Bidding opens November 14th to November 19th
The Rotary Club of Sarnia Personal Information Protection Policy

Protecting the privacy and confidentiality of personal information is an important aspect of the way that the Rotary Club of Sarnia (RCoS) conducts its business. Collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is also important to the club's daily operations.

RCoS strives to protect and respect the personal information of its customers, employees, business partners, and others who engage with the club.

RCoS' collection and use of personal information is governed by the Personal Information Protection and Electronic Documents Act, 2001, c. 5 (the .PIPEDA.), which grants rights concerning the privacy of user's personal information. This Privacy Policy applies to all personal information within The Rotary Club of Sarnia's possession and control.

In compliance with PIPEDA, this Privacy Policy complies with Schedule 1 of PIPEDA, and its 10 principles of fair information practices. The Government of Ontario's overall Privacy Statement can be found at


Personal information is defined as any identifying information about an individual or group of individuals.

Contact information refers to information that would enable an individual to be contacted at a place of business, including business address, business telephone number, name(s) of owner(s), executive officer(s), and director(s), job titles, business registration numbers, and financial status. Contact information is treated and handled with the same level of confidentiality, privacy, and respect as personal information.

Privacy Officer is the designated individual responsible for ensuring that RCoS complies with this Privacy Policy and PIPEDA.


RCoS's Privacy Policy is based upon and applies the 10 principles of PIPEDA:

  1. Accountability

RCoS is responsible for the personal information collected within its control, and has designated the Club President as the Privacy Officer, to whom questions about this Privacy Policy can be directed to. The Privacy Officer can be reached at the RCoS office:

Michael Hurry, Club President
1210 Michigan Ave., Sarnia ON N7S 6M7

To fulfil RCoS' responsibility for personal information under its control, the following policies and practices to have been implemented, including:

a) Implementing procedures to protect personal information, as discussed in section 7 below on 'Safeguards';

b) Developing information to explain the organization's policies and procedures, as discussed in section 8 below on .Openness.; establishing procedures to receive and respond to complaints and inquiries, as discussed in sections 9 and 10 below on .Individual Access. and .Recourse.; and

c) Training RCoS employees and communicating information about RCoS' policies and practices to employees.

  1. Identifying the Purpose

RCoS will endeavor to identify the purpose of why personal information is needed and utilized, before or when any personal information is collected. RCoS will also document the purposes for which personal information is collected.

RCoS collects and uses personal information solely for the purpose of conducting business and developing an understanding of its members and users. RCoS hereby asserts that personal information will only be used for the following purposes:

  1. To carry out transactions, such as auction registration, process payments for auction items
  2. To send information about upcoming online and/or live TV auctions
  3. To provide user feedback and the opportunity to respond to a questions from users

RCoS obtains personal information directly from the individual to whom the information belongs. Individuals are entitled to know how RCoS uses personal information and this organization will limit the use of any personal information collected only to what is needed for those stated purposes.

RCoS does not sell, distribute, or otherwise disclose personal information or contact lists to third parties. However, limited disclosure may be required as part of RCoS fulfilling its stated business duties and day-to-day operations. This may include consultants, suppliers, or business partners of the Rotary Club of Sarnia, but only with the understanding that these parties obey and abide by the Canadian Anti-Spam Legislation (CASL), to the extent necessary for fulfilling their own business duties and day-to-day operations.

In addition, RCoS may provide links to other websites managed by third parties/may permit third parties to offer users subscriptions/registration-based services through its website. As such, RCoS cannot control or be responsible for the actions or policies of such third parties.

By becoming a member or customer, requesting information, or registering for events or purchasing courses offered, users are giving RCoS permission to contact them at the address, email and/or phone number provided, to the extent permitted by other applicable laws, including CASL. In compliance with CASL, RCoS offers individuals with the option to opt-in, opt-out or modify how they receive various electronic communications, and at any time.

Access to personal information will be authorized only for the employees and other agents of RCoS who require the information to perform their job duties, and to those otherwise authorized by law.

