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VANOC General External Privacy Policy

I. BACKGROUND

The Vancouver Organizing Committee for the 2010 Olympic and Paralympic Winter Games (“VANOC”) respects your privacy and seeks to protect your personal information. The protection of personal information is subject to the provisions of the BC Personal Information Protection Act ( “PIPA”), and may be subject to comparable provincial or federal privacy law in Canada.

The Privacy Policy explains how VANOC collects, uses and discloses the personal information that may be provided to VANOC in the course of VANOC completing its mandate. VANOC has a website Privacy Policy and separate Privacy Policies protecting the personal information of its employees and volunteers.

“Personal Information” means information about an identifiable individual, but does not include the name, position, name or title, business telephone number, business address, business e-mail or business fax number of the individual. It also does not include the work product information of the individual.

The Privacy Policy outlines the principles and practices VANOC will follow in order to protect your personal information. VANOC will ensure the accuracy, confidentiality and security of your personal information, and as well will follow the legal requirements to allow you to request access to and correction of your personal information.

II. SCOPE

This Privacy Policy applies to VANOC. VANOC reserves the right to amend this Privacy Policy from time to time to ensure that it maintains current with changing laws and regulations.

This Privacy Policy does not impose any limits on the collection, use or disclosure of personal information that:

Is covered by one of the exceptions in Sections 12, 15 and 18 of PIPA to collection, use and disclosure of personal information without consent;
Was collected prior to January 1, 2004, where the personal information is used and disclosed in order to fulfill the same reasonable purpose for which it was collected;

This Privacy Policy does not apply to personal information if the Freedom of Information and Protection of Privacy Act applies or the federal Access to Information and the Privacy Act applies to the personal information.

III. DEFINITIONS

“VANOC” means the Vancouver Organizing Committee for the 2010 Olympic and Paralympic Winter Games.

“Games” means the 2010 Olympic Winter Games, the 2010 Paralympic Winter Games.

“participants” means the individuals attending the Games to participate in the Games, including, but not limited to athletes, judges, referees, trainers, coaches, media, and members of the Olympic family.

“collection” means the act of gathering, acquiring or obtaining personal information from any source, including third parties, by any means.

“consent” means voluntary agreement to the collection, use or disclosure of personal information for reasonable purposes, which are made known to the individual. Consent can be express or implied. Express consent can be oral or written, but is always unequivocal. Implied consent is consent that can be reasonably inferred from the action or inaction of an individual.

“disclosure” means making personal information available outside VANOC.

“use” means the treatment, handling, management and retention of personal information within VANOC.

“personal information” means information about an identifiable individual excluding the individual’s contact information or their work product information.

“contact information” means information to enable an individual, at a place of business, to be contacted and includes the name, position name or title, business telephone number, business address, business e-mail or business fax number of the individual.

“work product information” means information prepared or collected by an individual or group of individuals as part of the individual’s or group’s responsibilities or activities related to the individual’s or group’s employment or business, but does not include personal information about an individual who did not prepare or collect the personal information.

IV. ACCOUNTABILITY

VANOC is accountable for the protection of the personal information under its control and has designated as its Privacy Officer

Chief Privacy Officer
Vancouver Organizing Committee for the 2010 Olympic and Paralympic Winter Games
3585 Gravely Street
Vancouver, BC
V5K 5J5

778-328-1023

Privacy_Officer@vancouver2010.com

VANOC has developed Privacy Policies and procedures in addition to this Privacy Policy, in order to protect your personal information. VANOC will make every effort to ensure that all VANOC team members having access to or responsibility for personal information are given levels of training and awareness programs on essential privacy policies and practices appropriate for their role.

