SKATE CANADA PRIVACY CODE
Effective Date: July 30, 2024
Policy Owner: Chief Executive Officer
Origination Date: September 10, 2017
Last Revised Date: March 11, 2026
Introduction – Our Commitment to Privacy
The Skate Canada Privacy Code (the “Code” and/or “Privacy Code”) pertains to the protection
of personal information collected by Skate Canada as part of our interactions with you. Skate
Canada is committed to protecting your privacy whether you are browsing for information or
conducting business with Skate Canada. The handling of all personal information is governed by
the Personal Information Protection and Electronic Documents Act (the Act or PIPEDA)1
.
Your privacy is important to us: At Skate Canada, protecting the privacy and confidentiality of
the personal information entrusted to us is very important and an integral part of our
commitment to excellence. To help us meet this commitment, Skate Canada has appointed a
Privacy Officer to oversee Skate Canada’s privacy practices.
You have choices: In an era in which technology increasingly facilitates the circulation and
exchange of information, we encourage you to read this Privacy Code so that you understand
how we collect, use, share, and protect your personal information and how you can manage
your information in a way that suits you.
About this Privacy Code
This Privacy Code works collectively with our Online Terms of Use. This Privacy Code applies to
the collection, use and disclosure of any confidential information, including personal
information, collected by Skate Canada in the course of conducting business with us (which
includes when you are accessing or using Skate Canada programs and services (including
attending and/or online streaming of events/competitions), using our website or mobile
application, and otherwise interact with us). It will continue to apply for as long as Skate
Canada holds your information, including after the termination of a program or service
agreements or arrangements with us. By providing us with your confidential information, you
are consenting to the collection, use, or sharing of your information for the purposes as set out
in this Code.
1 British Columbia, Alberta and Quebec privacy legislation has been deemed substantially similar to PIPEDA and
therefore follow their respective provincial privacy legislation.
To Whom does this Privacy Code Apply
This Privacy Code applies to Skate Canada in respect of confidential information that Skate
Canada collects, uses, or discloses from individual(s) for the operation of its business and/or in
the course of its organizational activities.
When a person registers with a club or skating school, they will also be registered with Skate
Canada. This means that Skate Canada may collect, use, disclose and maintain their confidential
information for certain purposes described in this Privacy Code and as required to establish,
register, administer, and maintain their relationship with us. This applies to registrants, coaches
and/or in connection with their affiliation with a skating club or skating school. Their
confidential information may also be exchanged with Skate Canada affiliates which includes
their local skating club or school or provincial association or section.
All individuals at one time or another may receive personal, privileged and/or confidential
information which may concern other individuals. Individuals are obligated to ensure that
confidential information to which they may have access remains confidential, is only used for
the purposes for which it was collected is not disclosed without authorization or used for
personal gain. Any individual who discloses confidential information, contrary to this Privacy
Code will be subject to disciplinary measures.
Individuals are required to follow the Skate Canada Privacy Code as outlined herein, which is
designed to comply with PIPEDA, regarding the collection, use and disclosure of confidential
information.
*Important Note – for the privacy policies of your club / skating school, please
direct any questions directly to your club / skating school using the process that
they describe on their website or in their privacy policy.
Guiding Principles of this Privacy Code
Skate Canada is accountable to those whose confidential information comes under its custody
for ensuring that their information is protected in a manner consistent with this policy.
Accountability for Skate Canada’s compliance with this Privacy Code rests with the Privacy
Officer, or delegate.
Skate Canada is responsible for confidential information in its possession or custody, including
information that has been transferred to or is accessed by a third-party service provider for
processing. Skate Canada uses contractual or other means to provide a comparable level of
protection while a third party is processing the information.
Skate Canada has implemented policies and procedures to give effect to the principles of the
Act, including:
• procedures to protect confidential information;
• procedures to receive and respond to inquiries and complaints; and
• training staff and communicating information to staff about Skate Canada’s policies
and procedures.
Collection, Use, Disclosure, and Retention
Skate Canada will identify the purpose for which it collects, uses, and discloses confidential
information prior to collecting the information. Skate Canada only collects, uses, or discloses
confidential information for purposes consistent with meeting its mandate and core functions.
This Privacy Code explains our current practices regarding what information Skate Canada may
collect, use, disclose and retain during the course of your relationship with us.
Collection
Skate Canada limits the collection of confidential / personal information to that which is
authorized and/or authorized by law, and/or where it is necessary for the purposes it has
identified, such as to provide you with a program and/or service you request or use, to ensure
the health and safety of individuals, and any applicable legal and regulatory obligations.
Confidential / personal information will be collected by Skate Canada through fair and lawful
means from the individual (e.g., through membership, registration through your club or skating
school), use of our programs and services, communications with us and/or third parties (e.g., by
telephone, use of our website, accessing/streaming online Skate Canada events/competitions,
email, third-party services (email, phone, website, applications), Sport Integrity Canada as part
of the CADP, external authorities for the Skate-Safe and Canadian Safe Sport Program, including
case management reporting systems, Case Manager, Sport Integrity Canada, legal counsel,
investigators, etc.) and the Skate Canada Safe Sport program, etc.)). Skate Canada will not
collect confidential information indiscriminately or in a misleading manner.
What kind of information do we collect?
