Privacy Policy

Introduction

Windermere Golf and Country Club (“Windermere”) recognizes the importance of privacy and recognizes the sensitivity of personal information received by us in the course of our business. We recognize our obligation to maintain the confidentiality of our members’ and clients’ information and recognize our obligations concerning the personal information that we collect, use or disclose in our business. This policy has been developed with those obligations in mind.

The Personal Information Protection Act (PIPA) regulates the way that private sector organizations in Alberta collect, use and disclose personal information. Furthermore, PIPA regulates requests from individuals for access to the personal information that has been collected by organizations.

Where practical, we endeavor to collect personal information directly from the person to whom the information pertains. When necessary, we will collect personal information from other sources. By becoming a member or using the services provided by Windermere, an individual consents to our necessary collection, use or disclosure of the individual’s personal information in order to allow us to serve our members and clients. It is our policy to collect personal information about individuals other than our members and clients in accordance with the provisions of the PIPA. When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete.

Collection, Consent, Use and Disclosure of Personal Information

Collection

Why do we collect personal information?

Windermere collects personal information for the purposes of serving the needs of our members and clients. We require information to:

• Understand, access, and assist our members and clients with ongoing retail, food services and golfing needs, as well as bill members and clients for the services rendered; and

• Ensure information is accurate and up to date.

  • Windermere collects personal employee information for the purposes of serving the employment-related needs of our employees. We require information to:

  • Understand, access, and assist our employees with ongoing employment and employee benefit needs, as well as pay employees for the services rendered; and

  • Ensure information is accurate and up to date. 

What information do we collect?

‘Personal information’ refers to information about an identifiable individual. In Alberta, business contact information such as your office address, job title, business phone number, email address, fax number or other related business contact information is not considered personal information.

The types of personal information that Windermere may collect about you include, but are not limited to the following:

• Your name,

• Home address,

• Telephone number,

• Personal email address,

• Billing and account information,

• Information about a member’s and client’s preferences,

• Financial information,

• Tee times,

• Club facility bookings,

• Any other personal information that may be collected in accordance with the provisions of PIPA.

‘Personal employee information’ is information in respect of an employee or potential employee that is personal and is collected, used, or disclosed solely for the purposes of establishing, managing, or terminating an employment or volunteer relationship. It should be noted that personal employee information does not include information that is unrelated to this purpose.

How do we collect your personal information?

We collect personal information in accordance with the provisions of PIPA. Wherever possible we collect your personal information directly from you. Should it become necessary for us to collect additional personal information from a third party we will obtain your prior consent in writing or verbally.

If personal employee information must be collected from other sources we will, where required, first obtain the consent of the individual.

Consent

PIPA provides that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information.

Consent may be given in the following ways: We will request either your written or express oral consent, which may be given in person or over the telephone if your identity is authenticated.

If you volunteer to provide relevant personal information verbally or in writing, we assume that you are consenting to the collection, use and disclosure of your personal information as described in our Privacy Policy.

When you initiate contact with us, we may determine that consent has been implied for us to collect, use, and disclose personal information in a reasonable manner.

In some situations, we may require express consent in writing, by the provision of a letter, application form, electronic signature, or other document authorizing certain activities; and

If the information is being used solely for the purpose of the employment relationship, then consent in some circumstances may be implied.

• There are certain circumstances where we are required or permitted by law to collect, use, and disclose personal information without consent. Such circumstances include, but are not limited to where:

• The collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way,

• The collection, use of disclosure is necessary to respond to an emergency that threatens the life, health, or security of an individual or the public,

• It is necessary to establish or collect payment for services provided,

• Collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding,

• The personal information is available to the public from a prescribed source,

• The collection, use, or disclosure is required or authorized by a statute or regulation of Alberta or Canada.

We will handle all personal information confidentially and will substantiate the legal authority to collect, use and disclose personal information in these circumstances. Furthermore, we will make reasonable efforts to ensure that the information we collect is accurate and complete.

