Privacy Policy

At the Canadian Snowbird Association (the CSA), the trust and confidence of our members stand at the core of our mission to advocate, protect and represent the interests of Canadian travellers. Recognizing the unique nature of our members’ lifestyle, we are committed to upholding the highest standards of privacy and data protection.

The purpose of this privacy policy is to demonstrate the CSA’s unwavering commitment to protecting the privacy and personal information of our members and others (collectively “members”) who may access our services and/or those of our benefit partners. This policy outlines our practices regarding the collection, use, access and safeguarding of personal information, ensuring that our operations align with Personal Information Protection and Electronic Documents Act (PIPEDA) standards and reflect our dedication to transparency and accountability in all member interactions.

This policy applies to all personal information collected, maintained and processed by the CSA, encompassing, among other things, data obtained through membership enrolment, delivery of member benefits and member communications, digital or otherwise.

At the CSA, we ensure that our methods of collecting personal information are clear and straightforward, fostering an environment in which members can easily grasp and agree to the data collection process and the data being collected.

We gather personal information through various means to effectively serve our members in accordance with our privacy policy, those of approved third-party providers, and the respective terms and conditions of our member benefits. This includes personal interactions at our office or during special events in Canada and the U.S., enrolment in any member benefit (and the facilitation of same, whether by the CSA or an approved third-party provider), digital communications such as email exchanges and online submissions (Bird Talk, renewals, etc.), and hard-copy/paper transactions, which may include regular mail, couriers and or facsimiles.

Personal information is collected from third parties only when applicable to the benefits or services in which the respective member is enrolled.

The CSA collects a range of personal information that is tailored to our members’ needs and the services being provided. This may include:

• Contact details:
  • Members’ names, addresses, telephone numbers, email addresses, etc.
    International details may also be collected.
  • Dates and locations of hosted member events.
  • Travel dates.
  • Emergency contact details.
• Demographic information:
  • Gender, date of birth, personal interests, medical information (as you may provide though the online Health Record).
• Financial and other information (only where applicable):
  • Credit cards details (tokenized/masked and destroyed on receipt), membership type/cost, Special Action Fund donations, enrolment in member benefits (such as the CSA AutoClub or SCE), vehicle particulars, Canadian and U.S. bank account particulars, VOID cheques, bank statements, Drivers’ Licences, ID verifications from approved Canadian credit bureaus (NOT credit checks nor financial information/transactions).

In almost all instances, introductions to members are member driven. Consequently, any interactions initiated by the CSA, particularly via email, are deemed to be made with express permission, in accordance with Canada’s Anti-Spam Law (CASL), rather than being implied.

Each aspect of information collection is guided by our commitment to respect your privacy and adhere to PIPEDA’s principles, ensuring that personal information is handled responsibly, securely, and only for the purposes for which it is collected.

The primary purpose behind collecting personal information is to provide and improve the benefits and services which we offer. This includes:

• Facilitating membership management and administration.
• Delivering a personalized and efficient service experience.
• Collecting personal information required for the enrolment in, and or use of, certain member benefits, such as submissions of Bird Talk or Canada Club events, mailing the CSANews magazine or other documentation, medical information for the online Health Record, or banking and identification for SCE ID verification, etc.
• Advocating (in aggregate, not individually) on behalf of members with governmental and commercial entities.
• Informing members about issues, opportunities, offers and updates that may affect their travel plans and rights as Canadian travellers, such as changing legislation and or relevant travel advisories related to the snowbird lifestyle.
• Identity verification – SCE participants only:
  • WHY: Clients of ALL currency exchange services in Canada, including those offered through banks and programs such as Snowbird Currency Exchange (SCE) program, are required by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) to provide proof of identity for the purpose of anti-money laundering and anti-terrorist financing supervision. For more information, visit FINTRAC for access to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
  • HOW: Verification is conducted via FINTRAC-approved, third-party service providers, such as Equifax. Verification is determined by confirming the existence of a Canadian credit file only. Confirming identity in this manner is not a review of your credit or your credit score.
  • NOTE: For greater clarity, credit ratings/scores, financial transactions and other financial information are NOT accessible or available to SCE, NOR are participants’ credit ratings/scores impacted in any way.
  • NOTE: Individual SCE participants’ transactions are NOT submitted to the Canada Revenue Agency, to any credit bureau NOR to FINTRAC. Only transactions that are greater than $10,000 in cash and/or deemed suspicious would be submitted. SCE does not accept cash transactions and participation in the program is for personal use only.