The type of information including personal information we collect depends on various factors
and the medium in which you interact with Skate Canada, such as the program or services you
request or use, and any applicable legal or regulatory obligations. This information includes but
is not limited to:
• Contact information such as name, address, telephone number, email or other
electronic communication address, social media account and facsimile number
• Identifiable information such as age, demographics (as applicable), government issued
identification when required
• Financial information as part of payment details for a product or service your request as
applicable
• Login information when you login to Skate Canada IT owned resources (e.g., member
portal)
• Digital information when you browse or download information from the Skate Canada
website and use our applications, as our servers and that of our third-party service
providers automatically collect limited amounts of standard information about your
device and usage/activity of our applications and website to deliver our programs and
services, improve your experience, and for traffic monitoring and statistical purposes.
For example cookies, including but not limited to the following
o your internet protocol (IP) address of the computer you are using to access our
site (a number identifying your device or router on the internet), as well as your
internet service provider and sometimes your location, and your operating
system (MAC OS, iOS, Windows, Android, etc.) which is not stored or retained in
a format that can be used to identify you. Your location information is important
to help us provide features like search results for clubs and skating schools near
you based on your location
o operating systems and the types of versions of browsers used to access our site
(including but not limited to Google, Google Play, Firefox, Internet Explorer,
Safari, etc.)
o dates and times you access our site
• Personal Health Information as part of our Safe Sport program and processes. For
example, including but not limited to, the reporting and management of incidents of
injury, reporting and resolution of Skate-Safe reports, reporting and resolution of
Safe Sport reports, anti-doping, etc.), in the management of events/competitions, as
may be required, travel management, and medical emergencies
How do we collection information?
We may collect information from you both directly and indirectly, with much of the information
coming from you directly. For example,
• at time of registration with your club/skating school for a Skate Canada program and/or
service. Note: For the collection of identifiable confidential information for registration, a Notice of
Collection statement and consent must be completed by the registrants at time of registration with a
member (club, skating school) (See Appendix for the “Notice of Collection”).
• use of our programs and services (e.g., assessment results, qualifications, etc.)
• at time of application to be an event volunteer at a Skate Canada event/competition for
(e.g., training, education, work experience, volunteer experience, qualifications, etc.)
• correspondence or communications with us that may be monitored or recorded, such as
telephone calls, video conferencing, electronic communications, online chats, or other
interactions with Skate Canada’s website
• completion of forms
• purchases of Skate Canada merchandise, etc.
• interactions with us online, including through our social media website
• use of our website
• subscribing to Skate Canada publications (e.g., e-news, newsletters, etc.)
• surveys
• attending skating events / competitions hosted by Skate Canada
• online streaming of skating events / competitions hosted by Skate Canada
• visiting our Skate Canada Ottawa Service Centre
• other public and/ or permitted sources
• interactions with third party service providers (such as but not limited to the Skate-Safe
program, the Sport Integrity Canada Canadian Safe Sport Program, and the Sport
Integrity Canada Canadian Anti-Doping Program in the context of the investigation, as
applicable, and resolution processes as part of the Skate Canada National Safe Sport
Programs, and the management of incidents of injury)
• regulatory and legal authorities, other organizations with whom Skate Canada has
dealings, such as government agencies, publicly available records
Use and Disclosure
Use – How we use information
Skate Canada will not use identifiable confidential information for purposes other than
those identified prior to collection, except with the consent of the individual or as required
by law. “Use” includes processing identifiable information in such a way that it is no longer
identifiable (e.g., aggregated).
Skate Canada will use your identifiable confidential information as set out below in the
section entitled “Identifying Purposes”.
Skate Canada allows only authorized staff to access and use specific data holdings of
confidential information on a “need-to-know” basis, that is, when required to perform their
duties.
Skate Canada sometimes uses the services of third-party service providers only to the
extent required for the provision of such services. By providing confidential information, an
individual consents to the access and/or transfer, storing or processing of their confidential
information to a third-party service provider as applicable. Third-party service providers and
contractors are contractually obligated to ensure data is treated securely and in accordance
with this Privacy Code, to keep the information confidential, to use the information only for
the purpose requested and to destroy the information when it is no longer required.
Disclosure – How and when we disclose information
Skate Canada does not sell, share, or lease confidential information to a third-party service
provider or others for any other purpose from what is disclosed in this Policy without the
consent of the individual.
Skate Canada may disclose or publish non-identifiable (e.g., aggregated) confidential
information only, having used reasonable precautions to ensure that individuals cannot
foreseeably be identified by linking this information with other information.
Skate Canada may disclose identifiable confidential information only when:
• the recipient is the data provider that originally provided the identifiable
confidential information; or
• disclosure is required by law;
• disclosure is required as part of the Skate Canada National Safe Sport program,
including external authorities designated by Skate Canada for reporting and
complaint management (e.g., Skate-Safe program Case Manager, the Sport
Integrity Canada Canadian Safe Sport Program), insurance, injuries management,
external legal counsel, external investigators, etc.);
• disclosure is required to support funding, team selection, etc. For example, with
Sport Canada, ISU, COC, etc.;
• consent has been obtained from the individual(s) concerned.
