Camp Simpresca Policy on Privacy of Camper Personal Information

Camp Simpresca will comply with: (i) Personal Information Protection and
Electronic Documents Act ("PIPEDA"), a federally enacted act which protects
personal information that is collected, used or disclosed; (ii) other acts which
protect personal information and privacy; and (iii) any future provincial
protection of privacy legislation as it relates to the rights of campers. For the
purposes of this policy, personal information means information about an
identifiable individual, but does not include the name, title or business
address or telephone number of an employee of an organization. Any
reference to a camper within this policy is in reference to personal information
and not business information ("Camper").

Camp Simpresca has implemented policies and procedures to give effect to
the principles, including:

  1. Implementing procedures to protect personal information.
  2. Establishing procedures to receive and respond to complaints and
    inquiries in connection with the collection, use and disclosure of
    personal information by Camp Simpresca.
  3. Training staff and communicating information to staff about Camp
    Simpresca’s policies and procedures.
  4. Developing information to explain Camp Simpresca’s policies and
    procedures to Campers and/or a Camper’s guardian.

These principles are explained in more detail below:

1. Accountability

Camp Simpresca is responsible for the personal information under its control
and has designated a Privacy Officer to be accountable for Camp Simpresca's
compliance with PIPEDA.

2. Identifying Purpose

Camp Simpresca will identify and document the purposes for which it collects
personal information. Only personal information that is necessary for those
identified purposes will be collected. If Camp Simpresca intends to use the
personal information that has been collected for a new purpose, this new
purpose will be identified and consent for such new purpose will be obtained
from the Camper or in the case of a minor, a Camper’s guardian to which the
personal information relates prior to using such personal information.
Camp Simpresca shall only collect, use and disclose personal information
about Campers for the following purposes:

a. To assist Camp Simpresca in the collection of fees and other charges owing with respect to Camp Simpresca.
b. To assist Camp Simpresca in the assignment of cabin placements.
c. To assist Camp Simpresca in the treatment of known medical
conditions or unknown medical conditions that may arise during their
time while in the care of Camp Simpresca.
d. To assist Camp Simpresca in communication with users of the Camp
for the purpose of promoting the use of the Camp (including the use of
photographs on our website and brochures).

Camp Simpresca does not collect and use personal information about
Campers for the following purposes:

a. To sell Camper lists to third party agencies.
Camper or in the case of a minor, a Camper’s guardian inquiries regarding the
purposes for the collection, use and disclosure of personal information will be
addressed by Camp Simpresca or referred to the Privacy Officer.

3. Consent

The knowledge and consent of Campers, or in the case of a minor, a Camper’s
guardian, is required for the collection, use or disclosure of personal
information, except when inappropriate, including where permitted or
required by law. Camp Simpresca will seek consent for the collection of
personal information at the time of collection, wherever possible. Camp
Simpresca will make a reasonable effort to ensure that Campers, or in the
case of a minor, a Camper’s guardian are advised of the purposes for which
the personal information being collected will be used, and will state the
purposes in a manner that will allow Campers, or in the case of a minor, a
Camper’s guardian to reasonably understand how their personal information
will be used or disclosed by Camp Simpresca.

Consent may be obtained in a variety of ways, for example, through an
application form, orally by telephone or by electronic media (e-mail),
depending on the circumstances and the type of personal information being
collected, and in particular, on the sensitivity of the personal information.
The reasonable expectations of Campers, or in the case of a minor, a
Camper’s guardian will be considered when obtaining consent. For example,
where Campers, or in the case of a minor, a Camper’s guardian provide their
names and addresses for mailing and billing purposes, they should reasonably
expect that this information would also be used for sending out Camper
Satisfaction Surveys, where the choice to respond is the Campers’, or in the
case of a minor, a Camper’s guardian.

In certain circumstances, personal information can be collected, used or
disclosed without the knowledge or consent of the Camper, or in the case of a
minor, a Camper’s guardian. For example, legal, medical or security reasons
may make it impossible or impractical to seek consent. Seeking consent may be impossible or inappropriate when there is an emergency threatening the
Camper's life, health or security, or where the Camper is a minor, seriously ill
or mentally incapacitated.

Although information may be publicly available, Camp Simpresca will treat
this in accordance with PIPEDA principles. Moreover, Camp Simpresca may
provide personal information to its lawyers, advisors, agents and/or third
parties to comply with a subpoena, warrant or other court order, to a
government institution requesting the information upon lawful authority, or as
may be otherwise required by law. In all cases, proper internal authorization
for disclosure procedures will be followed.

Copies of the Camp Simpresca Privacy Policy will be published on the Camp
Simpresca Website at www.simpresca.net and also made available in Camp
Simpresca published brochures.

Consent may be withdrawn by a Camper, or in the case of a minor, a
Camper’s guardian by providing reasonable notice to Camp Simpresca to the
Privacy Officer. Camp Simpresca will inform the Camper, or in the case of a
minor, a Camper’s guardian of any implications of such a withdrawal.

4. Limiting Collection

The collection of personal information will be limited to that which is
appropriate in the circumstances.

The Camp Simpresca Website does not use or capture cookies; a technology
that installs a small amount of information on a visitor’s computer to permit
the Website to recognize future visits from that computer. The only
information collected through the Website, other than that provided by the
Camper, or in the case of a minor, a Camper’s guardian voluntarily to initiate
a transaction, is browser information used only to solve errors on processing
transactions, when these occur.

5. Limiting Use, Disclosure & Retention

Camp Simpresca will not use or disclose personal information for purposes
other than those for which it was collected, except with the consent of the
Camper, or in the case of a minor, a Camper’s guardian or as required by law.
Personal information cannot be used or passed on in a manner inconsistent
with the identified purpose.

