Privacy of Member Information

Table of Contents

1.0  Privacy Policy

The Rocky Rod and Gun Club (henceforth referred to as “the Club”) shall collect and manage member information in accordance with the basic tenets of Canadian privacy laws and its Bylaws.

1.1  Objectives

  • Outline the tenets of privacy of information.
  • Catalogue the types of online and electronic media that the Club shall use to collect information about its members.
  • Inform every member about how their personal information shall be used.
  • Define and collect applicant information from every member.
  • Identify rules about using information about members that:
    1. govern disclosure;
    2. limit access; and
    3. maintain the quality of their information.
  • Ensure that information collected about members is used for:
    1. Club administration purposes;
    2. insurance and liability coverage; and
    3. in accordance with the Shooting Club and Shooting Range Regulations and Chief Firearms Office requirements.
  • Access to information about the Club members shall be strictly controlled by the Board of Directors of the Club.

1.2  Policy Background

  1. Privacy rights, while not explicit in the Canadian Constitution, falls under Section 7 of the Constitution and affords everyone the “right to security of the person.”
  2. Privacy legislation in Canada governs the personal information handling practices of public sector organizations.
  3. The privacy practices of public sector organizations shall govern how the Club manages the personal information about its members.
  4. Privacy legislation protects and governs the use of personal information about individuals that identify their:
    1. name and address;
    2. race, national or ethnic origin, and religion;
    3. age, gender, and marital status;
    4. social insurance numbers, driver’s license and/or health cards;
    5. financial data; and
    6. medical, education or employment history.
In accordance with Shooting Clubs and Shooting Ranges Regulations SOR/98-212, the Club must collect Possession and Acquisition License (PAL) numbers. This license numberidentifies a member of the Club and shall be treated the same way as in point (4) (d).
  1. Information collected about individuals by public sector organizations can only be used for the purpose for which it was collected.
  2. Information collected by the Club must only be used for the purpose for which it was collected:
    1. to confirm Rocky Rod and Gun Club membership requirements; and
    2. to satisfy the requirements of Chief Firearms Office and Shooting Clubs and Shooting Ranges Regulations SOR/98-212.
  3. While Alberta not-for-profit Societies do not fall under the province’s privacy legislation, they still have an obligation to manage the private and personal information of its members according to the basic tenets of privacy law.

1.3.1  Collecting Member and Guest Information

  1. The Club shall collect Member information for administrative purposes and in accordance with the Club Bylaws and the Shooting Clubs and Shooting Ranges Regulations SOR/98-212.
  2. The Club shall collect member information using the following means:
    1. hardcopy applications forwarded directly to the Board of Directors;
    2. hardcopy applications collected from 3rd party business affiliates selling Club memberships;
    3. online applications submitted through the Club website; and
    4. FOB, card or any other electronic devices that open access gates and track shooting range usage.
  3. The Club must collect information on the following:
    1. member name, address, phone number and email address information;
    2. member number;
    3. as per Regulations SOR/98-212:
      1. the Possession and Acquisition License (PAL) number;
      2. the name, address and phone number of guests;
      3. a guest PAL number if one exists; and
    4. family member names of a family membership.
  4. Paying Club membership dues using cheques, electronic money transfers, debit or credit cards are transitory financial records that shall be processed:
    1. as a financial transaction between the member’s banking institution and the Club’s banking institution;
    2. to confer that the member is in good standing with the Club; and
    3. and deleted after the financial transaction is complete.
  5. Photographic, film, and video likenesses of members or guests can only be used on the Club website or social media when it is approved by that member or guest.
  6. In accordance with the Shooting Clubs and Shooting Ranges Regulations SOR/98-212,for guests participating in sponsored shooting competitions, the Club shall collect:
    1. name, address, phone number and email address information of participant;
    2. Club member number if applicable;
    3. shooting federation membership number if applicable;
    4. the number of his or her license to possess firearms – Possession and Acquisition License (PAL) number; and
    5. store and maintain the information for a period of 5 years.
  7. The Board of Directors shall manage member information and:
    1. keep it on a secure database;
    2. back it up throughout the year including offsite storage;
    3. back up the database of information at year end including offsite storage; and
    4. make changes to the information as requested by a member.
  8. Consecutive yearly backups of databases containing information about Club members shall be stored off site for purposes of:
    1. producing year over year trend and aggregate membership data;
    2. analyzing membership trends and interests in the Club; and
    3. producing membership data and shooting range usage as required by the Chief Firearms Officer under the authority of the Shooting Clubs and Shooting Ranges Regulations SOR/98-212.
  9. Every member has the right to review their personal information and to correct that information.
  10. As required, the Board of Directors may identify additional data to collect from its members and help with the management of the Club.
  11. As required, the Board of Directors may need to implement additional data to collectfrom its members because of regulation changes implemented by the RCMP through their Shooting Clubs and Shooting Ranges Regulations SOR/98-212.

