Victoria HarbourCats Baseball Club Inc.

Personal Information Protection Policy

At the Victoria HarbourCats Baseball Club Inc. (“Victoria HarbourCats”, we are committed to providing our fans with exception service. As providing this service involves the collection, use and disclosure of some personal information about our fans, protecting their personal information is one of our highest priorities.

We will always respect our fans privacy and safeguard their personal information in compliance of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our fans of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting fans’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality and security of our fans’ personal information and allowing our fans to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to the Victoria HarbourCats and any service providers collecting, using or disclosing personal information on behalf of the Victoria HarbourCats.

Definitions

Personal Information – means information about an identifiable individual including full name, address, phone number and email address. Personal information does not include contact information (described below).

Contact Information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individuals designated responsibility for ensuring that the Victoria HarbourCats comply with this policy and PIPA.

Policy 1 – Collecting Personal Information

  1. When required by this policy, or when asked before or at the time of collection of personal information, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
  2. We will only collect fans’ information that is necessary to fulfill the following purposes:
    • To complete a ticket purchase, we may collect full name, address, phone number and email address
    • To operate a loyalty program, we may collect full name, address, phone number, email address, gender and date of birth
    • To complete an order delivery, we may collect full name, address and phone number
    • For marketing purposes, we may collect email address, purchase history and product / service preferences

Policy 2 – Consent

  1. We will obtain fan consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
  2. Consent can be provided orally, in writing, electronically, or through an authorized representative, or it can be implied where the purposes for collecting, using or disclosing the personal information would be considered obvious and the fan voluntarily provides personal information for that purpose.
  3. Consent may also be implied where a purchase of goods or services is made from the Victoria HarbourCats and such personal information is provided by the fan directly.
  4. Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), fans can withhold or withdrraw their consent for the Victoria HarbourCats to use their personal information in certain ways. A fan’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the fan in making the decision.
  5. We may collect, use or disclose personal information without the fan’s knowledge of consent in the following limited circumstances:
    • When the collection, use or disclosure of personal information is permitted or required by law;
    • In an emergency that threatens an individual’s life, health or personal security;
    • When the personal information is available from a public source (e.g., a telephone directory);
    • When we require legal advice from a lawyer;
    • For the purposes of collecting a debt;
    • To protect ourselves from fraud;
    • To investigate an anticipated breach of an agreement or a contravention of law.

Policy 3 – Using and Disclosing Personal Information

  1. We will only use or disclose personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes, such as:
    • To conduct fan surveys in order to enhance the provision of our services;
    • To contact our fans directly about products and services that may be of interest.
  2. We will not use or disclose personal information for any additional purpose unless we obtain consent to do so.
  3. We will not sell fan lists or personal information to other parties.

Policy 4 – Retaining Personal Information

  1. If we use personal information to make a decision that directly affects the fan, we will retain that personal information for at least one year so that the fan has a reasonable opportunity to request access to it.
  2. Subject to policy 4.1, we will retain personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

  1. We will make reasonable efforts to ensure that personal information is accurate and complete where it may be used to make a decision about the fan or disclosed to another organization.
  2. Fans may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
  3. If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the fan’s correction request in the file.

Policy 6 – Securing Personal Information

  1. We are committed to ensuring the security of fan personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
  2. The following security measures will be followed to ensure that fan personal infromation is appropriately protected:
    • Physically security offices where personal information is held;
    • The use of user IDs, passwords and firewalls.
  3. We will use appropraite security measures when destroying fans’ personal information, such as shredding documents and securely deleting electronically stored information.
  4. We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Fans Access to Personal Information

  1. Fans have a right to access their personal information, subject to limited exceptions, such as when such disclosure would reveal personal information about another individual.
  2. A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
  3. Upon request, we will also tell fans how we use their personal information and to whom it has been disclosed if applicable.
  4. We will made the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
  5. A minimal fee may be charged for providing acess to personal information. Where a fee may apply, we will inform the fan of the cost and request further direction from the fan on whether or not we whould proceed with the request.
  6. If a request is refused in full or in part, we will notify the fan in writing, proviing the reasons for the refusal and the recourse availalbe to the fan.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

  1. The Privacy Officer or designated individual is responsible for ensuring the Victoria HarbourCats’ compliance with this policy and the Personal Information Protection Act.
  2. Fans should direct any complaints, concerns or questions regarding the Victoria HarbourCats’ compliance in writing to the Privacy Officer or designated individual. If the Privacy Officer or designated individual is unable to resolve the concern, the fan may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for the Victoria HarbourCats’ Privacy Officer and designated individual:

Jim Swanson
General Manager / Privacy Officer
101 – 1814 Vancouver Street
Victoria, BC V8T 5E3
778-265-0327
jim@harbourcats.com

Ticketing & Technology Operations Manager
101 – 1814 Vancouver Street
Victoria, BC V8T 5E3
778-265-0327
info@harbourcats.com

(Policy last updated and in force as of April 16th, 2013).