VERNON OUTDOORS CLUB PERSONAL INFORMATION PRIVACY POLICY AND PROCEDURES

Date Created: January 20, 2021

Last Update: April 19, 2021

.PURPOSE:  British Columbia’s Personal Information Protection Act (S.B.C. 2003, c. 63) requires that organizations such as the Vernon Outdoors Club {VOC} develop and implement policies and procedures to responsibly manage the collection, use and disclosure of members’ personal information.  The Act defines personal information as names, addresses, gender, age, ethnicity, health, Marital status, contact details, (home phone, e-mail), physical description and photos any of which might be used to identify individual members. 

Note: In the event of a discrepancy between this policy and the requirements of the BC PIP Act; the BC PIP Act shall prevail.

POLICY:  This policy applies to personal information relating to VOC members and guests participating in any VOC-sanctioned activity.

The Vernon Outdoors Club will comply with all applicable requirements of the BC Personal Information Protection Act by:

• Ensuring all members are aware of, and have access to the VOC’s Personal Information Privacy Policy, and Procedures.
• Informing members of the purpose for obtaining personal information and only collect, use or disclose that information with their consent (See Table #1 below).
• Collecting, using or disclosing only that personal information needed to plan, organize and carry out VOC activities in an efficient and safe manner (see Table #1).
• Taking reasonable precautions in the collection, use and disclosure of VOC members’ personal information to ensure its security commensurate with the nature of that information.
• Identifying a designated Privacy Officer to investigate any complaints or concerns regarding VOC Privacy practices.
• Upon request, performing an examination of VOC practices for possible non-conformance to its own Privacy Policies and Procedures, or to the BC PIP Act.

COLLECTION OF PERSONAL INFORMATION:

The VOC Membership Form (the primary method for collecting personal information) describes how personal information is to be used and disclosed, however additional details or clarification can also be obtained from Trip Leaders, by accessing the Personal Information Privacy Policy and Procedures (this document) posted on the VOC website, or by contacting the VOC Privacy Officer.

USE OF PERSONAL INFORMATION:

A General Membership Directory will be periodically updated and made available to ALL members to facilitate direct executive and member to member communications.  The General Membership Directory will include member’s names and contact details (e-mail and/or phone #). 

If members indicate on the Vernon Outdoors Club Membership Form that they DO NOT want their contact information shared with the broad membership; then e-mail and phone # details will be excluded and only their name will be listed in the General Membership Directory.

• This General Membership Directory is intended only for internal member use as shown in Table #1, and it is not to be accessed by, or provided to third parties except if/when required by law.

• Personal information will NOT be used for any purposes other than those identified in Table #1 without first obtaining consent from impacted members.

A separate Secure Membership Directory will also be prepared to include ALL members’ personal information.  The Secure Membership Directory containing: member’s names, areas of interest and contact details (e-mail and/or phone #) address, and emergency contact details will NOT be circulated to the wide membership, but rather will be available only to the VOC Board, Activity Coordinators and planners for administrative purposes and for safely managing VOC activities.

DISCLOSURE OF PERSONAL INFORMATION:

Personal Information is intended for internal use only and is NOT to be disclosed to any third Parties except as detailed in Table #1 should circumstances require it, or if/when specifically required by Law.

• Any request for disclosure beyond those purposes detailed in Table #1 must receive specific consent from impacted individuals.
• Any member can decline to have their contact information (e-mail, phone #) listed on the General Membership Directory.

COMPLAINTS PROCEDURE:

Any member may request an examination for conformance with the requirements of PIPA or the VOC’s Privacy Policy and Procedures as follows:

1. Contact the designated Privacy Officer for assistance or guidance as necessary
2. If a formal investigation is requested/required, it must be accompanied by a written request which identifies to the extent possible:
   1. Complainants Name and Contact Details
   2. The nature of the concern.

c.The personal information that may have been collected, used or disclosed contrary to VOC policies or the BC PIP Act.

4. A proposed resolution by the complainant.

3. The Privacy Officer will review the issue with the complainant as well as with other involved parties and the VOC Executive to reach a mutually acceptable resolution.
4. If a proposed resolution is unsatisfactory, the complainant will have recourse to ask the B.C. Office of the Information and Privacy Commissioner to investigate the complaint further.