Identifying Purposes – Specific ways we collect, use, and disclose information
Skate Canada collects, uses, or discloses confidential information for the following purposes,
including but not limited to:
Non-commercial activity:
a. For registration and delivery of Skate Canada programs, services,
competitions, events, and activities
b. For registration and attendance at national and/or international
competitions, as applicable (e.g., ISU, COC, etc.)
c. To establish and authenticate your identity
d. To confirm our discussions with you
e. For quality assurance and monitoring to enhance and maintain member
service quality (e.g., call recording of calls to Member Services)
f. For technical monitoring, coaches training, officials training, sport promotion
and media publications
g. To determine eligibility, age group and appropriate level of competition
h. To determinate registrant and membership demographics and program
wants and needs
i. To provide you with features such as search results for clubs/skating schools
that are near you based on your location
j. To comply as required by law and industry requirements, including
regulatory, Sport Integrity Canada as part of the CADP and CSSP, Sport
Canada, COC, and ISU
k. To comply with obligations with respect to Skate Canada’s Safe Sport
program (for example, external authorities designated by Skate Canada for
Safe Sport to receive reports of alleged, suspected, or actual misconduct who
operate at arm’s length to the organization , external legal counsel, external
investigators, third-party insurance provider) balancing privacy,
confidentiality and fairness regarding reporting and resolution management
l. To comply with obligations with respect to third-party service provider
requirements who assist Skate Canada in servicing members or registrants,
and for this Code sections (for example,, third-party insurance provider(s),
complaints of misconduct, anti-doping program, incidents of injury, etc.)
m. To communicate with you
o sending communications to you by postal mail, email, text message,
telephone, fax, other communication channels such as social media,
including but not limited to:
▪ sending e-news or a newsletter with content related to Skate
Canada programs, events, competitions, fundraising activities,
and other pertinent information, including related ads and
offers (*please note that you can “unsubscribe” to Skate
Canada newsletters by clicking the unsubscribe link at the
bottom of any of the newsletters)
▪ publishing articles, media relations and postings on the
website, displays or posters
▪ awareness nominations, biographies, and media relations
▪ regarding incidents of injury, complaints of misconduct,
complaints of Code of Ethics, general disputes, discipline, and
appeals
▪ regarding immediate temporary suspension of membership or
status as a registrant pending the outcome of the
investigation and disciplinary process
▪ discipline results and long-term suspension list
▪ checking residency status
n. To inform governing bodies (e.g., sections, ISU)) of a registrant and/or
members registration and/or participation with Skate Canada
o. To inform government funders the number and demographic profile of
registrants and/or members
p. To provide the educational tools and resources to pursue the highest levels
of achievement
q. For purposes necessary to provide the safest possible environment, including
advising other persons or organizations, including but not limited to, national
(domestic and/or international, as applicable) and provincial sport
organizations, sections, clubs, skating schools, Sport Canada, Sport Integrity
Canada, SDRCC, ISU, COC, etc., etc., of any decisions, as applicable, rendered
in accordance with the Skate Canada’s National Safe Sport Program and
supporting policies and procedures (e.g., Anti-Doping Policy; Misconduct
Reporting and Resolution Policy and accompanying procedure. This may also
include being advised by an external authority (Skate-Safe Case Manager
and/or Sport Integrity Canada) of the name of a respondent in the case of a
report against them, and that of the complainant if reasonably necessary to
protect that individual or other individuals
r. To support the resolution of general disputes in accordance with the General
Disputes Resolution Policy and accompanying procedure
s. Decisions, including disciplinary measures as may be applicable, resulting
from a complaint of misconduct (which includes those rendered by an
external authority), general dispute, doping violation, and/or the Code of
Ethics are maintained in a database or registry in a manner determined by
Skate Canada, which may include being publicly available. Names of
individuals disciplined may be disclosed as determined by Skate Canada to
the extent necessary to give effect to the discipline/sanction process
t. To understand and better manage our business and development of
programs and services (e.g., develop programs, services, and activities;
market research or analytics of data we hold about you, including with our
business partners)
u. To run our business, including but not limited to meeting tax, legal,
accounting, and regulatory obligations
v. To third-party service providers to perform services on our behalf (including
cloud or hosting service providers)
w. Personalize your experience with us through data analytics or otherwise
including reviewing and analyzing your programs and services, your needs,
wants and satisfaction level. This would be done through de-identifying or
anonymizing your information by removing identifiable information such as
your name, address, date of birth, etc., and such information may be
aggregated with information and used for the purposes outlined
x. To manage property and facilities, ensure environmental compliance and
perform risk management. (e.g., surveillance, monitoring, including video
recording, in and around Skate Canada Ottawa Service Centre to maintain
the safety of our employees, customers and others; protect against illegal
activity, such as theft and vandalism; to ensure the health and safety of
employees; and enhance and maintain client service quality)
y. To protect us or where permitted by law, including protecting our rights or
interests, to ensure the health and safety of individuals, comply with legal
and regulatory obligations, including demands or requests from
governments, regulators, courts, and law enforcement authorities. We may
also collect, use, or share information without consent where required by
law
Commercial Activity:
a. Video recording and photography for promotional use, marketing, and
advertising by Skate Canada
b. Promotion and sale of merchandise
c. Relevant ads and offers on our applications and websites
d. Promotion and offers, including tickets for skating events / competitions
based on your location information and/or in general on our applications and
websites
General:
a. Travel arrangements and administration, including requests for personal
health information, as applicable
b. Medical emergency, reports relating to medical or emergency issues
c. Any and all complaints of misconduct, incidents of injury, ethical concerns,
and doping reports, as per the policies under the Skate Canada National Safe
Sport Program – including but not limited to Misconduct Reporting and
Resolution Policy, Incidents of Injury Reporting and Management Policy, AntiDoping Policy and Code of Ethics
d. Any and all inquiries
Skate Canada collects or may collect confidential information from individuals during the
normal activities and for member and registrant management.
Retention
We apply a general rule of keeping personal information for as long as it is required to fulfil the
purpose for which it was collected. In some circumstances, however, the length of time we
keep your information will vary depending on the program or service and the type of
information we have and our legal obligations to do so. We keep your information as long as
long as is reasonably necessary for member service, legal or reasonable business purposes. For
these reasons, we keep your information beyond the end of your relationship with Skate
Canada. Legal requirements, tax and accounting obligations, complaints of misconduct, and/or
long-term analysis and reporting may necessitate our retaining some or all of your confidential
information for a period of time that is longer than we might otherwise hold it, up to and
including indefinitely in certain limited circumstances.