The CSA is dedicated to ensuring the privacy and security of our members’ personal information, in strict adherence with our privacy policy and in compliance with CASL, PIPEDA and regulations set forth by FINTRAC under Anti-Money Laundering (AML) legislation.

Our policy governs the careful disclosure of personal information to approved third parties, which is driven by necessity to facilitate benefits and services in which members are enrolled. This includes interactions with financial institutions, legal advisors and other service providers essential to the administration and delivery of member benefits such as SCE, CSANews, CSA Auto/Home Insurance Plan, Medipac Travel Insurance and this website – www.snowbirds.org – and any functions contained herein. Any disclosure of information is made with the obligation that such third parties are committed to protecting your information with a level of security that meets or exceeds our standards; is used for only the intended purposes; and is accessible only to those with a legitimate reason in the performance of their duties.

It’s important to note that, in certain circumstances, we may be required to disclose information without express consent from our members. This includes, but is not limited to, compliance with court orders, legal obligations or situations in which disclosure is necessary to prevent fraud or to ensure compliance with AML or other regulations. In such instances, we commit to disclosing only the information that is strictly necessary under the circumstances.

We obtain implied consent for these disclosures through your enrolment with our services, under the premise that such interactions necessitate the sharing of information to fulfil the service or benefit requested. However, we uphold the principle of transparency and give our members the right to withdraw consent at any time, provided such withdrawal is communicated to us in writing.

In every aspect of our operations, the CSA remains steadfast in our commitment to safeguarding your privacy, ensuring that any disclosure of personal information is justified, secure and in alignment with the highest standards of privacy legislation. This section outlines a clear and respectful approach to information collection, aligning with the overarching commitment to privacy and transparency set forth in the initial statement.

The CSA treats the security of your personal information with utmost seriousness. We ensure that all personal data, whether recorded in physical documents or stored electronically, are kept secure within our premises in Canada and, where applicable, at the locations of our trusted partner organizations.

Our electronic data storage systems are monitored 24/7 with robust hardware and software firewalls to guard against unauthorized access and ensure data integrity. Access to personal information is stringently controlled; it is granted only to CSA staff, associates and authorized contractors who have a clear and defined need to engage with the data as part of their job responsibilities.

To reinforce our commitment to privacy and security, all CSA personnel are provided with comprehensive training on best practices for handling personal information. This training emphasizes adherence to applicable privacy legislation, our own stringent privacy policy, and ethical codes of conduct, ensuring that every member of our team is equipped to protect your privacy rights diligently.

At the CSA, we are dedicated to maintaining the accuracy of the personal information which we hold and utilize. We are committed to providing our members with access to their own personal information upon receipt of a written request, subject to necessary and reasonable conditions to safeguard the information and our processes.

A nominal processing fee may apply to such requests, aimed at covering administrative costs. It is important to note, however, that there are specific circumstances under which access cannot be provided, including but not limited to situations where it might disclose:

• Information pertaining to another individual.
• Confidential business information.
• Data that could compromise another individual’s security.
• Information related to a potential or actual insurance or agreement breach, or a violation of laws.
• Details generated within formal dispute resolution processes.

This approach ensures that, while we uphold our members’ rights to access and verify their personal information, we also protect the confidentiality and integrity of all data managed by the CSA.

The CSA may amend this policy from time to time and without notice.

Requests for further information, personal information access or complaints about CSA’s handling of personal information should be referred to CSA’s Privacy Officer as follows:

Privacy and Compliance Officer
Canadian Snowbird Association
180 Lesmill Rd.
Toronto, Ontario M3B 2T5

The CSA strives to comply with all accessibility regulations in jurisdictions in which it operates. Feedback on the delivery and accessibility of our products and services is encouraged from all of our members. All privacy and accessibility related inquiries and feedback should be directed to the Privacy and Compliance Officer of the CSA in written format using the above contact information. Submissions should include the following:

• Member’s full name
• Contact information
• Member number
• Clear description of the inquiry or complaint
• Supporting documentation