Legal and Complaints Policy

Privacy Policy

1.Policy Statement
 

1.1 YMCA Calgary (hereafter referred to as “YMCA”) respects and is committed to protecting the confidentiality and security of Personal Information entrusted to YMCA, and ensuring that all Personal Information that YMCA holds is collected, used and disclosed in compliance with all applicable federal and provincial privacy laws, including Alberta’s Personal Information Protection Act (collectively, the “Privacy Legislation”).
 

2.Definitions
 

2.1 Within this Privacy Policy, “Personal Information” means information about an identifiable individual. Personal Information does not include publicly available information such as business contact information which includes an individual's name, position name or title, business telephone number, business address, business e-mail, business fax number and other similar business information provided that information is used for business contact purposes and not for other purposes; information that has been made anonymous, or aggregated information that cannot be associated with a specific individual.
 

3.Scope
 

3.1 Employees, volunteers, contractors, consultants, agents, auditors, and other third-party service providers are bound to comply with this Privacy Policy and YMCA’s practices governing the protection of Personal Information and privacy.
 

4.YMCA’s Privacy Practices
 

4.1 YMCA is committed to the ten principles outlined below which are mandated in Privacy Legislation governing the collection, use and disclosure of Personal Information. These principles form the foundation of YMCA’s Privacy Policy:
 

(a)Accountability
 

YMCA is responsible for safeguarding Personal Information in its possession or control. YMCA will use appropriate means to provide a comparable level of protection when Personal Information is being processed by a third party.
 

(b)Identifying Purposes for Collection
 

YMCA will document the purposes for which Personal Information is collected and will only collect Personal Information for the identified purposes.
 

YMCA will specify to the individual, orally, electronically or in writing, the identified purposes at or before the time Personal Information is collected. Upon request, persons collecting Personal Information will explain these identified purposes or refer the individual to the Chief Financial Officer (who also acts as the Privacy Officer for YMCA) who will explain the purposes.
 

In accordance with Privacy Legislation, YMCA will identify and document any new purposes for which previously collected Personal Information may need to be used and disclosed and obtain the consent of the individual where applicable.
 

Some of the Personal Information YMCA collects is needed to satisfy the requirements of Canada Revenue Agency (CRA). We may provide further details to you about Personal Information that we collect or use either at the time we ask you to provide that information or through changes to this Privacy Policy. Although you may choose to not share your Personal Information with YMCA, if you choose not to do so, your involvement in YMCA activities and the YMCA community may be limited.
 

If at one time you provided your Personal Information for any of the above reasons, or for any additional reason, you may unsubscribe to YMCA’s mailing list by contacting the Privacy Officer whose information can be found at the bottom of this Privacy Policy.
 

(c) Obtaining Consent for Collection, Use or Disclosure YMCA will seek consent, where required, to use and disclose Personal Information when it collects the information or in accordance with Privacy Legislation.
 

In obtaining consent, YMCA will ensure that an individual is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes will be stated in a manner that can be reasonably understood.
 

Examples of when YMCA may collect, use and disclose Personal Information include but are not limited to:
verify an individual's identity.
carry out human resources functions such as training, administering employee contracts, evaluating employees, implementing employment-related actions and obligations and providing employment benefits and related benefits.
administer compensation, bonus and benefit plans and other employment matters.
process a donation, payment or invoice.
provide a product or service that YMCA offers; or
provide an individual with promotional/marketing materials as it relates to YMCA's business.
 

In determining the appropriate form of consent, YMCA will consider the sensitivity of the Personal Information, the reasonable expectations of the individuals involved, and the requirements of Privacy Legislation.
 

An individual may withdraw their consent to the collection, use and disclosure of Personal Information in accordance with this Privacy Policy at any time upon reasonable notice to YMCA in writing, subject to legal or contractual restrictions. The withdrawal of an individual's consent may affect YMCA's ability to continue to provide an individual with the products and services that the individual has or would like to receive. 
 

Personal Information may also be disclosed without your consent if required by law or by order or requirement of a court, administrative agency or governmental tribunal; where YMCA believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety, or property of an identifiable person or group.
 

(d)Limiting Collection of Personal Information
 

YMCA will collect, use, and disclose Personal Information in accordance with Privacy Legislation and will limit the amount and type of Personal Information collected to that which is necessary to fulfill identified purposes. YMCA collects Personal Information primarily from its employees, volunteers, and members, but YMCA may also collect Personal Information from other sources to meet the requirements of its business.
 

Calgary Police Service Recommendation: As a community partner, Calgary Police Services has a longstanding recommendation to verify identification and track facility usage. This practice directly supports the maintenance of a safe and secure environment and is instrumental in the event of a crime or complaint.
YMCA National Child Safety Standards: YMCA Canada's national child safety and protection standards require all YMCA Associations to verify identification and track facility usage. This includes employees, volunteers, contractors, guests, members, participants and drop-in users. This security requirement directly supports the safety of our communities which are the most vulnerable.
Aquatics Risk Management: Collecting names and dates of birth in YMCA's system is connected to the enforcement of its pool admission standards.
Emergency Response: Tracking facility access has been an instrumental component of emergency response. Should one of our guests experience a critical medical event, we have used these controls to support the identification of the individual involved.
 

(e)Retention and Destruction
 

YMCA will keep Personal Information only if it remains necessary or relevant for the identified purposes or as required by law.
 

YMCA will maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information will be destroyed, erased, or made anonymous.
 

YMCA will maintain a record of the third parties that Personal Information is disclosed to in accordance with this Privacy Policy.
 

(f)Accuracy of Personal Information
 

YMCA will employ reasonable efforts to keep Personal Information relevant to its intended use, accurate, complete, and current. YMCA relies on individuals to notify it if there is a change to their Personal Information.
 

