Privacy Policy

On January 1, 2004, Canada’s Personal Information Protection and Electronic Documents Act came (PIPEDA) into effect. The Act balances the need for organizations to gather and use personal information with your right to privacy. It also gives you control over your personal information by requiring organizations to obtain your consent to collect, use or disclose information about you.

Personal information includes all information an organizations collects, retains or uses that can in any way identify or give information about an individual. It does not include the name, title, business address or business contact information of an organization’s employee.

Meeting PIPEDA compliance requirements has provided Kinasao Lutheran Bible Camp with the opportunity to put policies and practices in place to safeguard your privacy in accordance with the Act. In January of 2004, Kinasao Lutheran Bible Camp Board adopted a Policy to Protect Personal Information at Kinasao Lutheran Bible Camp. This policy ensures that the personal information provided to us from Kinasao members is collected, used and protected appropriately. The policy is based on the following ten PIPEDA principles:

  1. Accountability: Kinasao Lutheran Bible Camp is responsible for maintaining and protecting all personal information under its control. A Privacy Officer has been designated who is accountable for compliance with the ten principles that comprise the Kinasao Lutheran Bible Camp policy.
  2. Identifying purposes: When Kinasao Lutheran Bible Camp asks for your personal information, the purpose for which it is being collected will be identified. The information is used to inform you about the life of Kinasao, maintain your subscriptions to Kinasao publications, register you for Kinasao programs and events, fund raise for Kinasao capital and operating budgets and compile statistical and historical information about Kinasao Lutheran Bible Camp. Health information is collected to look after the health and safety of campers, staff and volunteers while in the care or employ of Kinasao and to respond to emergency situations. Personal information is not shared with third parties without your express consent.
  3. Consent: Kinasao Lutheran Bible Camp requires your knowledge and consent for the collection, use or disclosure of your personal information, except where it is required or permitted by law.
  4. Limiting Collection: Kinasao Lutheran Bible Camp collects information by fair and lawful means and limits collection to those details necessary for identified purposes. The personal information collected is usually limited to name, title, gender, age, address, telephone number, email address, photos and congregational membership.
  5. Limiting use, disclosure and retention: Kinasao Lutheran Bible Campuses your personal information only for the purpose for which it was collected unless your consent is sought to do otherwise. Personal information is retained indefinitely for archival purposes unless you request to have it deleted.
  6. Accuracy: Kinasao Lutheran Bible Camp endeavors to ensure that the information collected and used is accurate, up to date and as complete as possible. However, individuals are relied upon to inform us of changes to their personal information. You may request access to your personal information and if applicable, request that we make corrections or changes to your file.
  7. Safeguarding information: Kinasao Lutheran Bible Camp applies appropriate safeguards to our computer networks and physical files and access to personal information about you is restricted to those Kinasao employees and authorized administrators who need to use the information for the identified purposes.
  8. Openness: Kinasao Lutheran Bible Camp makes information available to you concerning the practices that apply to the protection of your personal information.
  9. Individual access: At your request, you will be informed of the existence, use and disclosure of your information and be given access to it. You may verify the accuracy and completeness of your information, and may request that it be amended or deleted.
  10. Challenging compliance: Kinasao Lutheran Bible Camp Privacy Officer will answer any questions or enquiries you have about Kinasao Lutheran Bible Camp Privacy Policy or practices

The complete Policy to Protect Personal Information in Kinasao Lutheran Bible Camp follows:

