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Privacy PolicyI. CHILD AND VOLUNTEER PROTECTION ADVOCATE (CVPA) PROTOCOLSA. AYSO Procedures for Protecting Volunteer Information
C. Electronic Process using eAYSO (new volunteer)
D. Pre-printed Forms for Returning Volunteers
E. Electronic Process using eAYSO (returning volunteer)
AYSO Volunteer Application Form - Flow Chart
Security of Information
D. Use of Photographs
II. OPERATIONSA. Registration - Registration Forms B. Registration - Player Forms
Evaluation of protection practices - An internal audit is performed annually. D. Employee Access, Training and Expectations We are committed to the protection of customer information. Business practices are in place that limit access to confidential information to key authorized personnel and limit use and disclosure of such information. Employee Screening - Employees required to handle sensitive information are screened through an independent contractor. E. Destruction Methods All confidential documents at the NSTC are stored in a secure area for seven years, after which they are shredded or incinerated. F. Records Retention Player and volunteer forms: Forms are retained for seven years. This is a requirement of NSTC. Note: Volunteer forms held at the NSTC may not be destroyed, under any circumstances, until approved by the director of operations. G. Nonfinancial Records - As needed. H. Information Forms (IF) IF forms are updated on the computer system through the Member Services Department. Registration may input information only on new members listed on the IF form. If the member has been a Board member previously, updating takes place in the Member Services Department. I. Events Forms (Section Meetings and NAGM) Events registration forms are sent to the Events Department, where the information is put into the system. The forms are then placed in a binder that will travel to the event via an events coordinator. The forms are used to verify registration. Forms are available at Section Meetings and are kept at the registration table to allow for quick checking. The forms are stored in the Events Department until December of each year, when they are shredded. J. AYSO Supply Center The AYSO Supply Center receives checks and credit card information. This information is kept in a double-lock file in the AYSO Supply Center for a period of five years. The AYSO bank does not have a holding requirement for credit card slips or a requirement for single- or double-lock security. Credit card slips are retained for five years. Every year, one year’s worth of credit card paperwork is to be destroyed via incineration or shredding. K. Building Security
III. MIS DEPARTMENT
IV. ACCOUNTINGThe Accounting Department handles all funds, including checks and credit cards. Once the accounts are credited, the documents are stored in locked containers. These documents are destroyed on a rotating basis, once every five years. V. MARKETING
VI. ADMINISTRATIONA. Administration Files Regional, area and section files are kept in the Administration Building. These file cabinets are not locked because staff utilizes the information contained in the files on a daily basis. The information is saved for perpetuity, thus giving a running history of the region, area or section. These files contain the Information Form (IF), budget forms and correspondence. Information is sent from the Member Services Department to the administration office “incoming file” basket. The receptionist files the information in the filing cabinet. The building is locked and alarmed each evening. All visitors must enter through a locked front door and receive a guest pass before being escorted by a staff member to their destination on campus. B. Mail
C.Telephone Confidentiality No personal information regarding staff or membership, including personal telephone numbers, addresses, e-mails, or work schedules, is given out over the telephone with the exception of region locator calls. In this case the Regional Commissioner’s phone number as listed in the Executive Member Directory (EMD) is given to the caller. The Executive Director, chief operations officer, administration manager and directors are able to change voice-mail passwords from a dedicated computer. D. Fax Confidentiality Faxes are received electronically through the administration office receptionist. One receptionist is assigned the responsibility of disseminating the faxes hourly during the workday. Faxes are directed to the individual addressed on the fax. The following confidentiality statement is printed on all outgoing faxes:
E. E-mail Confidentiality