In certain circumstances, we may also retain personal information for longer periods of time,
which my correspond to a statute of limitations, so that we have an accurate record of your
dealings with us in the event of complaints or challenges.
Minors (Child / Youth)
Skate Canada recognizes the importance of safeguarding the privacy of children. We take our
responsibilities seriously with respect to our minor skaters / athletes of our programs and
services. In addition to the steps that we take to safeguard the privacy and integrity of personal
information of a minor as submitted by parents / legal guardians, we adhere to the following
principles and practices regarding personal information of a minor:
• Skate Canada will not knowingly collect personal information from a minor without
the consent of their parent / guardian
• Skate Canada will not knowingly market to a minor. If we learn that personal
information of a minor was used for marketing purposes, we will take reasonable
measures to delete them from all marketing campaigns
• Skate Canada’s official website is not intended for children under the age of 14. By
using the Skate Canada official website, a minor represents that they are 14 or over
and that their parent or guardian has consented to minor’s use of the Skate Canada
official website.
It is important to note that complaints may be reported by a minor through our Safe Sport
and/or our Skate-Safe process depending on the nature of the situation (e.g., Code of Ethics,
Misconduct Reporting and Resolution Policy and supporting procedure). A minor may be
required to have a parent/guardian or other adult serve as their representative during the
processes as set out in the Code of Ethics and the Misconduct Reporting and Resolution Policy
and supporting procedure. For clarity, a complaint report will not be rejected on the sole basis
that it was submitted by a minor and not by a parent/guardian.
Safeguards – How we protect your information
Skate Canada makes every reasonable effort to protects confidential information with security
safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying,
use, or modification. Skate Canada will protect confidential information that it holds or
transmits regardless of the format in which it is held.
The nature of the safeguards will vary depending on the sensitivity and identifying nature of the
information that has been collected, amount, distribution, and format of the information, and
method of storage.
The methods of protection used include:
• physical measures, such as locked filing cabinets
• organizational measures, such as limiting access on a ‘need to know’ basis
• technological measures, such as the use of passwords, security solutions and
encryption protocols
We regularly access our security measures to ensure that they remain effective and
appropriate. Only employees who have a legitimate business need will be granted access to
your information.
Where is your information stored?
Skate Canada uses cloud-based technology and relies on data centers that are primarily based
in Canada. However, information may be stored and processed in any country where we have
third-party service providers. Skate Canada third-party service providers, with whom we share
information under this Privacy Code, may perform activities outside of Canada. As a result, your
information may be securely used, stored, or accessed in other countries and be subject to the
laws of those countries. By using our programs and services, you consent to the transfer of
confidential/personal information to countries outside of Canada — including the United States
— which may provide for different data protection rules.
In addition, depending on the nature of the information, your information may be stored in
various computer systems or in record storage facilities of Skate Canada or our third-party
service providers.
Your privacy choices
Subject to legal, security, business, or contractual requirements, individuals with a direct
relationship with Skate Canada may withdraw their consent to our collection, use or disclosure
of information at any time by contacting Skate Canada. However, withdrawing your consent
may limit or prevent us from providing or continuing to provide you with specific programs or
services.
To withdraw your consent, you can contact our Skate Canada Privacy Office to obtain the
necessary form as follows:
Email: privacy@skatecanada.ca
Write to:
Skate Canada Privacy Officer
800-333 Preston Street
Ottawa, ON K1S 5N4
Withdrawal of consent does not have a retroactive effect, and your personal information may
continue to be used or disclosed for purposes that have not been withdrawn, or where required
for membership, for security reasons, or as required by law without consent.
In addition, it is important to note that although individuals have the right to withdraw consent
at any time for the purposes as outlined below, a request for withdrawal will not terminate an
ongoing process under the Skate Canada Safe Sport program and/or under the external
authorities of our Skate-Safe program and the Canadian Safe Sport Program.
Marketing
Canada’s Anti-Spam Legislation (CASL) is a Canadian federal law that governs Canada businesses
or organizations using email, text messaging or social networks to promote programs, activities,
events, competitions, and/or services.
Subject to applicable law, from time-to-time Skate Canada may offer you programs or services
of Skate Canada and select third-parties or for other promotional purposes, which may be of
interest to you. Your consent to receive marketing communications is optional and you can
decide to withdraw at any time. However, this will not limit the information provided to you
through communications such as electronic messages on our website or information we send
you that is related to your existing programs or services or is permitted or required by law. We
may also, from time to time, communicate with you to ask whether you wish to update your
marketing preferences to help ensure our records are up-to-date and reflect your current
preferences.
Call recording
Telephone calls with Skate Canada may be recorded and monitored for coaching,
training, quality, and security purposes. If you do not wish to have your telephone call
recorded, you may opt out by ending the call and contacting us through email or postal
mail.
Accuracy – Keeping your information updated
We will make every reasonable effort to keep information in our records as accurate,
complete and up to date as necessary for the purposes for which it is to be used.
However, Skate Canada does not routinely update confidential information, only when
necessary to fulfill the purposes for which the information was collected.
Individuals are responsible for ensuring the confidential information they provide to Skate
Canada is accurate, complete and up to date for the purpose specified, and encouraged to
provide updates to us as changes occur.