Certain Camp Simpresca employees may be given access to a Camper's
personal information collected by Camp Simpresca in so far as their duties
require access for the purposes outlined.

Personal information that has been used to make a decision about a Camper
will be retained in accordance with the Camp Simpresca document retention
guidelines. Personal information that is no longer required will be destroyed,
erased or made anonymous. Camp Simpresca retains personal information of a Camper only for as long as it is required for Camp Simpresca's business
purposes or as required by federal and provincial laws.

6. Accuracy

Camp Simpresca will take reasonable steps to ensure that the personal
information under its control is as accurate, complete and up-to-date as is
necessary for the purposes for which it is to be used.

Camp Simpresca will not routinely update personal information, unless such a
process is necessary to fulfill the purposes for which the information was
collected. Camp Simpresca will take reasonable steps to ensure that personal
information that is used on an ongoing basis is accurate and up-to-date.

Access to a Camper's personal information on record with Camp Simpresca
may be requested by that Camper, or in the case of a minor, a Camper’s
guardian in order to review and amend their personal information, as
appropriate. To access your personal information, refer to "How to contact
us".

7. Safeguards

Camp Simpresca will take reasonable steps to protect personal information
through security safeguards appropriate to the sensitivity of the personal
information. Employees of Camp Simpresca who have access to personal
information will be made aware of the importance of maintaining the
confidentiality of personal information. Security safeguards protect against
loss or theft, as well as unauthorized access, disclosure, copying, use or
modification.

8. Openness

Camp Simpresca will make readily available to Campers, or in the case of a
minor, a Camper’s guardian specific information about its policy and
guidelines relating to the management of personal information.

Camp Simpresca will be open about its policy and procedure with respect to
the management of personal information, and Campers, or in the case of a
minor, a Camper’s guardian will be able to acquire information about these
policies easily and in a form that is generally understandable. This policy and
any related information is available at all times on Camp Simpresca web site,
www.simpresca.net under Privacy.

9. Individual Access

Camp Simpresca will inform a Camper, or in the case of a minor, a Camper’s
guardian of the existence, use and disclosure of their personal information
(including to third parties) and will provide access to that personal
information, upon written request. Camp Simpresca will assist a Camper, or in the case of a minor, a Camper’s guardian in the preparation of a request
for access when such a Camper requests assistance. Camp Simpresca will
inform the Camper, or in the case of a minor, a Camper’s guardian whether or
not it holds personal information about them, and will indicate the source of
any such personal information, when possible.

There may, however be situations in which Camp Simpresca will not be able
to provide access to all the personal information that it holds about a Camper,
although these situations will be limited and specific, and permitted or
required by law. For example, Camp Simpresca will not be able to provide
access to a Camper's personal information where giving such access would
likely reveal personal information about a third party, unless that third party's
personal information can be severed from the Camper's personal information.
If Camp Simpresca refuses a request for access, the Camper, or in the case of
a minor, a Camper’s guardian will be informed in writing of the refusal, setting
out the reasons for the refusal and informing the Camper, or in the case of a
minor, a Camper’s guardian of their recourse.

Camp Simpresca will require that Campers, or in the case of a minor, a
Camper’s guardian requesting access to their personal information will provide
the appropriate verification information required to obtain access to such
personal information. This information will not be used for any purpose other
than to permit Camp Simpresca to provide an account of the existence, use
and disclosure of the Campers' personal information.

Camp Simpresca will be as specific as possible in providing an account of third
parties to which personal information has been disclosed, and will provide a
list of organizations to which personal information may have been disclosed
when it is not possible to provide a list of the organizations to which specific
personal information have actually been disclosed.

Camp Simpresca will respond to a Camper's, or in the case of a minor, a
Camper’s guardian request to access their personal information within a
reasonable time, and not later than 30 days after receipt of the request.
Camp Simpresca may be entitled to a 30 day extension to respond, in limited
circumstances, in which case the Camper, or in the case of a minor, a
Camper’s guardian will be notified of such an extension, the new time limit,
the reasons for extending the time limit, and their right to make a complaint
to the Privacy Commissioner with respect to the extension.

Camp Simpresca may charge a reasonable fee for responding to a request.
This fee will be determined based on the request and any request specific
administrative or system costs that may be incurred, and will advise the
Camper, or in the case of a minor, a Camper’s guardian in advance, of the
approximate cost. The personal information requested would be provided in a
form that is generally understandable.

A Camper, or in the case of a minor, a Camper’s guardian will be able to
challenge the accuracy and completeness of the personal information and
have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or
addition of information.

10. Challenging Compliance

A Camper, or in the case of a minor, a Camper’s guardian will be able to
address a challenge concerning compliance with the above principles to the
Privacy Officer. Camp Simpresca will handle all complaints or inquiries about
the policies and procedures relating to the handling of personal information in
line with the processes that are in place.

Camp Simpresca will inform Campers, or in the case of a minor, a Camper’s
guardian who make inquiries or lodge complaints of the existence of the
relevant complaint procedures. Camp Simpresca will investigate all
complaints, and if a complaint is justified, Camp Simpresca will take
appropriate measures, including amending policies and procedures.

How to contact us

If you have any questions or comments about this Privacy Policy or you feel
that your concerns or complaints have not been resolved to your satisfaction,
please contact us

• by calling our Registrar at 1-705-355-0115
• in writing to the Privacy Officer, Camp Simpresca, 5107 Penetanguishene, Ontario, L9M 2G3