining Accuracy of Personal Information
- Security of Information
- Accessing and Updating Personal Information
- Questions Regarding the Association`s Privacy Policy
- Revisions to Policy
- Effective Date
The Canadian Association of Municipal Administrators gratefully acknowledges the assistance of the Ontario Municipal Administrators Association (OMAA) in the preparation of this Privacy Policy and the precedent value of that Association`s policy document.
Purpose
This Privacy Policy governs the collection, use and disclosure of Personal Information by the Canadian Association of Municipal Administrators (CAMA) from and about Members, including spouses and partners, program participants, sponsors and exhibitors, including spouses and partners and from individuals who may access the Association`s website.
This Policy has been developed in accordance with the principles set out in the Personal Information Protection and Electronic Documents Act, Statutes of Canada 2000, Chapter 5 (PIPEDA).
CAMA also follows the recommended practices in Schedule 1 to the PIPEDA as much as reasonably possible, in administering this Policy and in complying with the PIPEDA.
Policy
1. DEFINITION OF PERSONAL INFORMATION
For the purposes of this policy, Personal Information is defined as ``any information about an identified individual, recorded in any form, that can be used to distinguish, identify, evaluate or contact the individual or which can be used to infer or determine the identity of an individual.``
Personal information collected by the Association includes:
a) Home address, home telephone number and personal e-mail address information;
b) Business e-mail address information;
c) Name of spouse or partner and the home address, home telephone number and personal e-mail information of the spouse or partner;
d) Financial information, such as credit card numbers, provided by Members, program participants, and sponsors and exhibitors for conferences, workshops and program registration, and provided by purchasers of CAMA products, merchandise or for service acquisition purposes;
For greater certainty, as set out in Regulations accompanying the PIPEDA legislation, Personal Information does not include an individual`s name, job title, employer name, business address, business telephone number.
2. OUR COMMITMENT TO PRIVACY
Your privacy is important to us. To better protect your privacy CAMA provides this notice explaining our website`s practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, CAMA makes it available on our CAMA website and at every point where personally identifiable information may be requested.
3. COLLECTING AND RETAINING PERSONAL INFORMATION – MEMBERSHIP
The Association collects and retains Personal Information from new and existing Members in order to:
a) Establish a point of contact for future membership mailings and distribution of Association communications, information, information requests, or service acquisition purposes;
b) Process membership fee payments, conference and workshop registration payments and payments for CAMA products, merchandise or services; or,
c) Other purposes which must be identified before or at the time the information is collected.
The collection of personal information shall be limited to that which is necessary for the purposes identified. Personal Information shall be collected by fair and lawful means.
The Association may disclose the Personal Information collected from Members to organizations that assist the Association with the distribution of Association communications. Personal Information will only be provided to such organizations if they agree to use such information solely for the purpose of distributing Association communications under the instruction of the Association and, with respect to that information, to act in a manner consistent with the principles articulated in this Policy.
Member consent to the collection and retention of this Personal Information is presumed to be given at the time of submitting the information to the Association. Forms utilized to gather this Personal Information will clearly indicate the purposes for which the information is being collected and retained.
Personal Information, excluding financial information, collected from Members is retained:
a) For the duration of the individual`s membership in the Association;
b) Until such Personal Information is superseded, in which case any ``obsolete`` Personal Information is destroyed;
c) For a period of ten (10) years following an individual`s termination of their membership in the Association, except where the individual is deceased prior to the conclusion of the ten (10) year period. In the case of deceased individuals, disposal of any Personal Information retained will occur within no more than sixty (60) days following the date upon which the Association becomes aware that the individual is deceased.
Financial information collected from Members is retained for as long as required to comply with audit, statutory or other legal purposes.
4. COLLECTING AND RETAINING PERSONAL INFORMATION – NETWORKING, EDUCATION AND TRAINING
The Association conducts various networking, education and training programs throughout the year. These programs include seminars, workshops, and conferences.
The Association collects and retains Personal Information from program participants, including spouses and partners, in the Association`s networking, education and training programs in order to:
a) Establish a point of contact for future distribution of program materials and registration confirmations;
b) Process fee payments for registration in networking, education and training programs.
The Association may collect Personal Information from organizations and individuals who assist the Association with the offering of the Association`s networking, education and training programs. The Association will use such information solely for the purposes of gathering evidence of the successful completion of the education and training programs.
A Program Participant`s consent to the collection and retention of this Personal Information is presumed to be given at the time of submitting the information to the Association. Forms utilized to gather this Personal Information will clearly indicate the purposes for which the information is being collected and retained.
Personal Information, excluding financial information, collected from program participants is retained:
a) For the duration of the individual`s enrolment in the networking, education or training program;
b) Until such Personal Information is superseded, in which case any ``obsolete`` Personal Information is destroyed;
c) For a period of five (5) years following an individual`s completion of the networking, education or training program.
Financial information collected from program participants is retained for as long as is required to comply with audit, statutory or other legal purposes.
5. COLLECTING AND RETAINING PERSONAL INFORMATION – PURCHASE OF CAMA MERCHANDISE, PRODUCTS AND SERVICES
The Association collects and retains Personal Information from Purchasers of CAMA products, merchandise and services in order to:
a) Establish a point of contact for distribution and delivery of products, merchandise and services purchased;
b) Process payments for products, merchandise and services purchased.
Consent to the collection and retention of this Personal Information is presumed to be given by the Purchaser at the time of submitting the information to the Association. Forms utilized to gather this Personal Information will clearly indicate the purposes for which the information is being collected and retained.
