Casino Niagara and Niagara Fallsview Casino Resort (the "Casinos of Niagara") are subject to the Personal Information Protection and Electronic Documents Act ("PIPEDA"). PIPEDA, which is Canada's privacy law, sets out specific rules for organizations that collect, use and retain personal information as part of their commercial activities.
The Principles established by The Canadian Standards Association's ("CSA") Model Code for the Protection of Information form a major part of PIPEDA. The CSA Model Code Principles describe how organizations should collect, use and disclose personal information. They also address an individual's right to access his/her personal information and have it amended for commercial purposes.
PROTECTION OF YOUR PRIVACY AT THE CASINOS OF NIAGARA
The following Ten Privacy Principles govern our collection, use and disclosure of Personal Information and have been developed to reflect both the CSA Model Code Principles and the expectations of our Patrons:
- Identifying Purposes
- Limiting Collection
- Limiting Use, Disclosure and Retention
- Safeguarding Patron Information
- Patron Access
- Challenging Compliance
Principle 1 – Accountability
The Casinos of Niagara are responsible for Personal Information under their control. In that regard, it has designated a Chief Privacy Officer to ensure the Casinos of Niagara comply with these Ten Privacy Principles.
Principle 2 – Identifying Purposes
The purposes for which Personal Information is collected shall be identified by the Casinos of Niagara at or before the time such information is collected.
Principle 3 – Consent
The knowledge and consent of the Patron are required for the collection, use and disclosure of Personal Information, except where required or permitted by law.
Principle 4 – Limiting Collection
The collection of Personal Information shall be limited to that which is necessary for the purposes identified by the Casinos of Niagara. Personal Information shall be collected by fair and lawful means.
Principle 5 – Limiting Use, Disclosure and Retention
Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the Patron or as required by law. Personal Information shall only be retained as long as necessary for the fulfillment of those purposes.
Principle 6 – Accuracy
Personal Information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is used.
Principle 7 – Safeguarding Patron Information
Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information.
Principle 8 – Openness
The Casinos of Niagara shall make readily available to Patrons specific information about its policies and practices relating to the management of Personal Information.
Principle 9 – Patron Access
Upon making a request in accordance with this Policy, a Patron shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. A Patron shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 – Challenging Compliance
A Patron shall be able to address a challenge concerning compliance with these Ten Privacy Principles to the Casinos of Niagara's Chief Privacy Officer or other designated Associates working with the Chief Privacy Officer to ensure compliance.
WHY IS PERSONAL INFORMATION COLLECTED?
Personal Information is collected by the Casinos of Niagara for the purpose of conducting and managing our business. Most Personal Information we collect comes to us directly from you and only with your consent. Providing us with your Personal Information is always your choice.
All of the information you provide to us is securely maintained and kept confidential, except under certain special circumstances. The Casinos of Niagara collect certain Personal Information from Patrons and use it for the following reasons:
- To correctly identify you;
- To comply with legal requirements and to co-operate with law enforcement agencies;
- To protect both the Casinos of Niagara and their Patrons against fraud and other violations of criminal or civil laws;
- To ensure that minors do not gain entry to the Casinos of Niagara;
- To ensure a secure and safe environment for Patrons and our Associates;
- To assess a Patron's eligibility for cash back, retail items and complimentaries, such as meals, hotel accommodations and transportation;
- To provide Patrons with information about up coming activities, new games, tournaments and events at the Casinos of Niagara;
- To provide Patrons with promotional offers and invitations to player parties, concerts, sporting events and other events;
- For marketing purposes, including to learn about our overall market and to better understand their and your interests as well as to improve our overall service delivery.
TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW
The Casinos of Niagara may obtain and collect your Personal Information through the following means:
Identification ("ID") Verification.
Casinos verify the photo ID of all individuals who appear under 25 at the entrances, to ensure that no one under the legal gaming age of 19 is permitted entry. No information is recorded when ID is verified at the doors by Security Officers.
Casinos are also required, under the Regulations to the Gaming Control Act ("GCA" and/or the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA"), to verify government-issued photo ID and to record certain information, including name, date of birth, address, type of ID, ID reference number and place of issuance of the ID, before conducting certain types of transactions. These transactions include foreign exchange transactions of $3,000 or more, cash transactions of $10,000 or more*, electronic funds transfers of $10,000 or more*, credit extensions of any amount, opening a front money account in any amount, etc.
The Casinos of Niagara also require government-issued photo ID before issuing a Players Advantage Club ("PAC") card, or permitting a Patron to redeem points on their PAC cards. This requirement protects Patrons who may lose or misplace their PAC cards from having someone else redeem their points.
Security Officers posted at the entrances of the Casinos of Niagara use devices called IDLogix Verifiers to scan any ID they believe may have been tampered with or altered as well as any ID belonging to persons who appear to be under the age of 25 for verification purposes. The IDLogix Verifiers will display information encoded on IDs which may include: name, date of birth, address, ID reference number and expiry and issue dates and will also recognize any ID which has been falsified. The Casinos of Niagara do not maintain a log of the information collected by IDLogix.