To update your confidential information with Skate Canada, contact one of our
representatives through our Member Services division by calling 1 (888) 747-2372
Accessing your information
Upon written request through our Member Services division (a form can be provided), Skate
Canada will inform an individual of the existence, use, and disclosure of his/her identifiable
confidential information and shall be given access to that information subject to the
exclusions set out in PIPEDA (such as, but not limited to, legal exceptions, contains
confidential information, relates to an investigation of a breach of an agreement or law, or
contains information of other individuals that cannot be separated). An individual will be
able to validate his or her personally identifiable information for accuracy and
completeness, and to have it amended as appropriate.
Subject to the legal exceptions or as otherwise permitted by law, upon written request,
Skate Canada will:
• inform an individual whether or not it holds information about the individual
• use its best efforts to indicate from whom this information was collected and to
whom it has been disclosed
As part of the written request, an individual may be required to provide specific details
information to permit Skate Canada to provide an account of the existence, use and
disclosure of the confidential information. In addition, we will need to verify your identify
before searching for or providing you with access to your information. The information will
be used only for this purpose. We may also ask for additional information to confirm the
scope of your request, such as the relevant time period or specific description of the
information you are seeking to access.
Once we receive your written request, verify your identity, and understand the scope of
your request, Skate Canada will respond to an individual’s written request to access their
information within a reasonable time and at minimal or no cost to the individual. If there is
a cost to the individual for access, Skate Canada will provide the individual an estimate of
the cost. Skate Canada will respond to a request not later than 30 days after receipt of a
written request. If for any reason we do not grant access, the individual will be provided
with written reasons.
You can contact Skate Canada Privacy Office as set out below in the section entitled
“Answering your privacy questions or concerns”.
Answering your privacy questions or concerns
If you have any questions, concerns, or complaints about this Privacy Code, our Online Terms of
use or our privacy practices, let us know right away. If you choose to send us an email, don’t
include sensitive information such as credit card or account numbers.
Skate Canada makes readily available to individuals’ specific information about our policies
and practices related to the management of confidential information in order to promote
transparency and explicitness. Individuals will be able to acquire information in a form that
is generally understandable. Skate Canada will provide information on policies and
practices in various ways to registrants, members, coaches, sections, third-party service
providers and the public including by talking to a service representative at our Skate
Canada Ottawa Service Centre, and/or accessing the Skate Canada on-line Internet site.
Step 1: Talk to us
In most cases, a privacy question, concern or complaint is resolved simply by
talking to us about it. You should be able to get swift results by talking to our
Skate Canada Member Service team.
• Talk to a representatives of our Skate Canada Member Services division
by calling 1-(888) 747-2372. Hours of operation are 8:00 am to 4:00 pm
(ET)
• Email us at: info@skatecanada.ca
Step 2: Contact the Skate Canada Privacy Office
If your privacy question, concern, or complaint has not been resolved to your
satisfaction, individuals can contact the Skate Canada Privacy Office:
Email us at: privacy@skatecanada.ca
Write to us at:
Skate Canada Privacy Office
800-333 Preston Street
Ottawa, ON K1S 5N4
Step 3: Escalate to the Office of the Privacy Commissioner of Canada
If the above steps fail to resolve the concern of the individual, individuals may
also consider escalating the matter further by contacting the Office of the
Privacy Commissioner of Canada (OPCC):
Telephone: 1-800-282-1376 (toll-free)
Website: www.priv.gc.ca
Write to: Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Changes to our Privacy Code
We reserve the right to amend this Privacy Code at our discretion and at any time. Our Privacy
Code is reviewed and approved on a regular basis, at minimum every two years or sooner if
there are legislative or regulatory changes, as part of policy review and validation process and
amended as appropriate to ensure individuals are aware of updates to our practices, streamline
practices and to comply with all requirements by law. We encourage regular visits to our
website for updates. We will post any Privacy Code changes on our website privacy page and, if
the changes are significant, we will provide a more prominent notice. Any amendments or
modifications to this Code shall apply automatically, unless otherwise indicated, and come into
effect immediately upon their approval.
Definitions – Terms to help you understand our Privacy Code
Certain terms used herein may not be capitalized; however, for the purposes of this Privacy
Code, to help you understand our Code the following terms herein have the ascribed meanings
as set forth below. In addition, all references to the singular include the plural and vice versa.
affiliate means a section, a club or skating school who has an affiliation with Skate Canada
athlete means any person / skater who competes in the sport of figure skating at the national
and/or international level as defined by Skate Canada
athlete support personnel, as defined by Sport Integrity Canada, means any coach, trainer,
manager, agent, team staff, official, medical, paramedical, parent or any other person working
with, treating or assisting an athlete participating in or preparing for sports competition
Board, pursuant to the Bylaws, means the board of directors of Skate Canada
Bylaws means the bylaws of Skate Canada in force and effect, and as may be amended from
time to time
CADP means the Canadian Anti-Doping Program, as implemented, and managed by Sport
Integrity Canada as revised from time to time and as endorsed and adopted by Skate Canada
COC means the Canadian Olympic Committee, who represents Canada at the International
Olympic Committee and whose purpose is to transform Canada through the power for sport.