VII. AYSO WEB SITE – www.soccer.org and CorvallisAYSO.orgThe Web Site Guidelines Manual details the privacy policy for regions using a Web site. The following is the policy created for the NSTC Web site: ONLINE PRIVACY POLICY OVERVIEW OF POLICY The American Youth Soccer Organization is very concerned about the privacy of our kids and members and this concern extends to our website. Our goal is to always protect the personal identity of all users who interact with our website, children and adults. This policy outlines how we collect and use the data collected. It also provides a current listing of all third parties AYSO is partnering with concerning online activities. We strongly encourage parents or guardians to go online with their children and participate with them in their online activities. For guidelines on how to protect children's privacy online, please review the U.S. Federal Trade Commission's (FTC) How to Protect Kid's Privacy Online » The Children's Online Privacy Protection Act (COPPA; effective date 21 April 2000) establishes mandated disclosures, parental notifications and options for all online activities where information is requested from a child under 13 years of age. Currently, the Act establishes that website producers who collect personally identifiable data from children under 13 years of age are required to obtain verifiable parental consent in advance unless the data collected is an e-mail address for a one-time request, such as a contest entry, electronic postcard, etc. This policy covers the following topics pertaining to AYSO's online interactivity with visitors: DEFINITIONS Personally Identifiable Data: Refers to any information which could be readily associated with the individual to whom it pertains, e.g. addresses, phone numbers, e-mail addresses, etc. Personally identifiable information, under this definition, does not include information that is collected solely in the aggregate (such as IP Addresses, browser versions, etc.) nor does it include information that an individual publicly releases or intends for public dissemination. Domain names, for instance, are not included as personally identifiable information; however e-mail addresses are. This definition also includes other types of information that are related to the person specifically, such as hobbies, interests, etc. Aggregate Data: Refers to any data that is not personally identifiable. This data would include IP addresses, browser versions, etc. as well as quantifying data such as total number of entrants, age group dispersement, etc. Publicly Available: Refers to information maintained as a public record, or that an individual publicly releases, intends for public dissemination, or should reasonably understand should become public. Verifiable Parental Consent: Refers to substantiated assent from a child's parent or guardian for the child's data to be accepted by AYSO for the specific reasons for which it is collected. The veracity of the confirmation must be from reliable sources and may include postal mail, facsimile, e-mail with digital signature, etc. Third Parties: Refers to a person, group, organization, company or authorized agent (or more than one of these) whom AYSO deems should receive data obtained via the website for marketing or other purposes. PRIVACY POLICY STATEMENT When data is collected from children under 18 years of age, AYSO will require at minimum the e-mail address of the parent or guardian for that child. At minimum, an e-mail will be sent to the parent or guardian announcing to them that their child has supplied AYSO with personally identifiable data, what that data is, and will point them to this section of the website for further details. Exception to this policy: A one-time use of the data for such events as contests, e-postcards, etc., however, the exception will cover only the requirement of parent or guardian e-mail addresses prior to inclusion in the event.THIRD PARTY SHARING Up to 18 years of age 18 years of age and older PARENTAL CONSENT & OPTIONS At any time, a parent or guardian may request a Parental Consent Verification form in order to receive any information AYSO has obtained concerning their child via the national website. Upon completion and return of this form, you may receive all personally identifiable information AYSO has obtained concerning your child through online means from the national website, if such exists. This form will ask for information from you that will identify you as the parent or guardian of the child. You may request the Parental Consent Verification form by mail only. Send your request to: 12501 South Isis Avenue, Hawthorne, California 90250. Please be aware that all the types of information that are collected for an event will be itemized in the section Current Web Marketing Partners and Details. Your options as a parent or guardian in reference to collection of your child's personally identifiable information are as follows:
AYSO, may, if it deems necessary, terminate any service provided to the child if the information at issue is reasonably necessary for the child to participate in the event. (Example: if you request deletion of the child's address, but that information is necessary for delivery of a prize or newsletter, etc., then AYSO may refuse to allow the child to participate in that activity, however, other activities that do not require this information would remain available to the child) CURRENT WEB MARKETING PARTNERS & DETAILS PARTNER DESCRIPTION OF SHARED DATA TYPE DESCRIPTION OF SPECIFIC INVOLVEMENT MISCELLANEOUS "Duration of Event:" "Event:" WHAT AYSO IS DOING FOR PARTNER AND/OR AS AN ORGANIZATION "PII:" DETAILS OF ALL PERSONALLY IDENTIFIABLE INFORMATION AYSO IS OBTAINING IN EVENT "Other Information Requested:" WHAT OTHER INFORMATION THAT IS NOT PII ARE WE ASKING FOR THE VIEWER TO SEND TO US USE OF IP ADDRESSES Used for internal website purposes only. USE OF COOKIES AYSO currently does not use cookies. CorvallisAYSO.org uses cookies to varify users and gaurentee security. LINKS TO NON-AYSO SITES AYSO supplies links to other websites outside of its control for the information and entertainment of viewers to its site. Although every effort is made to offer only websites that meet our organizational mandates concerning children and uphold our organizational ethical precepts, we in no way, either implied or explicit, endorse or control the content of external sites or any offered links from these external sites. By using this website, you agree to the Terms Of Use policy herein. FORMS SECURITY Currently, all online forms are sent via an e-mail server-side mailto script offering no security. Only information that would be reasonably sent via e-mail is asked for via any form on the site currently. Information such as credit card numbers, etc. will not be requested via any online form on the site until secure means of transmission are obtained. YOUR ACCEPTANCE OF TERMS By using this site and the forms contained herein, you are agreeing to the terms of this policy and of the Terms Of Use policy of this website. Terms Of UseLegal InformationThe AYSO National Website (AYSONW) is an online information and communications service provided by the American Youth Soccer Organization (AYSO), subject to your compliance with the terms and conditions set forth below. Please read this document carefully before accessing or using the AYSONW. By accessing or using the AYSONW, you agree to be bound by the terms and conditions set forth below. If you do not wish to be bound by these terms and conditions, you may not access or use the AYSONW. AYSO may modify this agreement at any time, and such modifications shall be effective immediately upon posting of the modified agreement. You agree to review the agreement periodically to be aware of such modifications and your continued access or use of the AYSONW shall be deemed your conclusive agreement of the modified agreement. Copyright & Trademark InformationThe entire contents of the AYSONW are copyrighted under the United States copyright laws and international treaty provisions, including without limitation the Berne Convention. The owner of the copyright is AYSO. You may print and download portions of material, including programs, from the different areas of the AYSONW solely for your own non-commercial use (which also exludes any use by any governmental, charitable, educational, or other institutional use that is not strictly of non-commercial use). You may make: (a) one machine readable copy, (b) one backup copy, (c) one print copy of any portions of material downloaded from the different areas of the AYSONW solely for your own non-commercial use. Any other copying, redistribution, retransmission, repurposing, alteration or publication of any downloaded material, is strictly prohibited without the express written consent of AYSO. Use of the AYSO National WebsiteYou understand that, except for information and services clearly identified as being supplied by AYSO, AYSO does not operate, control or endorse any information, products or services on the internet in any way. Except for AYSO identified information and services, all information, products and services offered through the AYSONW or on the internet generally are offered by third parties that are not affiliated with AYSO. Additionally, affiliates of AYSO are autonomous and any information, services or products they may offer on their own internet sites may or may not be endorsed by AYSO National. External links offered on the AYSONW are strictly for the informational purposes and the enjoyment of viewers, no endorsement is implied or inferred. AYSO makes no representations whatsoever about any other web site which you may access through the AYSONW. You understand further that the internet contains unedited materials some of which are sexually explicit or may be offensive to you. You access such materials at your own risk. AYSO has no control over and accepts no responsibility whatsoever for such materials. WarrantiesTHIS INFORMATION IS PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. IN NO EVENT SHALL AYSO OR ANY OF ITS AFFILIATES BE LIABLE FOR ANY SPECIAL, INCIDENTAL, INDIRECT, OR CONSEQUENTIAL DAMAGES OF ANY KIND (INCLUDING, BUT NOT LIMTED TO, LOST DATA OR PROFITS), OR ANY OTHER DAMAGES WHATSOEVER WHETHER OR NOT ADVISED OF THE POSSIBILITY OF DAMAGE, UNDER ANY THEORY OF LIABILITY, ARISING OUT OF OR IN CONNECTION WITH THE USE OR PERFORMANCE OF THIS INFORMATION. THIS INFORMATION COULD INCLUDE TECHNICAL INACCURACIES OR TYPOGRAPHICAL ERRORS. CHANGES MAY BE PERIODICALLY ADDED TO THE INFORMATION HEREIN. Restricted RightsUse, duplication, or disclosure by the United States Government is subject to the restrictions set forth in FAR 52.227-19 or DFARS 252.227-7013 subparagraph (c), as applicable, relating to Commercial Computer Software -- Restricted Rights. The AYSONW is presented by the American