Privacy Policy of the Ontario Camps Association (OCA)

Last Amended: March 2021

The OCA (also referred to as “we”, “our” and “us” in this policy), is a voluntary, non-profit organization whose members are camps (which in this policy include outdoor education centres) , individuals and organizations and agencies devoted to maintaining high standards for organized camping and to sharing information and ideas for maintaining those standards. Since 1932, the OCA has played an important leadership role in promoting and encouraging children and youth camping in Ontario through a variety of activities. The OCA provides education such as training seminars for camp staff and organizes an Annual Conference that brings together camping professionals from across Canada and other countries.  The OCA operates an accreditation program through which we review the operations of member camps against over 650 standards that we have developed or adopted. The OCA raises public and governmental awareness of the value of camping and assists individuals to find a camp through means such as our website, annual Camping Guide and camp fairs. The OCA also advocates on behalf of the public to the camping community, responding to concerns raised by parents and campers.

  1. This Policy. This policy applies to “personal information”, by which we mean information about an identifiable individual, excluding information about an individual in his or her professional capacity, such as that used to communicate about an individual’s employment, business or profession.

The OCA used the 10 principles of fair information practices as the basis for this policy.  Although most (if not all) of the OCA’s collection, use and disclosure of personal information is not subject to privacy law, we have chosen to manage personal information in accordance with and to make our privacy practices known through this policy.  Our decision reflects our respect for the individuals who trust us with their personal information and our belief in the importance of letting them know what we do with that information.

The OCA may revise this Policy from time to time, posting the last revised date at the top of the policy.  Please take the time to read the policy if we have revised it since the last time you did so. By providing us with your personal information or using our website after a revision, you are consenting to the management of your personal information in accordance with the revised policy.

  1. Our Collection & Use of Personal Information. The OCA limits the personal information we collect to that required to:
  • register individual members, maintain their membership records and provide them with membership benefits;
  • register individuals for educational programs and provide such programs;
  • provide our other services and activities, and/or
  • create and distribute our Camp Guide.

The OCA may also use personal information it collects or that is publicly available to:

  • investigate what we reasonably believe to be a contravention of the law, or the breach of an agreement including to collect a debt;
  • address an emergency that threatens the life, health or security of an individual;
  • comply with a legal requirement; and/or
  • carry out due diligence on a proposed reorganization and/or complete a reorganization of our business.

For the most part, we collect personal information directly from the individual to whom it relates (or their legal representative).

  1. Information we collect automatically when you visit our website

We use electronic means, such as cookies, to collect information automatically from users of our website.

Read about the kinds of information that are collected when you visit our website, and how that information can be used. If you have any questions about this section, please contact Alex Houston.

a. Cookies

Cookies are small text files stored on your computer that allow us to remember information about you. You can disable cookies through your browser by following the instructions usually located within the “Help,” “Tools” or “Edit” menus in your browser. Please note that disabling a cookie or category of cookies does not delete the cookie from your browser unless manually completed through your browser function.

We use cookies for the following purposes:

    • Strictly necessary cookies: We use cookies that are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but that will cause some parts of the site not to work. These cookies do not store any personal information.
    • Performance cookies (Google Analytics): Performance cookies (we use Google Analytics) allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.

Google Analytics collects information about the pages you visit, your IP address (which implies location), and other browsing-related data. Google may set and read cookies in your browser. You can learn more by visiting this information page from Google: “How Google uses information from sites or apps that use our services”.

Google provides a tool for opting out of Google Analytics in case you don’t want to participate.

    • Marketing cookies: Google also provides us with aggregate data about our visitors’ demographics and interests using cookies, Device Advertising IDs, and the Google Signals feature (see below). This helps us understand our audience better — which helps us provide better content and to advertise more effectively.

The Google Signals feature of Google Analytics provides aggregated, anonymized insights into visitor behaviour across different devices. Google associates visitor information from our sites with information from signed-in Google account users who have consented to this kind of association for ad personalization. Google may use information like user location, search history, YouTube history, and data from sites that partner with Google in the process. (We only see the aggregated, anonymized insights.) You can see (and delete) your Google Activity data on Google’s My Activity page.

