The policy contains 10 principles as set out by PIPEDA that are observed in connection with Alpine’s collection, use and disclosure of personal information.
- Principle 1 – Accountability
- Principle 2 – Identifying Purposes
- Principle 3 – Consent
- Principle 4 – Limiting Collection
- Principle 5 – Limiting Use, Disclosure and Retention
- Principle 6 – Accuracy
- Principle 7 – Safeguarding Member Information
- Principle 8 – Openness
- Principle 9 – Member Access
- Principle 10 – Handling Complaints and Suggestions
Principle 1 – Accountability
Alpine is responsible for personal information under its control and has designated the general manager as the chief privacy officer to be accountable for compliance with the policy.
All staff are informed about the policy and its implications, including confidentiality obligations with respect to personal information.
Principle 2 – Identifying Purposes
Alpine collects personal information for the following purposes (the “purposes”):
- to facilitate the ongoing operation and management of the affairs of Alpine;
- to maintain systems for billing and collection of initiation fees, annual dues, levies, locker rentals, fees for guest passes, ski programs and Kids’ Club services, point of sale charges and other fees or charges as determined by Alpine;
- to determine membership status and category;
- to communicate various matters relating to Alpine;
- to publish a roster of Alpine members, including their address, telephone numbers and the names of their spouses and children and, in the case of children, their year of birth;
- to maintain emergency contact information;
- to comply with insurance requirements, including accident investigation;
- to assemble demographic and other information to assist Alpine with annual, long-range and strategic planning; and
- to assist with program planning and operations generally.
Principle 3 – Consent
The consent to collect, maintain and use personal information for the purposes set out in Principle 2 shall be deemed to be obtained and is understood to be implicit when Alpine services are utilized or Alpine forms are submitted in respect of, without limitation, the following: guest services, annual registration, group or individual bookings, enrolment in a snow program or in Kids’ Club, unless explicit instructions are received not to use the information for any of the above purposes. In such case, Alpine’s ability to provide various services may be impaired.
Except as may be required by law or where disclosure is legally permitted and determined to be in the best interests of Alpine, acting reasonably, Alpine will obtain consent prior to the disclosure of personal information where the personal information to be disclosed is for a purpose other than to fulfill the purposes set out in Principle 2.
Principle 4 – Limiting Collection
Alpine will only collect personal information by fair and lawful means and will only store such personal information as is necessary to fulfill the purposes.
Principle 5 – Limiting Use, Disclosure and Retention
Alpine will only use or disclose personal information in accordance with the purposes for which it was originally collected, unless consent is otherwise granted, or when it is required or permitted by law.
Alpine will not disclose personal information to other organizations except Alpine’s insurance carrier as required by its insurance policies.
Alpine will retain personal information only for so long as is required to fulfill the purpose for which it was collected or as required by law.
Principle 6 – Accuracy
Alpine shall take steps to ensure that personal information is as accurate, complete and up to date as is reasonably possible.
Principle 7 – Safeguarding Member Information
Alpine will take reasonable measures, consistent with industry standards, to safeguard personal information against loss, theft, unauthorized disclosure, copying, use or alteration.
Principle 8 – Openness
This policy will be made available to members and the public on request and will be posted on Alpine’s website. As and when Alpine documentation is updated, reference, where appropriate, to the policy will be noted.
Principle 9 – Member Access
Individuals may access their personal information as retained by Alpine to ensure its accuracy and completeness.
Principle 10 – Handling Complaints and Suggestions
The general manager shall be responsible for ensuring that Alpine is in compliance with PIPEDA and the policy and responding to any inquiries or complaints regarding the Policy and practices related to it. Any complaint received by Alpine regarding the use of personal information must be directed to the general manager. The general manger is responsible for initiating an inquiry regarding the circumstances and legitimacy of the complaint but may delegate this responsibility from time to time. The general manager must prepare a formal written response to any complainant, and take corrective actions should any improper collection, storage or disclosure of personal information have occurred.
Individuals who are not satisfied with the response received from the general manager may challenge Alpine’s compliance with the Policy or PIPEDA through the president of the Club or by making a complaint to the Privacy Commissioner.