Who Is STARS?
In this Policy, STARS refers to the Shock Trauma Air Rescue Society (“STARS Society”) and the Shock Trauma Air Rescue Service Foundation (“STARS Foundation”) (each of which are non-profit and registered charitable organizations) as well as STARS Aviation Canada Inc (“STARS Aviation”) (which is a wholly owned subsidiary of the STARS Society).
Does this Policy Apply to Me?
It is STARS' policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and an individual's right to privacy are different from one jurisdiction to another. The provisions of the various federal and provincial privacy legislation generally only apply to the commercial activities undertaken by non-profit organizations.
This Policy has a limited scope and application and the rights and obligations contained in this Policy may not be available to all individuals or in all jurisdictions. This Policy covers only those of STARS activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable. If you are unsure if or how this Policy applies to you, please contact our Privacy Officer for more information.
What is Personal Information?
What Personal Information does STARS collect?
We collect and maintain different types of personal information in respect of our volunteers, including the personal information contained in:
- resumes and/or applications;
- references and interview notes;
- photographs and video;
- mandatory policy acknowledgement sign-off sheets;
- police and other background check information;
- occupational health & safety information;
- WCB and other insurance information, as applicable;
- regulatory requirement and licensure information;
- awards and recognition program information;
- travel information, including credit card and passport information, if required;
- your beneficiary, your designated next of kin, and emergency contact information.
In addition to the examples listed above, we may collect identification information such as name, home address, telephone, personal email address, date of birth, volunteer identification number and marital status, and any other information necessary to STARS' operations, which is voluntarily disclosed in the course of your relationship with STARS.
As a general rule, STARS collects personal information directly from you. In most circumstances where the personal information that STARS collects about you is held by a third party, we will endeavor to obtain your permission before we seek out this information from such sources. Such permission may be given directly by you or implied from your actions.
From time to time, we may utilize the services of third parties in carrying out our activities and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
Why does STARS Collect Personal Information?
The personal information collected is used and disclosed for the purpose of enabling STARS to undertake its activities, including establishing, managing or terminating (collectively, "administering") your volunteer relationship with STARS. Such uses include:
determining eligibility for a volunteer role, including the verification of references, police checks, qualifications and licensures;
- processing certain claims (e.g., workers’ compensation, insurance claims, etc.)
- establishing training and/or development requirements;
- conducting performance reviews and determining performance requirements;
- assessing qualifications for a particular job or task;
- establishing a contact point in the event of an emergency (such as next of kin);
- complying with applicable laws and regulatory requirements
- compiling directories;
- ensuring the security of organization-held information; and
- such other purposes as are reasonably required by STARS.
The work product of STARS' volunteers, whether in paper record, computer files, or in any other storage format, belong to STARS, and that work product, whether it is stored electronically, on paper or in any other format, and the tools used to generate that work product, are always subject to review and monitoring by STARS.
In the course of conducting our activities, we may monitor volunteer activities and STARS property. For example, some of STARS’ locations are equipped with surveillance cameras. These cameras are generally in high risk areas. Where and when in use, surveillance cameras are there for the protection of volunteers and third parties and to protect against theft, vandalism and damage to STARS' goods and property.
Pursuant to our Usage of Information Technology and Communication Resources Policy, STARS has the option to monitor all volunteer computer and e-mail use. This is not to suggest that you will in fact be monitored or your actions subject to constant surveillance. It is meant to bring to attention the fact that such monitoring may occur and may result in the collection of personal information from volunteers (e.g., through their use of STARS’ resources). When using STARS’ equipment or resources, volunteers should not have any expectation of privacy with respect to their use of such equipment or resources.
How do we Use and Disclose Your Personal Information?
We may use or disclose your personal information:
- for the purposes described in this Policy; or
- for any additional purposes that STARS advises you of and where, if your consent is required by law, we have obtained your consent in respect of the use or disclosure of your personal information.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When and to whom does STARS Disclose Your Personal Information?
We may share your personal information with those of our employees, volunteers, contractors, consultants and other parties who require such information to assist us with administering your volunteer relationship with STARS, including: third parties that provide services to us or on our behalf; third parties that collaborate with STARS in the provision of services to you; and, third parties whose services we use to perform our services. For example, your information may be disclosed to a direct mail processing company to mail to you the latest STARS newsletter. Further, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of STARS' regular reporting activities;
- to protect the rights and property of STARS;
- during emergency situations or where necessary to protect the safety of a person or group of persons;
- where the personal information is publicly available; or
- with your consent where such consent is required by law.
Notification and Consent
Except in respect of certain of our aviation operations, Canada's privacy legislation does not generally require STARS to obtain your consent for the collection, use or disclosure of personal information for the purpose of administering your volunteer relationship. In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to STARS collecting, using and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time such personal information was provided to us).
Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
How is Your Personal Information Protected?
STARS endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
How Long is Your Personal Information Retained?
Except as otherwise permitted or required by applicable law or regulatory requirements, STARS endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting or record retention requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your relationship with STARS, please keep us informed of such changes.
In some circumstances, we may not agree with your request to change your personal information and may instead append an alternative text to the record in question.
Access to Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact the office of our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
Inquiries or Concerns?
We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner applicable for your jurisdiction.