Youth Soccer Organization from within the United States of America. AYSO makes no representation or claim that the materials in the AYSONW are available for use or appropriate in locations outside the United States of America. Neither the AYSONW nor any underlying information or technology - including, but not limited to, WinAYSO software - may be downloaded or otherwise exported or re-exported into, or to a national resident of, any country to which the United States has embargoed goods or to anyone on the U.S. Treasury Department's list of Specially Designated Nations or the U.S. Commerce Department's Table of Denial Orders. By downloading or using any element of the AYSONW, you are agreeing to the foregoing and are certifying that you are not located in, under the control of, or a national or resident of any such country or on any such list. Additionally, you are responsible for complying with any and all local laws in your jurisdiction which may impact your right to use the AYSONW. Social Security NumbersFrom: Pete MacPhail , National President Re: Collection of Social Security Numbers on Volunteer Applications. In the face of so much publicity these days about identity theft, more and more of our volunteers question why AYSO requires social security numbers (SSN) as part of the volunteer application process. Past AYSO President Joel Mark wrote the following memo in response to these concerns, and I have edited it to ensure it reflects our most current thinking and practices. We ask our volunteers to consider the following questions and answers concerning the AYSO decision to require the SSN. Is this choice something that has been mandated unilaterally by the NSTC? During the 1997 re-write of our Bylaws, which came from the floor of the NAGM and not from the NSTC, some 750 Regional Commissioners, 75 Area Directors, 13 Section Directors, together with the National Board of Directors, voted unanimously to adopt Bylaw provision 1.04(t) to require all regions to "cooperate in the policies developed by the Board or the National Support [and Training] Center with respect to requiring each coach, referee and other designated volunteers to complete a volunteer form, and with respect to verifying the information obtained, before permitting such coach, referee or such volunteer to participate." This is what we – all of the Executive Members of AYSO – decided we must do because of our shared concern for children. This provision also is important for the health of the organization. Should AYSO ever be sued for not doing all it could to protect the children, we all would be liable for the damages a jury may assess because we are a unitary corporation. Why does AYSO need the SSN in the first place? AYSO is a national organization. We secure criminal background reports by searching court documents in county jurisdictions all across the country. These jurisdictions use a variety of personal information to identify those convicted of crimes. Unfortunately, there is no consistency as to the information used from jurisdiction to jurisdiction to identify those convicted. The expert opinions we sought and received on the matter told us unequivocally that all this information – including the SS# - was necessary to ensure the viability of the background information we secure. Collecting all this information serves AYSO on two fronts. First, the accuracy of the information we receive ensures that we exclude those with the highest potential for harm to our children, and, equally important, it helps us avoid excluding a good and valuable volunteer due to mistaken identity. What risk do the volunteers face? Experts have informed us that there are so many easier ways to obtain someone's SSN or otherwise engage in identity theft that it is extremely unlikely that giving the SSN to AYSO will significantly increase that risk. Things we put in our trash, leave in our car, or supply in connection with consumer, banking and insurance transactions, all contain the SSN or other information sufficient to make identity theft possible even without the SSN. Therefore, while identity theft is a real risk, AYSO has taken every possible step to minimize that risk. As a result ,we do not believe that supplying the SSN to AYSO increases the risk our volunteers otherwise may face regarding identity theft generally. What risk do the children face? Recent articles in the media have established that youth sports generally presents an increasingly enticing target for predators. It also is a tragic fact that, before our Safe Haven procedures were instituted, AYSO had documented incidents of child molestation by volunteers who turned out to be predators. Additionally, our Safe Haven procedures already have alerted us to a number of potential predators within our volunteer ranks. And, while it cannot be quantified, it is our strong belief that the Safe Haven procedures have deterred an additional number of other potential predators from applying as volunteers to AYSO. Thus, it seems quite clear that youth sports participants in the United States – including those who choose to participate in AYSO – unfortunately are at increased risk and would remain