Use

We use your personal information to provide services to you and to administer our business incidental to providing services, such as member and client billing. With your permission, we may send you information about our other services, or about new developments in our business and new services we may offer. You may at any time withdraw your consent by notifying us, and we will not send you any such material.

Disclosure

Windermere will not disclose or sell your personal information or business contact information to any third party to enable them to market their products or services.

Your personal information will only be disclosed if it is necessary or beneficial to the provision of services to you, our member and client. Information may be disclosed to the following sources:

• Our staff and agents who use the information for the reasonable business purpose of providing you with services,

• To a third party we contract to provide administrative services to the business. These third-party contractors are bound by law not to use this information in a way that would be inconsistent with the privacy laws of Alberta,

• Professionals working with us such as lawyers, accountants, and consultants,

• Financial institutions

Protection (Safeguarding your information)

We recognize our professional and legal obligations to protect the confidential information of our employees, members and clients. We have made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.

Access

Requesting Access to your Personal Information

PIPA requires that every organization that collects personal information about an individual give that individual access to the personal information that they have in their custody or control upon request. Furthermore, the law requires that the organization must state the purposes for which the personal information is being used, and the circumstances and names of all persons to whom this personal information has been disclosed.

You may request access to your personal information by directing a written request to Windermere’s privacy officer, as identified below.

We will respond to you in the time allowed under PIPA. Furthermore, we are permitted by law to charge you a reasonable fee for retrieval and copying of your personal information; you will be notified of the amount prior to us completing the request. If the fee is going to be extensive due to a large volume of information you may be required to pay a deposit in advance of receiving the information.

Denial of access to personal information

There are two sets of specific circumstances where you may be denied access to your information.

First, the following list describes circumstances where Windermere may refuse to give you access:

• The information is protected by any legal privilege,

• The disclosure of the information would reveal confidential information that is of a commercial nature, and it is not unreasonable to withhold that information,

• The information was collected for an investigation or legal proceeding,

• The disclosure of the information might result in that type of information no longer being provided to the organization when it is reasonable that that type of information would be provided,

• The information was collected by a mediator or arbitrator or was created in the conduct of a mediation or arbitration for which the mediator or arbitrator was appointed to act,

• Under an agreement,

• Under an enactment,

• By a court; or

• The information relates to or may be used in the exercise of prosecutorial discretion,

Secondly, the following list describes circumstances where Windermere must refuse to give you access:

• The disclosure of the information could reasonably be expected to threaten the life or security of another individual,

• The information would reveal personal information about another individual,

• The information would reveal the identity of an individual who has in confidence provided an opinion about another individual and the individual providing the opinion does not consent to disclosure of his or her identity.

Revisions to Personal Information

The law permits individuals to submit written requests to us to correct errors or omissions in their personal information that is in our custody or control. We will:

• Correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or

• Decide not to correct the personal information but annotate the personal information that a correction was requested but not made.

Other

Communications by Email

We will imply your consent to use e-mail to send personal or confidential information unless you expressly notify us that you do not want to be contacted by this form of communication.

Changes to this Privacy Statement
We may review and change our Privacy Policy without notice, from time to time, in order to update our privacy commitment to you in keeping with current privacy laws.

Contact Information and Resources
If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Membership & Communications Coordinator at:
Windermere Golf and Country Club
Attention: Drew Johnson, Membership & Communications Coordinator
19110 Ellerslie Road SW
Edmonton, Alberta, T6W 1A5
Telephone (780) 988-5501, ext. 100
Email:  drewj@windermeregcc.com

If you are dissatisfied with our handling of your personal information, we invite you to contact our Membership & Communications Coordinator in writing, setting out the reasons for your concern. If, after our Membership & Communications Coordinator has reviewed and responded to your concern, you remain dissatisfied, you may wish to contact the Information and Privacy Commissioner at:
Office of the Information and Privacy Commissioner of Alberta
410, 9925-109th Street
Edmonton, Alberta, T5K 2J8
Telephone: (780) 422-6860
Website: http://www.oipc.ab.ca