To protect your privacy, photography is prohibited on the gaming floor. The only exceptions to this prohibition are photographs of jackpot winners, who consent in writing to their picture being taken. Except for your spouse or significant other, no other Patrons will be included in the photographs. With the permission of the Alcohol and Gaming Commission of Ontario ("AGCO"), the Casinos of Niagara may also take photographs on the gaming floor for publicity purposes and advertising campaigns. In these cases, only actors are used in the photographs, and clearly visible signage is posted to advise our Patrons of the photo shoot.
In order to comply with the GCA Regulations, the Casinos of Niagara are required to have surveillance systems to monitor all gaming and sensitive areas of the casino. Video surveillance cameras are used to protect the Casinos of Niagara, their Patrons and Associates against potential violations of criminal and/or civil laws. Surveillance camera output is strictly controlled and monitored by the Casinos of Niagara’s surveillance personnel, certain authorized officers, directors, and/or employees, Ontario Provincial Police and regulatory authorities.
Patron Tracking and Reward Programs
The Casinos of Niagara have established various player tracking and reward programs. You may choose to become a member of our Player's Advantage Club so that you can redeem your slot points for cash back or gift items. If you are a table games player, you may wish to have your play rated. If you choose to join the Player's Advantage Club or to have your play rated, we may collect certain information about you including name, address, telephone number, e-mail address, interests, gaming history, number of visits to the casino, level of play, etc. The Casinos of Niagara use this information to better understand the interests of its Patrons, to provide you with valuable marketing information, and to assess your eligibility for cash back, complimentaries, and other promotional offers.
Manual and Electronic Forms.
During your visit to the Casinos of Niagara, you may be asked to complete various forms for releasing different types of Personal Information. Forms you may be asked to complete fall in the following categories:
As a service to interested and eligible Patrons, the Casinos of Niagara may extend your credit to facilitate gaming. To assess your eligibility for credit and determine a line of credit that corresponds with your financial means, we will first have to obtain information about you and verify your financial history. You will be required to provide us with your name, address, income, banking information, credit history and social insurance number. The information on our credit applications is required under the GCA Regulations, and is similar to the type of information a bank would require before extending a consumer loan.
Other Financial Services
As a service to interested Patrons, the Casinos of Niagara may open a front money account for you, advance you cash on your credit card, transfer your funds by wire to a financial institution, or permit you to use a Safety Deposit Box. Before we can facilitate these services, we will require certain Personal Information. Depending on the type of service you are interested in, the Personal Information may include your name, address, date of birth, signature, etc. Where these transactions (excluding use of a Safety Deposit Box) amount to $10,000 or more in a consecutive 24-hour period, a Large Cash Transaction Report is required under the Regulations to the PCMLTFA.
Large Cash and Multiple Transaction Records
Under the Regulations to the GCA and the PCMLTFA, casinos are required to complete a Large Cash Transaction Report before conducting any cash transactions of $10,000 or more and a Disbursement Record for the disbursement of $10,000 or more in cash or by cheque (including multiple cash transactions by the same person amounting to $10,000 or more in a consecutive 24-hour period) and a Multiple Cash Transaction Record before conducting any cash transaction of $2,500 or more. These records may include Personal Information such as your name, address, date of birth, business or principal occupation. Where we determine that the transaction is being completed on behalf of a third party, Personal Information on the third party is also required, including the third party’s name, address, date of birth, business or principal occupation, and relationship between the patron conducting the transaction and the third party. Whenever $10,000 or more in cash is received or disbursed in cash or by cheque by the Casinos of Niagara (including multiple cash transactions by the same person, amounting to $10,000 or more in a consecutive 24-hour period), we are required to file these transactions with a federal agency, the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC").
Suspicious Transaction Records
Whenever we have reason to suspect that a transaction (regardless of the amount) is related to the commission of a money laundering offence, the PCMLTFA requires that casinos, as well as financial institutions, foreign exchange dealers, etc., report the transaction to FINTRAC. Certain Personal Information about the Patron conducting the transaction is required on these reports. The PCMLTFA prohibits us from disclosing that a Suspicious Transaction Report has been filed, or the content of such a report, with the intent of prejudicing a criminal investigation (whether or not a criminal investigation has begun).
If you have difficulty in gaming responsibly, you may wish to voluntarily self-exclude, advising the Casinos of Niagara of your intent not to return. If you sign such a form, all gaming premises in Ontario will be made aware of your decision and will take appropriate steps should you be found at any such premises. The Casinos of Niagara will also remove your name from our mailing list, and ensure that you do not receive invitations to player parties and events. The form requires that you disclose your name, address, date of birth, and a piece of ID, and that you allow us to take a photograph of you. This information is shared with all gaming premises in the province of Ontario in order to recognize the voluntary ban.
Details of security incidents, such as assaults, thefts, drunkenness or disorderly conduct, etc., are recorded. If you are involved in or witness a security incident, you may be asked to provide us with your name, address, and telephone number.