You can opt-out of seeing personalized Google ads using your Google account settings. (There may also be similar settings for ads on mobile apps.) You can also control some of the information Google uses to show you ads.

There are other tools you can use to opt-out of the collection and use of information for ad targeting. For example, visit the Digital Advertising Alliance of Canada Consumer Choice website for more information and one such tool.

b. Google ReCAPTCHA

Sometimes we use the Google reCAPTCHA service to avoid spam form submissions. The service works by collecting hardware and software information, such as device and application data, and sending it to Google for analysis. The information collected in connection with your use of the service is used for improving reCAPTCHA and for general security purposes. It is not used for personalized advertising by Google.

  1. Our Disclosure of Personal Information & Use of Third Party Service Providers. The OCA may disclose personal information to:
  • communicate with an individual’s next of kin or authorized representative in the event of an injury, illness or death;
  • comply with a subpoena, court order or other mandated production or disclosure;
  • notify law enforcement or a government agency, regulator or other authority of a possible violation of a law or an individual’s rights, and/or assist in the investigation or gathering of information about same;
  • investigate a breach of an agreement including collecting a debt;
  • detect, suppress or prevent fraud;
  • report, investigate and/or prevent financial abuse;
  • address an emergency that threatens the life, health or security of an individual; and/or
  • comply with the law.

The OCA may disclose personal information of board and committee members to other members to facilitate the work of the board and committees.

The OCA retains third parties to assist in providing membership, registration and other services including those related to our educational programs. Some of our service providers operate from the United States (U.S.).  Where required for their services, we provide or permit our third party service providers access to personal information. We require our third party service providers to manage personal information in a manner that is consistent with this policy. Notwithstanding any contractual obligations that the OCA imposes, once transferred or otherwise made available to service providers operating in the U.S., personal information is subject to U.S. law, including a lawful order for production or disclosure to the U.S. Government, its agencies including law enforcement, and courts.

  1. Our Retention of Personal Information

We may retain personal information after an individual’s file becomes inactive, unless otherwise required by law. Files become inactive on termination of membership with the OCA or for non-members, on termination of the educational program or activity for which the individual registered.

  1. Safeguards & Risks

The OCA uses reasonable organizational, physical and technological means to protect personal information against theft, loss and unauthorized access, use, disclosure and destruction. The OCA has designated its Executive Director as its privacy officer, with responsibility for overseeing our compliance with this policy. The OCA limits access to personal information to those of our employees, volunteers, committee members and directors who need the information for their OCA work or activities.  The OCA requires committee members, directors and volunteers to return personal information once they no longer require it for the applicable authorized purpose. The OCA shreds personal information before disposing of it to prevent unauthorized access.  The OCA restricts access to work areas in which it maintains or uses personal information files to employees. Access to OCA computers is password protected and the OCA uses other tools including firewalls to protect the personal information it holds in electronic format.

Please note that despite our efforts and actions, no safeguards are totally effective in protecting information in electronic databases or while in transit. Accordingly, the OCA cannot guarantee that personal information we collect, use, disclose or retain will be secure from malicious activities, including cyberattacks. Any such activity could result in the use of personal information for fraudulent or other improper purposes and a recommendation that the affected individuals replace identification numbers or documents, give notice to applicable authorities or service providers, or take other action. 

  1. Access & Correction, Inquires & Complaints. You may request a copy of your personal information in OCA records by writing to our Executive Director as set out below. Upon verification of your identity (to prevent our release of personal information to an unauthorized individual), we will generally respond to your request within 60 days or less. If you demonstrate to our satisfaction that your personal information in our file is inaccurate, we will correct the information. The OCA requests that you notify us of any change to your personal information in our file (change of address or legal representative, for example).

Please also direct any inquiries, concerns or complaints about the OCA’s personal information management or management of your personal information to the Executive Director in writing.  We will investigate and report our findings on any complaint.

  1. Contact information. Joy Levy, Executive Director at joy@ontariocamps.ca.