at such risk without some procedure such as Safe Haven to address and reduce that risk as far as may be reasonably possible. What are the comparative consequences of the two risks? While no one can calculate how many cases of identity theft AYSO may enable by collecting the SSN, if any, compared to how many cases of child molestation or abuse AYSO may prevent by doing so, we can measure a significant difference in the magnitude of the consequences. Experts have advised us that identity theft can be detected and corrected simply by running a personal credit check every year. And, while the most severe cases of identity theft may take longer to correct, they ultimately are correctable and good credit ultimately can be recovered. The same cannot be said for the child who becomes a victim of molestation or abuse. For the child who falls victim to such abuse, there is no cure except perhaps years of therapy and guilt and recrimination, years that can never be recovered. How are these risks being addressed by AYSO? Clearly, we need to do everything we can to reduce both risks. With respect to the children, every professional company with whom AYSO consulted about contracting to perform our background screening of volunteers informed us that, without the SSN, the accuracy of their reports could be diminished substantially. Therefore, AYSO has decided to heed this advice and require the SSN from volunteers to reduce the risk to the children. The risk to the volunteers of supplying the SSN can be and is being reduced significantly through our use of industry-standard encryption and certified electronic firewalls that protect the data stored on our servers. This is what AYSO has decided is the best balance between the two risks. What has AYSO concluded it must do when a volunteer asks AYSO to choose between the risk to the children and the risk to the volunteer? Admittedly, even the best devices and protocols cannot eliminate entirely either risk. Thus, some volunteers have asked AYSO to waive the requirement for the SSN – i.e., to choose between the two risks and to make the risk to the volunteers a greater priority than the risk to the children. We believe that AYSO must always stand up for the principle that, as between the two groups, it should never be the children who are put at increased risk. As a result, we have instructed all CVPAs to not accept a volunteer application from anyone refusing to fully cooperate with the process, including supplying the SSN. We know this may drive away some volunteers. But, we also know that it will drive down the risk that our children otherwise would face. We therefore remain convinced that, when asked to choose, AYSO must opt to put child protection ahead of the risk, if any, to a volunteer from supplying the SSN. Will AYSO continue to require the SSN? Until some other means of reliably verifying the information supplied by our volunteers becomes readily available we will continue to require the SSN to protect the children from unnecessary risk, to protect the organization from avoidable liability, and to comply with the Bylaw provision that the Executive Members have adopted unanimously. We respect that some people will refuse to supply their information. Regrettably, we will thank them for their interest but will not accept their application to be a volunteer in AYSO. Thank you for giving your consideration to these important questions and answers attendant to AYSO's need to obtain volunteers' SSN. Should you have any further questions or concerns, please contact Ellisa Hall at the AYSO National Support & Training Center. Legal Protection and SupportUnlike other youth organizations, AYSO is a single corporation one legal entity and each region is a component of such corporation. Hence the assets of each region, as well as the liabilities, belong to the AYSO National organization. Each section director, area director, regional commissioner and other regional official is, in effect, an agent of the corporation, and therefore capable in varying degrees of creating legal obligations on behalf of AYSO. Similarly, if sued based on his or her participation in an AYSO program, in his or her capacity as an AYSO officer, each AYSO official will be protected by AYSO, provided he or she has acted in good faith. The National Support & Training Center should be promptly notified of any claim, whether pending or merely threatened. If a lawsuit is actually brought and an AYSO official is the named defendant and the Legal Commission has determined that he or she has acted with apparent authority in such capacity, and in good faith, AYSO National will move in the appropriate court to substitute itself as the proper party defendant or take appropriate action to assure the defense of such suit. Refer to Policy Statement 3.5. NOTE: This area of the site addresses only administrative matters dealing with AYSO Regional Operations. Parents with serious concerns should address them to their Regional Board of Directors. Regional Board meetings are open to members for discussion of issues. |
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| Last Updated on Friday, 23 January 2009 10:41 |

