1. Introduction
The Quebec and Ottawa Valley Provincial Committee (QOVPC) of the Air Cadet League of Canada (ACLC) is committed to respecting the privacy of website visitors, QOVPC members, volunteers, air cadets and others. The following statement summarizes how the QOVPC collects, uses, discloses and safeguards your personal information, the type of information the QOVPC collects, and its practices in collecting, using, maintaining, protecting and disclosing that information.
The QOVPC will only use your personal information in accordance with this Privacy Policy, unless otherwise required by applicable law. The QOVPC takes steps to ensure that the personal information it collects is accurate, relevant, not excessive and used for limited purposes.
Elements of this policy that relate specifically to the website apply only to the QOVPC website. We are not responsible in any way for the practices of other websites that may be linked to the QOVPC website.
1.1 Definitions
“Personal information” means information about an identifiable individual, but does not include business contact information.
“Business contact information” means information such as a person’s name, title, business address, telephone number or e-mail address, which is collected, used or disclosed for the sole purpose of communicating with that person in the course of that person’s employment or profession.
2. Collection and use of your personal information
The QOVPC obtains personal information only when it is voluntarily provided. In general, it is obvious that QOVPC only collects personal information to initiate or maintain communication or correspondence. More specific uses will be described in this Privacy Policy.
The collection of personal information shall be limited to that which is necessary for the purposes identified, and information shall be collected by fair and lawful means. The QOVPC will not use any form of deception to obtain personal information.
The QOVPC does not sell the personal information it collects.
3. Website visitors
The QOVPC collects and uses several types of information about and from you, including:
- Personal information, obtained when you contact us via our website with your comments, questions and/or complaints, which may involve collecting and using your name, e-mail address and telephone number to enable us to respond promptly to your question or complaint. We may also retain this information to assist you in the future and to improve our customer service, product and service offerings, events and promotions.
- Non-personal information, which does not directly or indirectly reveal your identity or relate directly to an identified person, such as demographic information or statistical or aggregate information. Statistical or aggregated data does not directly identify an individual, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific website function.
- Technical information, including your login information, audit and tracking logs which may include various information such as IP addresses, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your Internet connection, the equipment you use to access our website and usage details.
- Non-personal details about your interactions with the website, including full Uniform Resource Locators (URLs), the flow of clicks to, through and from our website (including date and time), page response times, download errors, length of visits to particular pages, information about page interaction (such as scrolling, clicks and mouse-over), methods used to navigate away from the page, or any telephone number used to call our customer service number.
QOVPC websites may include links to third-party websites, plug-ins, services, social networks or applications. Clicking on these links or activating these connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or activate a third-party plug-in, please note that these third parties have their own privacy policies and that we accept no responsibility for these policies. We do not control these third-party websites and encourage you to read the privacy policy of every website you visit.
4. QOVPC members and affiliates
The ACLC maintains a database of your personal information which is used to maintain current contact information, emergency contact information, membership status and your QOVPC participation history, if applicable. Additional information on the use of your personal information will be communicated to you at the time of collection.
Only ACLC and QOVPC staff and members with a legitimate need to access this information have access to the database.
5. Consent
The QOVPC collects personal information only when it is voluntarily provided. We will seek consent to use or disclose personal information at the time of collection, and before using or disclosing it, as appropriate.
In determining the form of consent to use, whether express or implied, the QOVPC will take into account the sensitivity of the information and the reasonable expectations of the individual in the circumstances. For example, if you initiate a communication with the QOVPC (for example, by sending an e-mail) and provide personal contact information, we will assume that you authorize us to use your personal contact information to respond to the communication.
The QOVPC will not ask an individual to consent to the collection, use or disclosure of information beyond what is necessary to achieve the specified purpose.
6. Disclosure of personal information
Personal information is disclosed to the QOVPC and to approved QOVPC authorities and contractors who require such information to perform their official duties within the scope of the QOVPC’s objectives and in relation to the stated purpose. Personal information is also disclosed to QOVPC’s professional advisors.
In addition, in the case of donations, a mailing address is required by the Canada Revenue Agency (CRA) and will be provided on any tax receipt issued.
Personal information may also be disclosed to comply with a subpoena, warrant or order issued by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records, or if the information relates to a contravention of national or provincial law that has been or is about to be committed, or to activities suspected of constituting threats to the security of Canada.
The QOVPC does not share mailing lists.
7. Accuracy
Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Notification of changes to personal information, such as changes to telephone numbers and e-mail addresses, may be necessary to ensure continuity of communication and data accuracy.
8. Safeguards
The QOVPC takes reasonable administrative and technical measures to ensure the security of personal information, including (but not limited to) policy training, restricted office access, locked lanes, restricted file access and passwords. Examples of specific measures implemented by the QOVPC can be provided upon request, subject to reasonable limitations designed to ensure the effectiveness of the measures in question.
9. Retention of personal information
Unless otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as is necessary to fulfil the purposes for which we collected it, including to satisfy any legal, accounting or reporting requirements.
Information relating to the registration and screening of QOVPC volunteers will be held on a secure and restricted database for the lifetime of the organization, sufficient to demonstrate that the QOVPC has met its duty of care to Air Cadets regarding the responsible use of volunteers working with young people.
Personal information used to make a decision about you will be retained for at least one year to allow you access to this information once the decision has been made. Personal information may be marked for a longer retention period, where appropriate.
10. Accessing and correcting your personal information
Upon written request, you will be informed of the existence, use and disclosure of your personal information, and you will be given access to this information, insofar as the QOVPC has retained it.
The requested information will be communicated to you within 30 days of receipt of the written request, at no cost to you or at a nominal photocopying charge, unless there are reasonable grounds for extending the deadline.
If personal information is inaccurate or incomplete, it will be amended accordingly.
11. Withdrawing your consent
You may withdraw your consent to the collection, use or disclosure of personal information at any time, subject to legal or contractual restrictions (such as information retained to protect the QOVPC from liability), provided that you give reasonable notice of such withdrawal to the QOVPC. The executive director will inform you of the consequences of such withdrawal.
12. Changes to the Privacy Policy
The QOVPC reserves the right to modify this privacy policy. Any changes to this privacy policy will be posted on the website for public review.
13. Contact information and challenging compliance
Questions, comments or concerns regarding this Privacy Policy or its administration by the QOVPC may be directed to the executive director by calling 438-858-4883, ext. 105, or by writing to the Air Cadet League of Canada, Quebec and Ottawa Valley Provincial Committee, PO Box 6100, Station St-Luc, St-Jean-sur-Richelieu, QC, J2W 2A1. Inquiries may also be addressed to the QOVPC by e-mail: dg@cadetsair.ca.
If you are not satisfied with the QOVPC’s response to a complaint, or if you believe that the QOVPC is not complying with applicable privacy legislation, you may file a complaint with the appropriate Information and Privacy Commissioner.