YMCA will take reasonable steps to permit individuals to correct, amend or delete Personal Information that it demonstrates to be inaccurate or incomplete. These requests may be made in writing by contacting the Privacy Officer.
 

Those individuals who are party to any YMCA benefit plans or receive other benefits from YMCA shall ensure that their Personal Information, particularly information that deals with benefit entitlement or status, is kept current and accurately reported.
 

YMCA will update Personal Information as and when necessary to fulfill the identified purposes or upon notification by the individual.
 

(g)Security Safeguards
 

YMCA will use reasonable commercial efforts to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, use, modification, or destruction, through reasonable security measures. The nature of the safeguards will vary depending on the sensitivity of information collected.  YMCA will take all reasonable steps in the disposal or destruction of Personal Information, to seek to prevent unauthorized parties from gaining access to the Personal Information, including shredding paper records and permanently deleting electronic records. We use a variety of secure means to store your Personal Information as follows:
 

YMCA uses technological security measures, including access controls, to prevent unauthorized access to financial and other Personal Information stored on computer systems.
Locked cabinets in secure areas are used to store hard copies of financial information.
Third party providers, agents or vendors are used to provide services to or on behalf of YMCA such as secure data storage, data hosting, and data management.
Either YMCA or such third-party service provider may use servers for such purposes located in Canada and the United States of America. The Personal Information of an individual may be processed and stored in Canada and the United States of America, and the governments, courts or law enforcement or regulatory agencies of that country may be able to obtain disclosure of Personal Information through the laws of the foreign country.
 

(h) Openness Concerning Policies and Practices The information that YMCA makes available about its policies and practices will include:
the Email address of the person(s) who is accountable for YMCA's policies and practices regarding the management of Personal Information and to whom complaints or inquiries can be forwarded.
the means of gaining access to Personal Information held by YMCA.
a copy of information that explains YMCA's policies, standards or codes.
the type of Personal Information made available to related organizations and the context and limitations of such Personal Information; and
a description of the type of Personal Information held by YMCA, including a general account of its use.
 

(i)Individual Access to Personal Information Individuals have a right to access their own Personal Information that is in the custody or under the control of YMCA, subject to some limited exceptions provided for in the applicable privacy laws. YMCA will grant individuals reasonable access to their Personal Information held by YMCA. YMCA will advise the individual in advance of any charges for retrieval, reproduction or delivery of the Personal Information requested.
 

YMCA may limit or deny access to Personal Information as permitted by applicable Privacy Legislation. YMCA will provide the reasons for denying access.
 

In order to safeguard Personal Information, an individual will be required to provide sufficient identification information to permit YMCA to authorize access to the Personal Information held regarding that individual. Any such identification information will be used only for this purpose.
 

Individuals can obtain information or seek access to their Personal Information by contacting the Privacy Officer.  (j)Challenging Compliance
 

YMCA will maintain procedures for addressing and responding to all inquiries or complaints from individuals about YMCA's handling of Personal Information.
 

YMCA's Privacy Officer, in conjunction with the appropriate parties involved, will investigate all complaints concerning compliance with this Privacy Policy. If a complaint is found to be justified, YMCA will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures or disciplinary action up to and including termination. An individual will be informed of the outcome of the investigation regarding his or her complaint.
 

YMCA will promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness will be noted in the file in which the Personal Information is contained. Where appropriate, YMCA will notify third parties having access to the Personal Information in question about any amended information or the existence of any unresolved differences.
 

An individual that has concerns with YMCA's privacy practices should contact YMCA's Privacy Officer.
 

(k)Cross-Border Transfers of Personal Information YMCA has centralized certain aspects of its data process and human resources administration in order to allow it to better manage its business. That centralization may result in the transfer of Personal Information from one country to another within the limits and subject to the requirements of the applicable laws. The countries where the information will be transferred may or may not have laws that seek to preserve privacy of the Personal Information. However, whenever Personal Information is transferred outside of the country, the Personal Information will be processed in accordance with the principals of this Policy and Privacy Legislation. Individuals may obtain written information regarding cross-border transfers by contacting YMCA's Privacy Officer.
 

(l)Website Use YMCA may collect and use an individual's IP address, and date and time that the individual accessed our website, to help identify the individual, gather broad demographic information about users of the website, diagnose problems with YMCA’s systems, and administer the YMCA website.
 

Depending on an individual's browser settings, the YMCA website may use cookies. A cookie is a tiny element of data that a website can send to an individual's browser, which may then be stored on their hard drive so the website can recognize them when the individual returns to the particular website. We may use cookies to deliver content according to the individual's preferences. If an individual's browser settings do not accept cookies from our website, they may not be able to take advantage of all of the features of the website.
 

We use “Google Analytics” to collect information about use of the YMCA website.
 

Google Analytics is a web analytics service that uses cookies to track information about the use of the website such as how often users visit the sites, what pages they visit when they do so, and what other websites they used prior to coming to the YMCA website. This information is used to improve the YMCA website.
 

You can prevent Google Analytics from recognizing you on return visits to the YMCA website by disabling cookies on your browser. If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit: http://www.google.com/analytics/
 

5.Accountability
 

5.1 Responsibility for ensuring compliance with the provisions of this Privacy Policy rests with the designated Privacy Officer of YMCA. The Privacy Officer will have responsibility for giving effect to the Privacy Policy, including:
implementing procedures to protect Personal Information and overseeing YMCA's compliance with this Privacy Policy.
establishing procedures to receive and respond to inquiries and complaints regarding Personal Information.
training staff and communicating with staff about YMCA's policies and practices; and
developing employee and student communications to explain YMCA's policies and practices.
 

Contact Information

The contact information of the person currently designated as YMCA's Privacy Officer is Privacy@ymcacalgary.org