COLLECTING PERSONAL INFORMATION

Unless the purposes for collecting the personal information are obvious, and you voluntarily provide your personal information for that obvious purpose, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

The mandate of VANOC is to plan, organize, finance and stage the Games. During the course of carrying out that mandate, VANOC may collect your personal information. We will only collect your information by fair and lawful means and where it is necessary to fulfill the following purposes:

To fulfill the Olympic identity and accreditation card program;
To build venues for the Games;
To provide transportation to participants and spectators at the Games;
To organize and stage competitive events at the Games;
To provide security for the Games;
To provide accommodation for participants of the Games;
To carry out VANOC’s mandate of sustainable development;
To provide sponsorship opportunities for the Games;
To provide medical services including health services and doping control during the Games;
To comply with VANOC’s contractual obligations under the Host City Contract and the Multi-Party Agreement;
To provide cultural programs for the Games;
To facilitate the Olympic flame and torch relay program;
To provide performances for the Games;
To provide medals and commemorative medals;
To ensure legal protection over Olympic symbols and tradenames;
To carry on a distribution system for admission tickets and merchandise, and to provide tickets and merchandise for the Games;
To carry out advertising;
To implement VANOC’s marketing programs;
To meet statutory and legal requirements

V. CONSENT

VANOC will obtain consent to collect, use or disclose personal information except where as noted in this Privacy Policy, we are authorized or required to do so without consent.

Consent can be provided orally, in writing, or electronically, or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious to a reasonable person and you voluntarily provide your personal information for that purpose.

Consent may also be implied where you are given notice and a reasonable opportunity to opt out of your personal information being used or disclosed and you do not opt out.

Subject to the personal information being necessary to provide the service or product or where the withdrawal of consent would frustrate the performance of a legal obligation, you can withhold or withdraw your consent from VANOC to use your personal information for particular purposes. If you choose to withdraw your consent to the collection, use and disclosure of your personal information, VANOC will advise you of the consequences of the withdrawal.

VI. USING AND DISCLOSING PERSONAL INFORMATION

VANOC will only use or disclose personal information where it is necessary to fulfill the purposes for which it was collected, or for a purpose reasonably related to those purposes.

As part of fulfilling the purposes for which the information was collected, as set out earlier in this Policy, VANOC will be disclosing personal information to third parties, including the RCMP (for security and accreditation purposes), the International Olympic Committee (IOC), the International Paralympic Committee (IPC), the Canadian Olympic Committee (COC), the Canadian Paralympic Committee (CPC) and other national Olympic committees of other countries, provincial and federal government bodies associated with VANOC in organizing the Games, to volunteer organizations, for example to administer the Home Stay Program, and to other third party contractors and outsourced agencies who will be contracted to VANOC to assist VANOC to carry out the Games. VANOC may disclose your personal information outside of Canada. To the extent that we enter into contracts or other arrangements with third parties, which involve the transfer of personal information, we will ensure that the third party enters into appropriate covenants with us to provide the same level of protection over your personal information that VANOC provides.

In some cases, VANOC may seek your consent for the use and disclosure of your information after it has been collected, but before it is used or disclosed, for example, where VANOC wants to use your personal information for a purpose not previously identified to you.

VANOC does not, as a condition of supplying products or services to you, require you to consent to collection, use or disclosure of personal information beyond what is necessary to provide the product or service.

VANOC does not attempt to obtain consent for collecting, using or disclosing your personal information by providing false or misleading information regarding the purposes for the collection, use or disclosure of your personal information or by using deceptive or misleading practices. VANOC will not sell, rent or lease your personal information to third parties unless we have obtained your explicit consent to do so.

VII. RETAINING PERSONAL INFORMATION

If VANOC uses your personal information to make a decision that directly affects you, VANOC will retain that personal information for at least one year, so that you have a reasonable opportunity to request access to it.

Subject to the above, VANOC will retain your personal information only as long as necessary to fulfill the identified purposes, or to fulfill a legal or business purpose.

VANOC will develop guidelines and implement procedures to govern the destruction or anonymization of personal information which is no longer to be retained.

If VANOC transfers personal information to any other organization at the completion of the Games, VANOC will take appropriate steps to ensure that appropriate guidelines and procedures are in place to govern the security of the personal information, and that guidelines and procedures are implemented for the retention of the personal information including minimum and maximum retention periods.

VIII. ENSURING ACCURACY OF PERSONAL INFORMATION

VANOC will make reasonable efforts to ensure that your personal information is accurate and complete if it will likely use it to make a decision that directly affects you, or if VANOC is likely to disclose it to another organization.