RETENTION AND DISPOSAL OF RECORDS CONTAINING PERSONAL INFORMATION:

A copy of the Secure Membership Directory will be permanently retained in VOC Files (accessible only to the VOC Executive) for planning/archival/historical purposes.  The General Membership Directory will be retained only until it can be replaced with an updated version and then shredded/deleted.  

Membership Forms/Waivers (hard copy and e-mail) will be retained for up to two years beyond the year of collection and then shredded/deleted.

Activity Sign-up/Participation Forms (hard copy and e-mail) will be shredded/deleted annually after all pertinent information, such as Activity/Event Title, Date, Leader’s Name and contact information, and Number of Participants is transferred to a central file for planning/archival/historical purposes.  Individual participant’s names, (except for leader’s), will not be retained.

Photos and Videos taken by members during club activities may be used for club publicity. The VOC may archive photos and/or videos in perpetuity.  If a member considers a particular photo or video (that is posted publicly) to be unacceptable for a privacy-related reason, that member may contact the VOC Privacy Officer to review the matter and seek resolution.

 

Table #1: Management of Personal Information

Collection Method	Identified Purpose/Use	Disclosure Route(s)	Comments
VOC Membership Form: Name E-mail Phone Activity Interests *Address *Trail Maintenance skills                                   *Emergency Contact Information(ECI) Contact Name(s) Contact Phone # *Available only to Executive via Secure Membership Directory	General Membership Directory: Member to Member communications Secure Membership Directory: Administrative Tracking Executive and Membership inter- communications Facilitating AGM and/or General meetings Newsletter distributions Notices regarding topics of common interest Public Service announcements Trip/Activity Planning                                  Emergency Contact Information: Facilitate Emergency response activities for VOC members involved in a VOC sanctioned event.	General Membership Directory: Internal circulation to VOC Members for social/Club purposes only. Name E-mail Phone Activity Interests deleted/disposed of upon issue of updated directory   Secure Membership Directory: Internal access only by VOC Executive Name E-mail Phone Activity Interests *Address *Trail Maintenance skills *Emergency Contacts (deleted. see below) Permanently secured in VOC files for planning/archival/ historical purposes.                  Emergency Contact Information: Emergency/1st Responders Medical Personnel Police VOC Insurance Contacts Designated family	Members must be aware, e-mailed versions of the General Membership Directory may exist in electronic or hardcopy copy form among individual members. As a reminder, each page of the VOC General and Secure Membership Directories will include issue date, page # (for hardcopies only), and the statement: “Confidential: In accordance with the BC Privacy Act, do not share any of this information with anyone other than VOC members”         *Members are encouraged to carry their own Emergency Contact Information thereby reducing the need for VOC to gather and manage this information.
Trip/Activity Sign up Activity Title Activity duration and conditions Names of Trip Leaders and contact information Names of Participants Numbers of Participants Note: Except for possible recognition awards, participant names from activity sign up, are excluded from aggregate data, and deleted at the end of each year when signup forms are destroyed.	Aggregate Reporting Organizational analysis Future Trip planning/scheduling Internal reporting Trail management Archival/Historical Statistical analyses for usage surveys, trip leader names, etc. Member/Leader recognition (volunteer awards) Insurance	Internal to VOC Executive and planners Government *Individual Participant names removed and not disclosed   Aggregate data (*with individual participants names removed) will be retained permanently in VOC files for planning/archival/historical purposes	Collected during sign up prior to VOC-sanctioned activities, or even during the course of a trip/activity.
Photos and Videos Taken by VOC members	Enjoyment and Sharing Documentation/Reference Historical/Archival Website Publicity	As noted in the membership sign up form, Photos/Videos of members may be used publicly (i.e. VOC webpage, brochures, etc.) without individual notice. Photos/Videos taken and used by members for personal enjoyment are outside the scope of this policy. Permanent in Secure VOC files for planning/archival/historical purposes	If a member considers a particular photo or video (that is posted publicly) to be unacceptable for a privacy-related reason, that member may contact the VOC Privacy Officer to review the matter and seek resolution.