This is achieved by leading the achievement of Team Canada’s podium success and advancing
Olympic values across Canada
CSSP means the Canadian Safe Sport Program, through which Sport Integrity Canada receives
and responds to reports of prohibited behaviour under the Universal Code of Conduct to
Prevent and Address Maltreatment in Sport (UCCMS) for designated individuals of national,
federally funded NSOs, including Skate Canada
Case Manager means an appropriately qualified, external, independent, impartial, and
confidential third-party person or organization with no personal ties to Skate Canada, a
club/skating school, or a section retained as an external authority by Skate Canada through
which an individual (with the exception of the Sport Integrity Canada Canadian Safe Sport
Program (CSSP) for program signatories) may pursue the just, fair, and equitable resolution of
complaints of alleged, suspected or actual misconduct reported through the Skate-Safe
program
CEO means Chief Executive Officer of Skate Canada, a Board appointed position
club, pursuant to the Bylaws, means a not-for-profit organization that is operating for the
general purpose of providing Skate Canada programs and is managed by a volunteer board of
directors
code means a set of standards adopted by an organization to establish minimum expectations.
Codes are a set of principles that express the organization’s values and culture. Codes enhance
the organization’s reputation and promote compliance with laws and regulations applicable to
the organization
Commissioner means the Privacy Commissioner appointed under section 53 of the Privacy Act
of Canada
complainant means the individual(s) who has filed a report with the applicable external
authority of an alleged, actual, or suspected violation of the Misconduct Reporting and
Resolution Policy and/or the supporting procedure. The individual filing the report as the
complainant could be (i) the impacted individual who directly experienced the alleged, actual or
suspected misconduct; or (ii) an individual who was not directly impacted by the misconduct
confidential business information means non-public information. It is information about Skate
Canada that has not been disclosed to the public. Confidential business information may
include, but is not limited to, financial information projections, intellectual property,
proprietary processes, proposed transactions, trade secrets, and information that might be
useful to competitors or information about members, registrants, suppliers, or service
providers. All information about, or received from, sponsors should be presumed to be
confidential business information unless the contrary is clear
confidential information comprises individual’s personal information, personal health
information, confidential business information, and any other information about Skate Canada
that has not been generally disclosed to the public. See also “personal information”, “personal
health information” and “confidential business information”
designated athlete support personnel means a coach designated by Skate Canada, integrated
support staff (IST) designated by Skate Canada, Skate Canada Sectional Technical Directors, and
employees of the High Performance division of Skate Canada who work with and support the
national athlete pool (NAP) as part of the High Performance Program
director, pursuant to the Bylaws, means an individual elected or appointed to serve on
the Board
electronic communication means communication using channels including but not limited to
email, the Internet, the intranet, instant messaging, chat, text messaging, facsimile, voice
communications, social media
employee means a person who is hired by Skate Canada on a permanent full-time or short-term
on-going basis, or on a temporary / contract basis for a defined period of time. Employees may
also include certain independent contractors who, while not technically employees within the
meaning of applicable labour or tax laws, have been identified as being applicable in this Code
external authority means an independent external third-party designated and retained by
Skate Canada to receive and resolve reports of misconduct. Specifically for Skate Canada, this
means the Case Manager for the Skate-Safe program and Sport Integrity Canada for the
Canadian Safe Sport Program (CSSP) for program signatories
individual means a natural person whose personal information has been collected, used, and
disclosed and/or retained by Skate Canada, and includes past and current employees, officers,
directors, officers, members of standing committees of the Board, members of operating
committees or working groups of Skate Canada, members, registrants, parents (and guardians),
program signatories, athlete support personnel, event volunteers, designated athlete support
personnel, alumni of Skate Canada, inductees of Skate Canada Hall of Fame, third-party service
providers, event/competition spectators (in-person and/or via on-line streaming services), and,
for the purposes of this Code, sections, and anyone else associated, affiliated, or engaged in
activities, events/competitions, and programs with and/or hosted by Skate Canada but does not
include such legal persons as corporations
IOC means the International Olympic Committee, the entity that is the guardian of the Olympic
Games and the leader of the Olympic Movement and who acts as a catalyst for collaboration
between all Olympic stakeholders, including the athletes, the National Olympic Committees
(the COC for Canada), the International Federations, Organising Committees for the Olympic
Games (the ISU for figure skating and speed skating), the Worldwide Olympic Partners, and
Olympic broadcast partners. It also collaborates with public and private authorities including
the United Nations and other international organisations
ISU means the International Skating Union, which is the exclusive international sport federation
recognized by the International Olympic Committee (IOC) administering sports in the branches
of figure skating and speed skating throughout the world. The ISU is composed of a number of
national associations called ISU Members, who administer ISU sports at the national level and
recognize that all international matters are under the sole jurisdiction and control of the ISU.
ISU is responsible for the ISU Anti-Doping Rules and ISU Anti-Doping Procedures, as compiled in
accordance with the WADA Code, which apply to all skating activities over which the ISU has
jurisdiction
law means any applicable legislation, statutes, regulations, policies, rules, and codes of conduct
established by government, legal or regulatory authority, or by any self-regulatory industry
association by which Skate Canada is or has agreed to be bound
member, pursuant to the Bylaws, means each person that meets the requirements of any of
the three Member classes as defined in Article 3 of the Bylaws and that has been duly admitted
as a member of Skate Canada (which includes coaches, clubs, and skating school)
membership, pursuant to the Bylaws, means the status of being in one of the classes as
outlined in section 3.1 of the Bylaws
minor means a child under the age of majority, as defined in the relevant province or territory
of Canada, as may be amended from time to time. It is the responsibility of the adult to know
the age of a minor
NSO means National Sport Organization, which, as defined by Sport Canada, are the national
governing bodies for a given sport in Canada. The NSO for figure skating in Canada, as
recognized by Sport Canada, is Skate Canada
officer, pursuant to the Bylaws, means the President and such other officers as the Board may
determine by Ordinary Resolution
organization collectively means Skate Canada, unless otherwise noted
permitted or required by law or “legal and regulatory obligations” means actions that we are
permitted or required to do under applicable laws, statutes, regulations or applicable policies,
rules, codes, guidelines, expectations, or requests of any regulator or self-regulatory
organization, or under rules, codes, programs, protocols, guidelines, or principles by which
Skate Canada is or has agreed to be bound
personal information means information about an identifiable individual. This may include,
without limitation, the individual’s name, contact information (residential address, home
and/or cellular telephone number(s), email or other electronic communication address, social
media account name, fax number), login credentials to Skate Canada owned IT resources (as
applicable), digital information (for example, but not limited to information regarding your
devices such as your internet protocol (IP), internet service provider, location, operating system
(MAC OS, iOS, Windows, Android, etc.) and version of browser used to access our website, the
date and time of access to our website, and your activity/usage of our website and
applications), date of birth, gender, government issued identification number (e.g., Social
Insurance Number, passport number), personal health information, criminal record checks,
payroll/employee identification, employment history, personal references,
salary/compensation history, financial status, pension contributions, employee benefit
information, emergency contact information, financial information (such as credit card and
direct deposit banking information). Personal information also includes information that may
relate to the work performance of the individual (performance appraisals), absenteeism, and
training history/evaluations.
