1. Purpose

The Hamilton Amateur Radio Club (“HARC” or “the Club”) respects the privacy of its members, prospective members, volunteers, donors, event participants, and other individuals who provide personal information to the Club.

This Privacy Policy establishes how HARC collects, uses, discloses, safeguards, retains, and disposes of personal information.

As a not-for-profit organization, not all HARC activities are necessarily subject to the Personal Information Protection and Electronic Documents Act (“PIPEDA”). Nevertheless, HARC has chosen to follow recognized Canadian fair information principles, including the principles reflected in PIPEDA, as a standard for the responsible management of personal information. Where applicable privacy legislation imposes additional requirements, HARC will comply with those requirements.

2. Accountability

The HARC Board of Directors is responsible for overseeing the Club’s privacy practices and for personal information under the Club’s control.

The Board is responsible for ensuring that appropriate policies, procedures, and safeguards are maintained for the collection, use, disclosure, retention, and protection of personal information.

Privacy-related inquiries, requests for access or correction, and complaints may be directed to any member of the Board of Directors. The Board may designate one or more directors or other authorized individuals to respond to a particular privacy matter or to administer specific aspects of the Club’s privacy practices.

All directors, officers, volunteers, committee members, and other persons who are provided access to personal information on behalf of HARC are expected to comply with this Policy and to protect the confidentiality of that information.

3. Personal Information We Collect

HARC collects only personal information that is reasonably necessary for legitimate Club purposes.

Depending upon the individual’s relationship with HARC, this information may include:

  • name;
  • amateur radio call sign;
  • mailing or residential address;
  • postal code;
  • telephone number;
  • email address;
  • Radio Amateurs of Canada (“RAC”) membership status or membership number;
  • HARC membership type and status;
  • membership application and renewal information;
  • membership payment and transaction records;
  • participation in Club activities, committees, programs, elections, or volunteer activities;
  • emergency or other information voluntarily supplied for a particular Club activity; and
  • correspondence or other information an individual voluntarily provides to the Club.

HARC will not collect personal information merely because it may be useful at some future time. Information collected must have a reasonable and identified Club purpose.

4. Purposes for Collection and Use

HARC may collect and use personal information for purposes including:

  • processing membership applications and renewals;
  • maintaining the Club’s membership records;
  • determining membership categories, eligibility, and applicable membership fees;
  • communicating with members concerning their membership;
  • providing notices of meetings, elections, nominations, Annual General Meetings, and other governance matters;
  • distributing newsletters, bulletins, announcements, and information about Club activities;
  • organizing Club meetings, programs, contests, training, social activities, Field Day, hamfests, and other events;
  • administering volunteer activities and committees;
  • administering insurance programs and confirming insurance eligibility;
  • communicating with RAC where required for programs or services in which HARC participates;
  • processing and maintaining records of membership payments and other transactions;
  • maintaining appropriate historical, financial, corporate, and governance records;
  • responding to inquiries or requests;
  • protecting the Club, its members, property, systems, and activities;
  • complying with applicable laws and legal requirements; and
  • other purposes that are identified to the individual at or before the time the information is collected.

If HARC wishes to use personal information for a materially different purpose that was not previously identified, the Club will obtain additional consent where appropriate.

5. Consent

HARC will obtain meaningful consent for the collection, use, and disclosure of personal information where consent is appropriate.

Consent may be express or implied depending upon the nature and sensitivity of the information, the circumstances in which it is collected, and the reasonable expectations of the individual.

For example, submitting a membership application or renewal constitutes consent for HARC to use the information supplied to administer that membership for the purposes identified in this Policy and in the applicable privacy disclosure.

Individuals may withdraw consent to optional uses of their personal information by contacting HARC. Withdrawal of consent does not apply retroactively and may be subject to legal, contractual, insurance, governance, or other legitimate requirements.

Where particular information is reasonably necessary to provide a membership, service, insurance coverage, or Club activity, withdrawing consent to its necessary use may prevent HARC from continuing to provide that service or benefit. HARC will explain the consequences where appropriate.

6. Limiting Collection

HARC will limit the collection of personal information to information reasonably necessary for identified Club purposes.

The Club will periodically review the information requested on membership applications, renewal forms, event registrations, and other forms to ensure that unnecessary personal information is not being collected.

