INTERNATIONAL KARATE ORGANIZATION KYOKUSHINKAIKAN, CANADA (IKOKC)
Vulnerable Persons Protection Policy
Appendix D. Protection of Privacy.
IKOKC respects Individual privacy and takes responsibility for personal information under its control. This Policy and related Appendices balances the rights of participants to be protected against the rights of Individuals provided under the BC Human Rights Code, the BC Personal Information Act and the Canadian Charter of Rights and Freedoms.
Like Volunteer Canada’s 10 safe steps, Privacy is also based on 10 principles, being: accountability; identifying purposes; consent; limiting collection; limiting use, disclosure, retention; accuracy; safeguards; openness; Individual access; question or complaint.
This Policy explains how IKOKC collects, uses, and discloses the personal information that may be provided to IKOKC. Responsibility for ensuring compliance with this Policy rests with Branch Chief, who shall designate one or more persons to be accountable for compliance. At the present time this consists of Dojo Operators/Head Instructors and Designated Authority.
IKOKC will ensure the accuracy, confidentiality and security of Individual personal information, and as well will follow the legal requirements to allow an Individual to request access to and correction of his/her personal information.
This Policy and related Appendices does not impose any limits on the collection, use or disclosure of personal information that is covered by or subject to the Freedom of Information and Protection of Privacy Act (PIPA) or the Federal Access to Information and the Privacy Act.
IKOKC will only collect and use personal information that is necessary to fulfill the purposes identified to assess the suitability of Individuals to supervise, instruct, teach, train, direct, interact and work with Vulnerable Persons. IKOKC will not collect, use or disclose personal information except for the identified purpose unless the Individual provides further consent.
Consent can be provided orally, in writing, or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious to a reasonable person and the Member voluntarily provides his/her personal information for that purpose. Consent may also be implied where the Member is given notice and a reasonable opportunity to opt out of his/her personal information being used or disclosed and the Member does not opt out.
When collecting personal information of a sensitive nature, IKOKC will ensure it obtains express consent for the collection of such information. By submitting personal information to IKOKC the Member agrees that IKOKC may collect, use and disclose such information in accordance with this Policy and as permitted or required by law.
If the Member chooses to withdraw consent to the collection, use, and disclosure of his/her personal information which results in the frustration of the performance of a legal obligation or in the determination of assessing the suitability of Individuals to supervise, instruct, teach, train, direct, interact, work with Vulnerable Persons, IKOKC will advise the Member of the consequences of the withdrawal.
IKOKC will retain Member’s personal information only as long as necessary to fulfill the identified purposes governed under this Policy and related Appendices. IKOKC will develop guidelines and implement procedures to govern the destruction or anonymity of personal information or inappropriate use which is no longer to be retained.
IKOKC has implemented security safeguards which are appropriate to the sensitivity and protection of personal information against loss or theft; unauthorized access, collection, use, disclosure, copying; modification or disposal. Information will be retained in locked facilities and organizational access will limited on a “need to know basis.”
IKOKC will make reasonable efforts to ensure that Member’s personal information is accurate and complete in order to make a decision that directly affects the Member. To the extent a Member believes that the personal information provided to IKOKC is no longer accurate or complete, the Member may advise IKOKC Designated Authority to update its records, by submitting a request in writing and by providing sufficient detail, and the correction being sought. IKOKC Designated Authority will review the request and determine whether or not to correct the personal information as required, and so advise the Member in writing.
Subject to any exceptions as set out in the PIPA, an IKOKC Member has the right to access his/her personal information that is held by IKOKC. In order to obtain access the Member must make a written request to the Designated Authority setting out in sufficient detail the personal information being sought in order for IKOKC to identify the personal information being sought. IKOKC has the right to request that the Member provide sufficient personal information and identification and answers to any specific questions before providing any personal information being sought. Designated Authority will make a decision whether or not to allow the Member access to his/her personal information, and advise if any extension is required in order to respond to a Member’s request. If access is provided then only that Member’s personal information that is under IKOKC control will be provided within 10 business days. If access is refused in whole or in part, the Member will be notified in writing within 10 business days, outlining the reasons for refusal, including reference to any applicable privacy legislation.
If a Member has a question or complaint about IKOKC Vulnerable Persons Policy and related Appendices and/or privacy practices relating to the handling of his/her personal information, the Member shall direct his/her complaint, concern, or question in writing to the Designated Authority for adjudication. The Designated Authority will research the nature of the complaint, concern, or question,and review the matter with the Branch Chief, and respond in writing as to the outcome of the review within 30 business days.