1.3.2  Rules about Using Member and Guest Information

  1. A member has the right to access personal information about themselves to verify the accuracy of that information or to correct it.
  2. Other than members of the Board of Directors and approved committee members with specific responsibilities, a member shall never be granted access to personal information about another member.
  3. Information regarding membership dues, payment, and personal information shall be shared with the Club’s Treasurer as required.
  4. Selling or sharing Club member information to a third (3rd) party is prohibited, with the exception noted in point (5) below.
  5. The Chief Firearms Officer (CFO) of Alberta is the exception to point (4) above. The CFO in accordance with Shooting Clubs and Shooting Ranges Regulations SOR/98-212:
    1. “may request a report containing all or any requested part of the information”1 described in 1.3.1 Collecting Member Information point (3) (a) (b) (c) (d); and
    2. “request … a written description of participation, if any, of a current or pastmember … of the shooting club, or his or her guest, in target practice or target shooting competitions within the previous five years.”2
  6. With the permission of the appropriate member, the Board of Directors may post photographs, film, and video likenesses on the Club’s Website or on Social Media.
  7. The Board of Directors shall have access to members’ information in the commission of their duties for the Club.
  8. As per the Bylaws, “members not in good standing” shall be removed from the Club’s database and website as necessary.
1: Shooting Clubs and Shooting Ranges Regulations SOR/98-212, January 31, 2017, page 7. 2: Ibidem; page 8.

1.4  Periodic Review and Updates

  1. The Board of Directors shall periodically review this policy.
  2. Updates to this policy may be recommended by the Board of Directors.
  3. Updates to this policy that result from new requirements identified in the Shooting Clubsand Shooting Ranges Regulations SOR/98-212 may be implemented by a Board of Directors decision.
  4. Implementation of any recommendations from the Board of Directors shall be approved by general meeting resolution.
  5. All changes shall be published and communicated to members through the Club website and/or social media.

1.5  Website Cookies

  1. Cookies: A cookie is a small computer file or piece of information that may be stored inthe website user’s electronic device’s hard drive when they visit websites. Cookies are widely used, and most web browsers are configured initially to accept cookies automatically.
  2. The Club may use cookies to improve the Club’s website’s functionality, and in some cases, to provide website users with a customized online experience.
  3. Website users may change their internet browser settings to adjust and manage the handling of their individual website cookies. Such settings may prevent the website user’scomputer from accepting cookies, or the settings may notify the user when receiving a cookie so that they may manually decline its acceptance. Please note, however, if website users disable cookies, they may not experience optimal performance of the Club’s website.

1.5.2  Other Third-Party Websites

  1. The Club’s website may contain links to other third-party sites that are not governed by this privacy policy.
  2. The Club endeavors to only link to sites with high privacy standards, however, theClub’s privacy policy will no longer apply once a user leaves the Club’s website.
  3. The Club is not responsible for the privacy practices employed by third-party websites. Therefore, the Club recommends that the user examine the privacy statements of any third-party websites to learn how their information may be collected, used, shared, and disclosed.