  1. Accountability

    1. Kari Alford, Kinasao Lutheran Bible Camp Executive Director is hereby appointed as the personal information compliance officer (the “officer”) of Kinasao Lutheran Bible Camp.
    2. All persons, whether employees, volunteers or board or committee members who collect, process or use personal information shall be accountable for such information to the officer.
    3. This policy shall be made available upon request.
    4. Any personal information transferred to a third party for processing is subject to this policy. The officer shall use contractual or other appropriate means to protect personal information at a level comparable to this policy while a third party is processing this information.
    5. Personal information to be collected, retained or used by Kinasao shall be done so only after the officer gives written approval. This information shall be secured according the officer’s instructions.
    6. Any person who believes that Kinasao uses personal information collected, retained or used for purposes other than those the person explicitly approved may contact the officer to register a complaint or make a related inquiry.
    7. Upon receiving a complaint from any person regarding the collection, retention or use of personal information, the officer shall promptly investigate the complaint and notify the person who complained about his/her findings and corrective action taken, if any.
    8. Upon receiving the response from the officer, the person who filed the complaint may appeal to the Kinasao Lutheran Bible Camp Board to review and determine the disposition of the complaint at issue.
    9. The determination of the Kinasao Lutheran Bible Camp Board shall be final and the officer shall abide by and implement any of their recommendations.
    10. The officer shall communicate and explain this policy and give training regarding it to all employees and volunteers who might be in a position to collect, retain or use personal information.
    11. The officer shall prepare and disseminate information to the constituency which explains Kinasao Lutheran Bible Camp’s protection of personal information policies and procedures.

  2. Identifying Purposes

    1. The officer shall document the purpose for which personal information is collected to comply with the openness and individual access principles outlined below.
    2. The officer shall determine the information that will be needed to fulfill the purposes for which the information is to be collected in order to comply with the limited collection principle.
    3. The officer shall ensure that the purpose is specified at or before the time of collecting the personal information from an individual.
    4. The officer shall ensure that the information collected will not be used for any other purpose before obtaining the individual’s approval, unless the new purpose is required by law.
    5. The officer shall ensure that a person collecting personal information will be able to explain to the individual why the information is being collected, how it will be retained and if and when it will be disclosed.
    6. The officer shall ensure that limited collection, limited use, disclosure and retention principles are respected in identifying why personal information is to be collected.

  3. Consent

    1. The officer shall ensure that the individual from whom personal information is collected consents to the collection and to the manner in which it will be used and disclosed.
    2. The officer shall ensure that the individual can reasonably understand why and how the information will be used when consent is given.
    3. The officer shall ensure that express consent is obtained wherever possible and appropriate. In some circumstances, implied consent may be acceptable if the information’s sensitivity and the policy’s purpose and intent is respected. (For example, implied consent might exist if it is generally understood that information obtained when a new member (camper, staff, volunteer) joins, applies or registers at Kinasao Lutheran Bible Camp that the information will be used for all Kinasao Lutheran Bible Camp related purposes.) Implied consent may not be assumed if Kinasao Lutheran Bible Camp passes on personal information to a para-church organization.
    4. In obtaining consent, the officer shall ensure that the individual’s reasonable expectations are respected. For example, a person giving his/her name to Kinasao Lutheran Bible Camp to receive the Kinasao Newsletter, reasonably expects that Kinasao will use that personal information to send other information about itself.
    5. The officer shall ensure that the express consent obtained from an individual is clear and in an appropriately verifiable form. For example, an application form may be used and kept on file where the individual consents to the collection and specific use; a check box may be used to permit information already on file to be used for a new purpose; consent may be given orally which would require the receiver of the consent to create appropriate documentary evidence; or consent might be given by email, requiring an electronic record to be maintained.
    6. The officer shall ensure that the individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The individual shall promptly be informed of the implications of the withdrawal.

  4. Limiting Collection

    1. The officer shall ensure that personal information will not be collected indiscriminately. Both the amount and type of information collected shall be limited to that which is necessary to fulfill the purposes identified.
    2. The officer shall ensure that information is collected only by fair and lawful means without misleading or deceiving individuals as to the reason.
    3. The officer shall ensure that the identifying purposes and consent principles are followed in identifying why personal information is to be collected.

  5. Limiting Use, Disclosure and Retention

    1. The officer shall ensure that personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law, and any use of personal information shall be properly documented.
    2. The officer shall ensure that all personal information is destroyed, erased or made anonymous as soon as the purpose for which it was collected is no longer relevant.
    3. The officer shall ensure that all use, disclosure and retention decisions are made in the light of the consent principle, the identifying purposes principle and the individual access principle.