Financial Information collected from purchasers of CAMA products, merchandise and services is retained for as long as is required to comply with audit, statutory or other legal purposes.
6. COLLECTING AND RETAINING PERSONAL INFORMATION – CAMA WEBSITE
The Association collects and retains Personal Information submitted by individuals accessing the Members Only portions of the CAMA Website. The collection and retention of this information is handled in accordance with the applicable sections of this Policy with respect to the collection and retention of Personal Information for various Association purposes.
The Association does not collect any Personal Information from individuals accessing the public portions of the CAMA Website. The Associations` website operating system may automatically record certain general, and non-personal, information regarding an individual`s access to the CAMA Website. Further information regarding the non-personal information collected is contained in the Association`s Website Privacy Policy document.
The Association`s Website may provide links to other websites. Once an individual links to another site, the individual is subject to the privacy and security policies of that site. The Association does not retain any responsibility with respect to the collection and retention of Personal Information by other organizations through these linked websites.
7. EXCHANGE OF PERSONAL INFORMATION WITH OTHER ORGANIZATIONS
Unless detailed in this Policy, the Association does not sell, trade, barter or exchange for consideration any Personal Information collected from Members, including spouses and partners, program participants, includes spouses and partners, or purchasers of products, merchandise and services.
8. DISCLOSURE OF PERSONAL INFORMATION – SPECIAL CIRCUMSTANCES
Circumstances may arise where the use and (or) disclosure of Personal Information may be justified or permitted or where the Association is obliged to disclose the information without consent. Such circumstances would include, but not be limited to:
a) Where required by law or by order of a court, administrative agency or other governmental tribunal:
b) Where the Association believes, upon reasonable grounds, that disclosure is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
c) Where it is alleged that the person concerned is: guilty of a criminal offence, civilly liable in a legal action; or guilty of professional misconduct, and the individual requesting the information is an authorized agent of an organization responsible for investigation or prosecution of the allegation.
d) Where disclosure is necessary to permit the Association to pursue available remedies or limit any damages that it may sustain;
e) Where the information is otherwise deemed to be public information.
Where obliged or permitted to disclose Personal Information without consent, the Association will not disclose more information than is required.
9. MAINTAINING ACCURACY OF PERSONAL INFORMATION
To the best of its ability, the Association will ensure that any Personal Information in its possession is as accurate, current and complete as necessary for the purposes for which the Association has collected the information.
10. SECURITY OF INFORMATION
The Association will maintain adequate physical, procedural and technical security with respect to its information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information collected and retained.
As part of these precautions, the Association will restrict access to an individual`s Personal Information to those persons or organizations that the Association determines require access to the information in order to fulfill their respective responsibilities to the Association.
If a person or organization misuses the Personal Information to which they have access, this will be considered a serious offence. In the case of a person retained by CAMA, such misuse may include termination of any service contract with CAMA. If an organization providing services to the Association misuses this Personal Information, action will be taken, up to and including termination of the service agreement between the Association and the organization.
11. ACCESSING AND UPDATING PERSONAL INFORMATION
Upon request, the Association will provide Members, including spouses and partners, program participants, including spouses and partners, and purchasers of CAMA products, merchandise and services, access to the Personal Information collected and retained about them. If the individual person accessing such information believes that the Personal Information about them is not correct, they may, depending upon the nature of the Personal Information, make or request an amendment to that information. The Association reserves the right to not change the Personal Information but will append any alternative information, which the individual concerned believes to be appropriate.
Requests for access to Personal Information will be addressed within a reasonable time and no later than sixty (60) days following the date of the request.
To guard against fraudulent requests for access or corrections, the Association may request sufficient information to allow the Association to confirm that the individual making the request is authorized to do so, before granting access or making corrections.
The Association reserves the right to decline to provide access to Personal Information, upon the request of an individual, where the information requested:
a) Would disclose Personal Information, including opinions, about another individual or about a deceased individual;
b) Would disclose confidential information about the Association or a third party that may harm the Association or third party or interfere with contractual or other negotiations of the Association or third party;
c) Is subject to solicitor-client or litigation privilege;
d) Is not reasonably retrievable and the burden or cost of providing the information would be disproportionate to the nature or value of the information;
e) Does not exist, is not held, or cannot be found by the Association;
f) Could reasonably result in serious harm to the treatment or recovery of an individual concerned, serious emotional harm to the individual or another individual, or serious bodily harm to another individual;
g) May harm, or interfere with, law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
The Association reserves the right to not respond to repetitious or vexatious requests for access.
12. QUESTIONS REGARDING THE ASSOCIATION`S PRIVACY POLICY
In the event that a Member, including a spouse or partner, program participant, including a spouse or partner, purchaser of CAMA products, merchandise and services, has questions about:
a) Access to Personal Information collected and retained by the Association;
b) The collection, use, management or disclosure of Personal Information;
c) The contents of the Association`s Privacy Policy;
the individual shall contact the President of the CAMA who is the Privacy Officer of CAMA appointed by the Association`s Board of Directors.
13. REVISIONS TO POLICY
The Association may, from time to time, review and revise its privacy practices and this Policy. In the event of a policy amendment, the Association`s Members, program participants, purchasers of products, merchandise and services, and other individuals who may access the Association`s Website will receive appropriate notice as soon as possible following the amendment. Policy changes will apply to Personal Information collected from the date of the revised Policy as well as existing Personal Information, which the Association has already collected and retained.
14. EFFECTIVE DATE
This Policy shall be in effect as of March 3rd, 2011.
