Personal Information Protection Policy
At Club Tread, we are committed to providing our members with exceptional service. As providing this
service involves the collection, use and disclosure of some personal information about our members, protecting
their personal information is one of our highest priorities.
While we have always respected our members privacy and safeguarded their personal information, we
have strengthened our commitment to protecting personal information as a result 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 members 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 members’ personal information. Our privacy commitment includes ensuring
the accuracy, confidentiality, and security of our members’ personal information and allowing our members to
request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Club Tread. This policy also applies to any service
providers collecting, using or disclosing personal information on behalf of Club Tread.
Personal Information-means information about an identifiable individual including name, home address,
phone number, and email address.
Privacy Officer– means the individual designated responsibility for ensuring that Club Tread complies with this
policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the member voluntarily provides
his or her personal information for those purposes, we will communicate the purposes for which
personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect member information that is necessary to fulfill the following purposes:
- To verify identity and to identify member preferences and needs;
- To provide services and to send out association membership information;
Policy 2 – Consent
2.1 We will obtain member consent to collect, use or disclose personal information (except where, as noted
below, we are authorized to do so without consent).
2.2 Consent can be provided in writing, or it can be implied where the purpose for collecting using or
disclosing the personal information would be considered obvious and the member voluntarily provides
personal information for that purpose.
2.3 Consent may also be implied where a member is given notice and a reasonable opportunity to opt-out of
his or her personal information being used for mail-outs and the member does not opt-out.
2.4 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), members
can withhold or withdraw their consent for Club Tread to use their personal information in certain ways.
A member’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 member in making the decision.
2.5 We may collect, use or disclose personal information without the member’s knowledge or 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 or for the purposes of collecting a debt;
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose member personal information where necessary to fulfill the purposes
identified at the time of collection.
3.2 We will not use or disclose member personal information for any additional purpose unless we obtain
consent to do so.
3.3 We will not sell member lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use member personal information to make a decision that directly affects the member, we will
retain that personal information for at least one year so that the member has a reasonable opportunity to
request access to it.
4.2 Subject to policy 4.1, we will retain member 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
5.1 We will make reasonable efforts to ensure that member personal information is accurate and complete
where it may be used to make a decision about the member or disclosed to another organization.
5.2 Members 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.
5.3 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 members’
correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of member personal information in order to protect it from
unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 Security measures will be followed to ensure that member personal information is appropriately
6.3 We will use appropriate security measures when destroying member’s personal information such as
shredding documents and deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to
ensure ongoing personal information security.
Policy 7 – Providing Members Access to Personal Information
7.1 Members have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify
the personal information being sought.
7.3 Upon request, we will also tell members how we use their personal information and to whom it has been
disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of
an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we
will inform the member of the cost and request further direction from the member on whether or not we
should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the member in writing, providing the reasons for
refusal and the recourse available to the member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Club Tread’s compliance with
this policy and the Personal Information Protection Act.
8.2 Members should direct any complaints, concerns or questions regarding Club Tread’s compliance in
writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the member may
also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Club Tread’s Privacy Officer or designated individual:
Insert Contact Information