  6. Accuracy

    1. The officer shall reasonably ensure that the personal information is accurate, complete and up to date, taking into account the individual’s interests. The officer shall ensure that the information is sufficiently accurate, complete and up to date to minimize the possibility that inappropriate information might be used to make a decision about an individual.
    2. The officer shall ensure that Kinasao Lutheran Bible Camp does not routinely update personal information unless it is necessary to fulfill the purposes for which it was collected.
    3. The officer shall ensure that personal information used on an ongoing basis should be generally accurate and up to date, unless limits to the requirement for accuracy are clearly outlined.

  7. Safeguards

    1. The officer shall ensure that Kinasao Lutheran Bible Camp has security safeguards to protect personal information against loss or theft and unauthorized access, disclosure, copying, use or modification. This shall be done regardless of the format in which Kinasao Lutheran Bible Camp holds the information.
    2. Depending on the information’s sensitivity, the officer may permit reasonable discretion regarding the information that has been collected: the amount, distribution, format and method of storage. A higher level of protection shall safeguard more sensitive information according to the consent principle’s considerations.
    3. The officer shall ensure that the protection methods include:
      1. Physical measures (locked filing cabinets, restricted access to offices);
      2. Organizational measures (security clearance, limiting access on a ‘need to know’ basis); and
      3. Technological measures (passwords and encryption).
    4. The officer shall ensure that all Kinasao employees and volunteers know the importance of keeping personal information confidential.
    5. The officer shall ensure that care is taken when personal information is disposed of or destroyed to prevent unauthorized parties from gaining access to it.

  8. Openness

    1. The officer shall ensure that Kinasao Lutheran Bible Camp is open about its policies and practices regarding the management of personal information. The policies and information about the related practices shall be available without unreasonable effort in a generally understandable format.
    2. The officer shall ensure that information about Kinasao Lutheran Bible Camp’s policies and practices shall include:
      1. The name or title and address of the officer who is accountable for Kinasao Lutheran Bible Camp’s polices and practices and to whom complaints or inquiries may be forwarded;
      2. The means of gaining access to personal information held by Kinasao Lutheran Bible Camp;
      3. A description of the type of personal information held by Kinasao Lutheran Bible Camp, including a general account of its use;
      4. A copy of any information that explains Kinasao Lutheran Bible Camp’s policies, standards or codes; and
      5. What, if any, personal information is made available to related organizations.
    3. The officer shall ensure the information that must be provided according to 8.2 is available on the Kinasao website or in print as requested.

  9. Individual Access

    1. The officer shall ensure that upon request, an individual shall be informed whether Kinasao Lutheran Bible Camp holds personal information about him/her. If possible, the information’s source shall also be given. Kinasao Lutheran Bible Camp shall allow the individual access to this information. It shall also account for the use that has been made or is being made of this information and give an account as to any third parties to whom it has been disclosed.
    2. If Kinasao Lutheran Bible Camp has supplied personal information about an individual to third parties, the officer shall ensure that an attempt is made to be as specific as possible with a list of the organizations to which it has actually disclosed the information. If an actual list is impossible to provide, a list of organizations to which it might have disclosed information about the individual is to be provided.
    3. The officer shall ensure that Kinasao Lutheran Bible Camp responds to an individual’s request within a reasonable time and at minimal or no cost to the individual. The requested information shall be made available in a generally understandable form with abbreviations or codes explained.
    4. The officer shall ensure that when an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Kinasao Lutheran Bible Camp shall amend the information as required. When appropriate, the amended information shall be transmitted to third parties having access to the information.

  10. Challenging Compliance

    1. The officer is authorized to address a challenge concerning compliance with the above principles.
    2. The officer shall develop procedures to receive and respond to complaints or inquiries about the policies and practices regarding the handling of personal information. The compliance procedures shall be easily accessible and simple to use.
    3. The officer shall inform individuals inquiring about lodging complaints that relevant complaint procedures exist.
    4. The officer shall investigate all complaints. If a complaint is found to be justified, the officer shall take appropriate measures, including, if necessary, amending the policies and practices.

Adopted by Kinasao Lutheran Bible Camp Board

January 2004