Procedure on Documentation and Privacy of Camp Records

Contact Officer: Executive Director, Risk and Safety Services; Executive Director, Office of the Provost

 

Definitions

Off-site activity – Camp activities that take place in a different location from where the majority of the regular Camp activities are held. This could include locations both on and off university owned property. (E.g., water games at City Park, Swimming activity at the ARC pool for non-swimming camps, etc.)

Camps for Minors (Camps): A day or overnight program that offers recreational activities and/or instruction to Minors. Such Camps typically have five or more Campers and operate anytime during school vacations. Camps are run by academic and administrative units of the university and student groups. This may include partnerships between university units and external organizations that use university facilities or brand. A list of approved Camps is posted on the Queen’s university website.

Campers: Minors attending Camps held at Queen’s facilities.

Camp Director: The person responsible for developing Camp programming and ensuring the Camp complies with university policies and procedures related to Camps for Minors.

Camp Staff:  Employees who are responsible for delivering programming and providing care for Campers.

Minor: A person under the age of 18.

Volunteer – An individual who donates their time to deliver Camp programming and provide care to Campers, without an employment relationship or receipt of compensation.

Purpose

This procedure provides details for creating and keeping appropriate and sufficient documentation, and for protecting the privacy of personal information collected, in the course of operating a Camp for Minors on Queen’s properties or to a Camp affiliated with the university as per the Policy on Establishing and Operating a Camp for Minors and Protection of Minors Involved in University Camps, Programs and Activities Policy. Except where specifically noted, the requirements provided in this procedure relate to both in-person and virtual/online camps.

Procedure

1. Camp Registration Forms

1.1 Camp Registration Forms must include at a minimum:

  • All important information about the child. This includes: name, birth date, gender identification, known medical conditions, special needs or accommodations required, two emergency contacts (contact name, home phone number, cell number and email), authorized pick-up list.
  • To be as inclusive as possible for Gender identification provide a blank space or text box for the answer if possible. Depending on the nature of the Camp and its activities if gender is not disclosed Camp Directors can refer to the Guidelines on Collecting Information About Sex and Gender at Queen’s University and are encouraged to contact the Equity Office and/or Human Rights Office for guidance.
  • Signed consent from the parent or guardian for the child to participate.
  • Disclosure of all off-site activity and the nature of this activity, as well as any other risks that could pose harm so parents or guardians fully understand the activities the Campers will be partaking in prior to granting consent to their child’s participation in the Camp.
  • Explanation of expectation of acceptable Camper behaviour.
  • Cancellation and refund policy.

2. Informed Parental Consent

2.1 Camps must obtain signed consent from the parent or guardian for each Camper on either the registration form or a separate document. The following consent must be obtained:

  • A statement to release the university from liability arising from injury, damages, or loss which may occur as a result of the Camper’s participation in the camp, except those caused by neglect.
  • Consent for the Camper to participate in the program.
  • Consent for the Camp to photograph Campers and/or use their name for promotional purposes – this must be provided as a separate “consent box” to enable the parent to decline consent. Consent for administering medication if the individual Camp policy allows for that (see Health and Safety and Emergency Procedures for Camps).
  • Consent for the Camper’s participation in any off-site activity.

Virtual Camps Only: Consent for parent/guardian to take responsibility to structure their child’s internet access in an age-appropriate manner and to talk to their child about online privacy and responsible online engagement. Virtual Camp Consent Forms must include an acknowledgement from parent/guardian that they or another caretaker chosen by them (babysitter, other relative) is primarily responsible for the Campers safety in the virtual location and that a parent/guardian/caretaker will be present at the location for the duration of the Virtual Camp session.

2.2 Camps must request University Counsel review any updates to the registration and parental consent section(s) of the registration or parental consent forms. Copies of blank forms must be forwarded to camps@queensu.ca 30 days before the opening of registration.

3. Medical information

3.1 All Camps must request parents/guardians provide all pertinent medical information, including any special needs, allergies and medications required, as part of the registration process. This will enable Camps to best accommodate and prepare for Campers’ needs.

3.2 Camp literature must advise parents/guardians to keep their child home in the event that they are sick, to help reduce an illness from spreading to other Campers. Parents must be asked to contact the Camp if a child will be absent due to illness.

3.3 All Camps must request parents/guardians to complete an Epinephrine Administration Waiver Form for all children who carry an epi-pen.

4. Notification of the Purpose of Collecting Information

4.1 Camps are required to notify parents/guardians of the collection of personal information and the intended purpose and use of this information in compliance with the Freedom of Information and Protection of Privacy Act (see the Fact Sheet at (link)  This notice must include the following statement: “Personal information is collected under the authority of the Queen’s University Royal Charter of 1841, as amended, and will be used for the purpose of registration, administering program-related activities, and safety, or consistent purposes. Questions regarding the collection or use of this personal information should be directed to the Records Management and Privacy Office (link).

5. Information Security

5.1 All confidential information, including Camp Staff and Camper records must be stored in a secure location accessible only to designated staff on a need-to-know basis.

5.2 Camps must ensure that all Camp Staff agree to maintain strict confidentiality regarding medical, health status, and any other private, privileged, or confidential information about program participants, their families, other staff, Volunteers, and the program. A confidentiality agreement must be included in a code of conduct to be signed and dated by all Camp Staff.

5.3 Camps collecting and storing personal information electronically must consult with the Information Security Officer at Queen’s to ensure compliance with the university IT policies for security.

5.4 Camps who accept, capture, store, transmit and/or process payment card data must be in compliance with the PCI Data Security Standard (DSS) as per the university’s Payment Card Acceptance Policy and Procedure.

5.5 Virtual/online Camps must not record their sessions.

6. Records Retention

6.1 Camp Directors are required to retain program related documentation per the authorized records retention schedule (link). Documentation must be kept in a locked or secured location. If forms are scanned into an electronic format, the electronic version may be declared the official record, and the paper version securely destroyed. Documents should not be retained in multiple formats. Electronic storage must be in a password-protected or encrypted form.

Camp Staff are required to comply with the Procedures for Disposal of University Records.


Date Approved: 2015 December 14
Approval Authority: SLT
Date of Commencement: 2016 January 1
Amendment Dates: May 2023, April 2019
Date for Next Review: May 2028
Related Policies, Procedures and Guidelines:
Protection of Minors Involved in University Programs & Activities
Policy on Establishing a Camp for Minors
Hiring and Training of Camp Personnel Procedures
Documentation and Privacy of Camp Records Procedures
Health & Safety and Emergency Procedures for Camps
Supervision of Campers Procedures