Whenever practical, HARC will avoid collecting sensitive personal information that is not necessary for Club activities.

7. Disclosure of Personal Information

HARC does not sell or lease its membership lists or members’ personal contact information.

Personal information will not be disclosed to third parties except:

  • with the individual’s consent;
  • for a purpose identified when the information was collected;
  • to a service provider acting on behalf of HARC where reasonably necessary to provide a Club service;
  • to RAC or another organization where necessary to administer an insurance program, affiliation, benefit, or service in which HARC participates;
  • where disclosure is reasonably necessary to protect HARC, its members, or others;
  • where permitted or required by law; or
  • as otherwise authorized by the individual.

Where HARC uses third-party service providers to process, store, transmit, or otherwise handle personal information on its behalf, HARC will take reasonable steps to ensure that the information is handled appropriately and used only for the intended purpose.

8. Radio Amateurs of Canada and Insurance

HARC participates in programs administered or supported by Radio Amateurs of Canada (“RAC”), including group liability insurance.

Where required to administer these programs, HARC may provide RAC with limited membership information, which may include a member’s name, amateur radio call sign, RAC membership status or membership number, or other information reasonably required for the applicable program.

HARC will limit information provided to RAC to information reasonably necessary for the applicable purpose.

9. Member Communications and Email

Members who provide an email address authorize HARC to use that address for communications reasonably related to their membership and Club activities.

These communications may include:

  • membership and renewal information;
  • meeting notices;
  • AGM notices;
  • nominations and election information;
  • governance and other official Club notices;
  • insurance-related information;
  • event information;
  • newsletters;
  • bulletins; and
  • other Club announcements.

Members may unsubscribe from optional newsletters and general Club communications.

An unsubscribe request from optional communications does not prevent HARC from sending messages reasonably necessary to administer the individual’s membership or to fulfill the Club’s legal, corporate, governance, safety, insurance, or similar obligations.

When sending messages to multiple recipients, HARC will take reasonable measures to prevent members’ email addresses from being unnecessarily disclosed to other recipients.

Where an electronic message is subject to Canada’s anti-spam legislation (“CASL”), HARC will comply with applicable consent, identification, and unsubscribe requirements.

10. Member Directories and Membership Lists

HARC will not publish or distribute a membership directory containing members’ personal contact information unless the affected members have been informed of the purpose and appropriate consent has been obtained.

Access to internal membership lists shall be limited to directors, officers, volunteers, or others who reasonably require the information to perform authorized Club duties.

Membership information obtained through a Club position or volunteer role must not be used for personal, commercial, political, or other unauthorized purposes.

A person who ceases to hold a Club position requiring access to membership information must cease using that information and return or securely delete Club membership records in their possession, subject to any records that must be retained by HARC.

11. Photographs and Club Activities

HARC may take photographs or recordings at Club meetings, events, and activities for legitimate Club purposes, including newsletters, historical records, and promotion of Club activities.

Where an individual is the principal subject of a photograph, recording, interview, profile, or similar material, HARC will obtain consent where reasonably appropriate.

Individuals who do not wish to be prominently photographed or identified in Club publications are encouraged to advise the event organizer or a member of the Board.

HARC will exercise particular care before publishing a photograph together with personal information that is not already publicly associated with the individual.

12. Accuracy and Correction

HARC will make reasonable efforts to ensure that personal information used to administer membership and Club activities is accurate, complete, and current.

Members are encouraged to notify the Club when their contact or membership information changes.

An individual may request correction of inaccurate or incomplete personal information held by HARC. Where appropriate, HARC will correct the information as soon as reasonably practical.

13. Safeguards

HARC will use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the personal information in its possession.

Safeguards may include:

  • restricting access to membership information to authorized persons;
  • using passwords and appropriate access controls for electronic systems;
  • limiting copies and exports of membership databases;
  • using reasonable security measures for online membership and administrative systems;
  • securely storing paper records containing personal information;
  • using appropriate methods when transmitting personal information;
  • ensuring directors and volunteers understand their privacy responsibilities; and
  • securely disposing of records when they are no longer required.

No electronic system can be guaranteed to be completely secure. HARC will periodically review its safeguards and make reasonable improvements where appropriate.

14. Third-Party and Online Services

HARC may use third-party services to operate its website, membership system, email distribution, payment processing, document storage, event registration, or other Club functions.