For all individuals including sections, personal information includes any injury claim reports,
allegations, investigations or findings of wrongdoing, misconduct or discipline stemming from
(i) a complaint through the internal Ombudsperson process, and/or (ii) a complaint of
misconduct, complaint of a breach of the Code of Ethics and/or an incident of injury report
through the Safe Sport processes (including the Safe Sport division of Skate Canada, and
external authorities as applicable), and/or (iii) a general dispute through Skate Canada.
For registrants, in addition to the information outlined above, personal information also
includes but is not limited to information related to assessment results and program
information for skaters, and qualifications for officials.
For event volunteers, in addition to the information outlined above, personal information may
also include information related to training, education, work experience, volunteer experience
and qualifications, and expense information.
In general, personal information includes any information that could be used to commit identity
theft or other forms of fraud. All information about or received from individuals and/or thirdparty service providers should be presumed to be personal information unless the contrary is
clear.
By virtue of applicable privacy legislation, personal information does not include business
contact information that is collected, used, or disclosed solely for the purpose of
communication or facilitating communication with an individual in relation to their
employment, business, or profession such as the individual’s name, position name or title,
work address, work telephone number, work fax number or work electronic addresses.
This information can be in any form including but not limited to correspondence, paper,
electronic, electronic communications, video or voice recording, photograph, film, sound
recording, videotape, machine-readable record, and any other documentary material,
regardless of physical form or characteristics, and any copy of any of those things.
personal health information, with respect to an individual, as applicable, means identifying
information about an individual in oral or recorded form, if the information:
• relates to the physical or mental health of the individual, including information that
consists of the health history of the individual’s family
• relates to the provision of health care to the individual, including the identification of a
person as a provider of health care to the individual
• is collected incidentally to the provision of health services to the individual (such as the
individual’s payments or eligibility for health care, eligibility for coverage for health care,
the individual’s entitlement to payment for an insurance claim for an injury
• is the individual’s health number
• identifies an individual’s substitute decision-maker
policies and procedures mean all applicable manuals, guidelines, handbooks, job aids, forms,
policies, procedures, codes, protocols, and standards as implemented by Skate Canada,
including those that relate to how Skate Canada wishes to manage its business in accordance
with its business strategy and risk appetite
President, pursuant to Bylaws, means the chair of the Board and officer of Skate Canada
Privacy Officer means a Board appointed position accountable for overseeing privacy
governance, all activities related to the implementation of, and adherence to, the
organization’s privacy policies and to ensure operational procedures are in compliance with
relevant privacy laws
program signatory(ies) means designated persons named on an annual basis by Skate Canada
(NSO) as participants (as defined by the Universal Code of Conduct to Prevent and Address
Maltreatment in Sport (UCCMS)) to the Sport Integrity Canada complaint management process
through the Canadian Safe Sport Program (CSSP)
registrant, pursuant to the Bylaws, means (i) an individual who is registered by a club or skating
school with Skate Canada and who is subject to all applicable rules, regulations, and policies of
Skate Canada but who is not a member; and (ii) an individual who is engaged in any activity
provided, sponsored, supported, sanctioned, or recognized by Skate Canada and registered
directly with Skate Canada but who is not a member
respondent means an individual who is alleged to have engaged in one or more action, conduct
and/or behaviour of misconduct and thereby to have violated the Misconduct Reporting and
Resolution Policy and/or the supporting procedure
section, pursuant to the Bylaws, means an organization incorporated or organized in a
particular province or territory (and in some cases, a combination thereof) strategically aligned
with Skate Canada, that may receive funds from provincial or territorial Governmental
Authorities and be subject to applicable sport recognition programs and transfer payment
arrangements. Each Section is held to the governance and operating requirements of their
respective province and / or territory(ies) and is responsible for skating in their respective
jurisdictions
Skate-Safe is a program that is part of the Skate Canada National Safe Sport Program through
which a Case Manager, as a designated external authority, receives and responds to reports of
misconduct under the Misconduct Reporting and Resolution Policy for individuals (other than
those individuals designated as program signatories)
skater means (i) a person who is registered at a club or skating school with Skate Canada and
who is subject to all applicable rules, regulations, and policies of Skate Canada but who is not a
member; and (ii) a person who is engaged in any activity provided, sponsored, supported,
sanctioned, or recognized by Skate Canada and registered directly with Skate Canada but who is
not a member
skating school, pursuant to the Bylaws, means an organization other than a club that is
operating for the general purpose of providing Skate Canada skating programs
social media means interactive digital-media technologies that facilitate the creation and
sharing of information, ideas, and other forms of expression via virtual communities and
networks
Sport Canada means the division of the Government of Canada that provides leadership and
funding to help ensure a strong Canadian sport system which enables Canadians to progress
from early sport experiences to high performance excellence, including the Athlete Assistance
Program (AAP)
SDRCC means the Sport Dispute Resolution Centre of Canada, and is the entity created through
the Government of Canada’s Physical Activity and Sport Act with the mandate to provide to the
sport community a national alternative dispute resolution service for sport disputes; and
expertise and assistance regarding alternative dispute resolution
Sport Integrity Canada, which is an independent, national, not-for-profit organization. The core
mandate of Sport Integrity Canada is to be a regulator for sport at the national level
administering the Canadian Anti-Doping Program (CADP), the Canadian Safe Sport Program
(CSSP), and the Canadian Program to Prevent Competition Manipulation (CPPCM) [Note -
Previously known as the Canadian Centre for Ethics in Sport (CCES)]
third-party service provider means an individual or corporate entity having a business
relationship of any kind with Skate Canada (such as, sponsors, partners, suppliers, service
providers, consultants, event volunteers, etc.)