VANOC will not routinely update personal information. To the extent that you believe that the personal information you provided to VANOC may no longer be accurate or complete, you may advise VANOC to update its records. A request to update your personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. Your request to update or correct your personal information should be forwarded to VANOC’s Chief Privacy Officer:

In writing:
Chief Privacy Officer
Vancouver Organizing Committee for the 2010 Olympic and Paralympic Winter Games
3585 Gravely Street
Vancouver, BC
V5K 5J5

By telephone: 778-328-1023

By e-mail: Privacy_Officer@vancouver2010.com

If you successfully demonstrate to VANOC that your personal information is inaccurate or incomplete, VANOC will correct the personal information as required. VANOC will also send the corrected information to any other organization to which VANOC disclosed your personal information in the prior year.

If VANOC determines that no correction is required to be made, we will nevertheless note your request for the correction and annotate your file accordingly.

IX. SECURING PERSONAL INFORMATION

VANOC has implemented security safeguards to protect personal information regardless of the format in which it is held, against loss or theft, unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. VANOC uses safeguards which are appropriate to the sensitivity of the information.

VANOC uses the following security measures to ensure that your personal information is being appropriately protected:

Physical measures such as locked filing cabinets, drawers and offices, and restricted access to offices;
Organizational measures such as limiting access on a “need to know” basis and requiring service providers to provide comparable security measures; and
Technological measures such as the use of user id’s, passwords, encryption, and internet firewalls, and anti-virus software.

When disposing of or anonymizing personal information, VANOC will use appropriate security measures as set out in its Personal Information Records Retention and Destruction Procedures to ensure that your personal information is not inappropriately used.

VANOC will, on a regular basis, review and update security policies and controls as technology changes to ensure ongoing personal information security.

VANOC has developed a Personal Information Security Policy, which sets out more specific provisions that VANOC will follow in order to ensure that your personal information is kept secure at all times.

X. PROVIDING ACCESS TO PERSONAL INFORMATION

You have a right to access the personal information that is held by VANOC. This right is subject to exceptions which are set out in PIPA.

In order to obtain access to your personal information, you must make a written request that provides sufficient detail to allow VANOC to identify the personal information being sought.

You may be required to provide sufficient personal information to identify yourself in order to enable VANOC to verify your identity before providing you with your personal information. You may also be asked more specific questions about the type and amount of personal information that you are seeking.

VANOC will make the information available within 30 working days. If VANOC is seeking an extension in order to respond to your request, VANOC will provide you with written notice of the extension.

VANOC may charge you a minimal fee for access to your personal information. In the event that VANOC intends to charge a fee, we will give you a written estimate of the fee and may require you to pay a deposit for all or part of the fee, prior to providing you with access to your information.

In responding to your access request, VANOC will provide you with your personal information that is under its control, information about the ways in which the personal information has been and is being used by VANOC, and the names of the individuals and organizations to whom the personal information has been disclosed by VANOC.

If VANOC refuses in whole or in part to provide you access to your personal information, we will notify you in writing. The notification will include providing you the reasons for the refusal, in particular, the exceptions in PIPA upon which we are relying, and will advise you of any recourse which is available to you as a result of VANOC’s refusal.

XI. CHALLENGING COMPLIANCE: QUESTIONS AND COMPLAINTS

At any time you may seek information about VANOC’s privacy policies and practices by contacting VANOC’s privacy officer at
In writing:

Chief Privacy Officer
Vancouver Organizing Committee for the 2010 Olympic and Paralympic Winter Games
3585 Gravely Street
Vancouver, BC
V5K 5J5

By telephone: 778-328-1023

By e-mail: Privacy_Officer@vancouver2010.com

If you have a question or a complaint about VANOC’s privacy practices, you should direct that complaint, concern or question in writing to the Privacy Officer designated under this Privacy Policy. VANOC has implemented Inquiry/Complaint Handling Procedures to receive and respond to your inquiry or concern or complaint about the policies and practices relating to the handling of your personal information.

If you provide a written complaint, concern or question to VANOC, VANOC will advise you of the complaint procedure. VANOC will also conduct a review into your concern or complaint. If VANOC concludes that a complaint is justified, VANOC will take appropriate measures which may include amending its policies and practices. VANOC will inform you of the outcome of its review regarding your question or complaint.

If you are not satisfied with the resolution proposed by VANOC, you will be advised as to the appropriate procedure to elevate your concern.

This version has been in effect since June 21, 2006