Information processed through these services may be stored or processed outside Ontario or outside Canada and may therefore be subject to the laws of the jurisdiction in which it is stored or processed.

HARC will take reasonable steps when selecting and configuring third-party services to protect personal information and limit their access and use to legitimate Club purposes.

Where a third-party payment processor is used, HARC should not retain complete credit or debit card information unless there is a legitimate need and appropriate security measures are in place.

15. Website Information

HARC’s website may automatically collect limited technical information ordinarily generated when a person visits a website, such as IP address, browser information, date and time of access, referring pages, and pages visited.

HARC may use this information for website operation, security, troubleshooting, and aggregate usage statistics.

If HARC uses cookies, analytics services, embedded third-party content, or other technologies that collect personal information beyond what is reasonably necessary to operate the website, HARC will provide appropriate notice and obtain consent where required.

The HARC website may contain links to third-party websites. HARC is not responsible for the privacy practices of websites that it does not operate.

16. Retention and Destruction

HARC will retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected and to satisfy applicable legal, financial, insurance, governance, historical, or recordkeeping requirements.

HARC may retain limited records concerning former members where reasonably necessary for legitimate Club purposes, including financial records, corporate records, insurance records, membership history, awards, election records, meeting minutes, or other historical records.

Personal information that is no longer reasonably required will be securely destroyed, deleted, or anonymized.

The Board may establish specific retention periods for different categories of Club records.

17. Privacy Incidents and Breaches

Any director, officer, volunteer, or other person acting on behalf of HARC who becomes aware of the loss, theft, unauthorized access, unauthorized disclosure, or suspected compromise of personal information under HARC’s control shall promptly notify the President.

HARC will investigate suspected privacy incidents and take reasonable steps to:

  • contain the incident;
  • determine what information was affected;
  • identify and address the cause;
  • reduce the risk of further unauthorized access or disclosure;
  • recover or securely delete improperly disclosed information where reasonably possible;
  • document the incident and the Club’s response; and
  • notify affected individuals, regulators, insurers, law enforcement, or others where required by law or reasonably appropriate considering the circumstances and potential risk of harm.

18. Access to Personal Information

An individual may request access to personal information about them that is under HARC’s control.

Requests should be directed to the President or Board of Directors and should provide sufficient information to allow HARC to identify the records being requested.

HARC will respond within a reasonable period and may take reasonable steps to verify the identity of the person making the request before releasing personal information.

Access may be limited where disclosure would reveal another person’s personal information, information protected by legal privilege, confidential Club information concerning another individual, or where disclosure is otherwise prohibited or inappropriate under applicable law.

Where access cannot be provided, HARC will explain the reason where reasonably possible.

19. Privacy Complaints and Questions

Questions or concerns regarding this Policy or HARC’s handling of personal information should first be directed to the Club’s President or Board of Directors.

The President or Board of Directors will investigate legitimate privacy complaints and respond within a reasonable period.

Where a complaint identifies a deficiency in HARC’s privacy practices, the Club will take reasonable steps to correct the deficiency.

Nothing in this Policy limits an individual’s right to make a complaint to an appropriate regulatory authority where applicable.

20. Directors, Officers, and Volunteers

Directors, officers, committee members, and volunteers may be given access to personal information only where reasonably necessary to perform their Club responsibilities.

Anyone receiving such access must:

  • use the information only for authorized Club purposes;
  • maintain its confidentiality;
  • not provide membership information to unauthorized persons;
  • use reasonable safeguards to protect the information;
  • immediately report suspected loss or unauthorized disclosure; and
  • return or securely delete personal information when access is no longer required.

Access to HARC systems and records should be removed promptly when a director, officer, or volunteer no longer requires that access.

21. Changes to this Policy

The Board of Directors may amend this Privacy Policy from time to time to reflect changes in Club operations, technology, legal requirements, or accepted privacy practices.

Material changes affecting how members’ personal information is collected, used, or disclosed will be communicated to members where reasonably appropriate.

The current version of this Policy will be made available on the HARC website.

22. Contact

Questions, requests for access or correction, complaints, or other privacy concerns may be directed to:

HARC Board of Directors
Hamilton Amateur Radio Club
Website: www.hamiltonarc.com