UCCMS means the Universal Code of Conduct to Prevent and Address Maltreatment in Sport, in
force and effect and as may be amended from time, and serves as the core document that sets
harmonized rules to be adopted by sport organizations that receive funding from the
Government of Canada to advance a respectful sport culture that delivers quality, inclusive,
accessible, welcoming, and safe sport experiences
WADA means the World Anti-Doping Agency, which is an international independent agency
composed and funded equally by the sport movement and governments of the world. Its key
activities include scientific research, education, development of anti-doping capacities, and
monitoring of the World Anti-Doping Code (WADA Code) – the document harmonizing antidoping policies in all sports and all countries – which includes the possible Anti-Doping Rule
Violations (ADRV)
WADA Code means the WADA Anti-Doping Code, which is a core document, as revised from
time to time, that provides the framework for anti-doping policies, rules, and regulations within
sport organizations and among public authorities, and is designed to harmonize anti-doping
policies and ensure the standards are the same for all athletes
we, us, our means Skate Canada, unless noted otherwise
Related Documents
Legislation
Personal Information Protection and Electronic Documents Act
Breach of Security Safeguards Regulations
Canada Anti-Spam Legislation
Skate Canada Policies / Procedures
Code of Ethics
Online Terms of Use (Skate Canada website)
National Safe Sport Program, including
Misconduct Reporting and Resolution Policy and procedure thereunder
General Dispute Reporting and Resolution Policy and procedure thereunder
Incident of Injury Reporting and Management Policy and procedure thereunder
Concussion Management Policy, and protocol thereunder
Forms
Personal Information Access Request Form
Withdrawal of Consent Request Form
Code Template Origination Date: September 10, 2017
Code Template Last Revised Date: August 10, 2022
29
Appendix: Notice of Collection
By signing below, you acknowledge that you have read, understood and agree to comply
with the Skate Canada Privacy Code as provided and hereby request, and consent to, the
registering of myself with Skate Canada.
By signing below and registering with a club or skating school and allowing yourself to be
registered nationally with Skate Canada and submitting this form, you indicate your
acceptance of all terms and conditions associated with the Skate Canada Privacy Code
and expressly provide your consent to the collection, use and disclosure of your
confidential information to register you with Skate Canada in any capacity including,
without limitation, as a Skate Canada registrant, coach or in connection with your
affiliation with a skating club or skating school and to administer various services, such as
Skate Canada programs, services and events, contact you to provide you with relevant
offers regarding events and competitions, all as set forth in the Privacy Code. In addition,
through the submission of form, you expressly consent to the sharing or exchange of your
confidential information with Skate Canada affiliates, which includes your local skating
club or skating school or provincial association or section, and with service providers.
Individual
Printed Name (First and Last): _____________________________________________
Signature: _____________________________________________
Date (mm/dd/yyyy): _____________________________________________
If the individual is a minor (under the age of majority as defined in the relevant
province or territory of Canada that the individual resides), the next section must be
completed.
Parent / Guardian for an individual who is a minor
A parent or guardian’s signature must be obtained if the individual is a minor at the time of
signing this acknowledgement. This parent or guardian’s signature can be in addition to or
in place of the skater’s signature.
I am the parent/guardian of __________________________________________, who was born on
__________________ and is therefore a minor at the time of signing this acknowledgment
with Skate Canada.
By signing below and registering my minor child with a club or skating school and allowing
your minor child to be registered nationally with Skate Canada and submitting this form,
you indicate your acceptance of all terms and conditions associated with the Skate
Canada Privacy Code and expressly provide your consent to the collection, use and
disclosure of your minor child’s confidential information to register your minor child with
Skate Canada in any capacity including, without limitation, as a Skate Canada registrant,
coach or in connection with your affiliation with a skating club or skating school and to
administer various services, such as Skate Canada programs, services and events, contact
you to provide you with relevant offers regarding events and competitions, all as set forth in
the Privacy Code. In addition, through the submission of form, you expressly consent to
the sharing or exchange of your confidential information with Skate Canada affiliates,
which includes your local skating club or skating school or provincial association or
section, and with service providers.
Printed Name (First and Last): ________________________________________________
Signature of Parent / Guardian: ________________________________________________
Date (mm/dd/yyyy): _______________________________________________