Health and Safety
If you or a family member become ill or are involved in an accident while visiting the Casinos of Niagara, we may ask you to provide us with your contact information, health history, physician and next of kin. Other information may be documented depending on the nature of the medical or accident.
DISCLOSURE OF PERSONAL INFORMATION
It is our policy at the Casinos of Niagara to keep your Personal Information confidential except under certain special circumstances.
The Casinos of Niagara do not sell to third parties any Personal Information it collects on Patrons. The Casinos of Niagara may disclose this information to the AGCO, the Ontario Lottery and Gaming Corporation, other gaming premises, insurance companies and law enforcement for security, health and safety and legal or regulatory compliance reasons.
Unauthorized access to and/or disclosure of Patron information by the Casinos of Niagara's Associates is not permitted. All Associates are expected to maintain the confidentiality of Patron information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
We sometimes contract outside organizations to perform specialized services such as Financial Audits. Our trusted service providers may at times be responsible for processing and handling some of the information we receive from you. When we contract our suppliers to provide specialized services, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide. In fact, our suppliers are bound by strict contractual obligations that have been designed to protect the privacy and security of your information. Furthermore, as part of our contract agreements, our suppliers and employees are required to protect your information in a manner that is consistent with the privacy policies and practices that we have established.
HOW THE CASINOS OF NIAGARA PROTECT YOUR PRIVACY
The Casinos of Niagara take all reasonable steps to keep the Personal Information it collects about you confidential and to ensure your Personal Information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. All computers on which Personal Information is stored are password protected. Access to surveillance videotapes is restricted to authorized personnel, law enforcement, legal and regulatory authorities, and our insurers.
Paper based files are securely stored and access to such files is restricted.
Our security practices are reviewed on a regular basis for the purpose of protecting the confidentiality and privacy of your Personal Information.
HOW TO STOP MAILINGS AND PLAY RATING
If you don't want the Casinos of Niagara to use Personal Information collected about you for marketing purposes, or do not wish to have your play rated, please let us know at the time the information is collected. Please also let us know if you do not want to be on our mailing list, or to receive telephone calls at your home about events or promotions at the Casinos of Niagara. You can also make such requests in writing to:
ACCESSING AND AMENDING YOUR INFORMATION
At the Casinos of Niagara decisions are often made based on the Personal Information we have. Therefore, it is important that your Personal Information is accurate and complete. To help us keep your Personal Information up-to-date, we encourage you to amend inaccuracies and make corrections as often as necessary. Despite our best efforts, errors sometimes do occur.
As a Patron you have the right to access, verify and amend the information maintained by the Casinos of Niagara. Should you identify any incorrect or out-of-date information maintained about you by the Casinos of Niagara we will make the proper changes and provide you with a copy of the corrected information.
You may access and verify any of your Personal Information whenever you wish by contacting us at (905) 353-6719. We can assist you in correcting any inaccurate information.
If for some reason you are refused access to Personal Information maintained by the Casinos of Niagara, you will be provided with the reason and may challenge this refusal by contacting our General Counsel and Chief Compliance Officer.
RESOLVING YOUR CONCERNS
Please let us know about your questions or concerns and we will do our best to help you. Correspondence should be directed as follows:
PERSONAL INFORMATION COLLECTED BY THE ALCOHOL AND GAMING COMMISSION OF ONTARIO AND THE OPP
The AGCO is an agency of the Government of Ontario that is responsible for ensuring that gaming in this province is conducted with honesty and integrity. This involves overseeing the operation of Ontario’s gaming facilities. Officers of the OPP are seconded to the AGCO to carry out law enforcement activities within gaming facilities.
Regulations made under the GCA require that gaming facility operators install video surveillance in certain parts of the facilities. OPP officers monitor the video surveillance in order to identify any illegal activity. In cases where illegal activity is suspected OPP officers carry out an investigation. Some investigations may involve use of face recognition information comparing a facial scan to a database of known or suspected criminals.
Patrons of gaming facilities do not automatically have their face recognition information gathered by the OPP when they enter a gaming facility. Face recognition information is gathered and used strictly in the course of police investigations. Access to information gathered by OPP officers is restricted to the officers who are assigned to work in the gaming facility. All information gathered is protected by sophisticated systems. Once an investigation is completed the relevant face recognition information is removed from the OPP database.
The AGCO gathers personal information in accordance with the Freedom of Information and Protection of Privacy Act for the purpose of law enforcement. Anyone seeking access to the information must meet the requirements set out in the Freedom of Information and Protection of Privacy Act. If you have any questions or would like more information about the role of the commission and its use of face recognition information, please contact:
This Policy was produced on January 1, 2004 and updated on September 28, 2009. The Casinos of Niagara reserve the right to modify or amend its Personal Information Protection and Privacy practices as set out in this Policy at any time and for any reason.
Note: * Includes multiple cash transactions or electronic fund transfers, by the same person, amounting to $10,000 or more during the gaming day.