  1. Consent

Consent occurs and is obtained when an individual signs an application or other form containing personal information, thereby authorizing RCoS to collect, use, and disclose the individual’s personal information for the purposes stated on the form or in the Appropriate Use section of this policy. This includes new member registrations, member renewals, course enrolments, awards and events registration.

Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the member voluntarily provides personal information for that purpose.

Consent may also be implied where a member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the member does not opt-out.

Consent (also known as .opting out.) can also be withdrawn at any time by contacting RCoS' Privacy Officer or the individual specifically identified. An individual's decision to withhold or withdraw their consent to certain uses of personal information may restrict RCoS' ability to provide a particular service or product.

Exceptions to consent occur when RCoS may collect, use or disclose personal information in the following, limited circumstances:

  • When the collection, use or disclosure of personal information is permitted or required by law;
  • In an emergency that threatens an individual’s life, health, or personal security;
  • When the personal information is available from a public source (e.g., a telephone directory or the Internet);
  • When RCoS requires legal advice from a lawyer;
  • For the purposes of collecting a debt;
  • To protect ourselves from fraud;
  • To investigate an anticipated breach of an agreement or a contravention of law
  1. Limiting Collection

RCoS limits the collection of personal information for the aforementioned purposes and use, and does not collect personal information indiscriminately. Both the amount and the type of information RCoS collects is limited to that which is necessary to fulfil the general purposes.

RCoS monitors website traffic patterns, site usage, and related digital information (social media, email) in order to optimize RCoS' online services. This information may also be used for statistical analysis and may be provided to third parties, but this does not include any identifiable personal information.

  1. Limiting Use, Disclosure and Retention

RCoS does not use or disclose personal information for purposes other than those for which it was originally collected, except with user consent or as otherwise permitted by law. In addition, RCoS retains personal information only as long as necessary for the fulfilment of those purposes.

RCoS also does not disclose email addresses on published platforms, such as the online member directory or printed member directory. It only discloses the same type of company information that would appear in standard marketing practices.

  1. Accuracy

RCoS strives to keep accurate records of personal information, and asks for and applies updates to information, as users disclose new updates.

  1. Safeguards

RCoS has developed the following safeguards to help ensure compliance to PIPEDA and its policies:

  • Protect personal information against loss or theft by only storing information on a secured server, which is password protected, encrypted, and backed up.
  • Safeguard the information from unauthorized access, disclosure, copying, use or modification, and protect personal information, regardless of the format in which it is held, by training staff to adhere to this Privacy Policy.
  1. Openness

RCoS will inform members, employees, and other users of the policies and practices in place for the responsible management of personal information.

This information will be easy to understand and accessible by including

    • The name and contact information of the Privacy Officer, who is responsible for RCoS' compliance to this Privacy Policy (see section 1)
    • A description of the purpose for collecting personal information, and its use
    • Personal information that is made available to related organizations
  1. Individual Access

RCoS respects the individual's right to access their personal information within RCoS' collection.

Upon receipt of written request, RCoS will provide an account of personal information about the individual and show how it has been used and any other related organizations that have their information. RCoS will grant access to users. personal information at minimal or no cost to the individual. RCoS will correct or amend any personal information in order to keep records most accurate and up-to-date, and send amended information to any third parties who have access to the information, where appropriate. RCoS will also endeavour to make the information understandable (i.e. explain acronyms and codes).

In certain situations, RCoS may not be able to provide access to all the personal information held about a user. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. The reasons for denying access will be provided to the individual upon request, along with any recourse that you may have under PIPEDA.

  1. Recourse

The Privacy Officer is responsible for RCoS' compliance to this Privacy Act and PIPEDA.

Members can direct any complaints or concerns concerning RCoS' compliance to this Privacy Act in writing to the Privacy Officer, as identified in Principle 1. RCoS reserves the right to seek legal advice where appropriate.

The Privacy Officer will investigate all complaints received and take appropriate measures to correct information handling practices and policies. If the Privacy Officer is unable to resolve the concern, members can also write to the Information and Privacy Commissioner of Ontario.