NHL HOTLINE PRIVACY NOTICE
Welcome to the NHL Hotline, which is accessible online [www.nhlhotline.com], by phone to a live operator or voicemail [1-833-999-1184] and by email [NHLhotline@deloitte.com] (collectively, the “Hotline”). The Hotline is a reporting platform operated by Deloitte LLP (“Deloitte”) on behalf of the National Hockey League (“NHL”) and its member clubs. This Hotline is part of the NHL’s efforts to create a workplace culture that is inclusive, respectful and free from abuse, harassment and unethical behavior or misconduct in accordance with the workplace policies of the NHL and its member clubs and the NHL Declaration of Principles. The NHL has established the Hotline to allow NHL stakeholders, including without limitation NHL players, club personnel and NHL employees, to report incidents of unethical behaviour and misconduct. The NHL takes allegations of unethical behaviour and misconduct seriously and will review disclosures made through the NHL Hotline to determine an appropriate course of action.
This Privacy Notice describes the manner in which the NHL and Deloitte collect, use, and share the information disclosed by you when you report an incident through the NHL Hotline.
Can I make a Disclosure Anonymously?
You are not required to provide your name or contact information unless you choose to do so. You have three options when making a Disclosure (“Disclosure”) to the Hotline:
- Anonymously: Do not provide your name or contact information to Deloitte, the NHL, or a relevant NHL member club;
- Confidential Restricted: Provide your name and contact information to Deloitte on a confidential basis, but this information will not be shared with the NHL, or a relevant NHL member club, without your consent; or
- Confidential: Provide your name and contact information to both Deloitte and the NHL Disclosure Review Committee on a confidential basis (which may include disclosure to other NHL-related entities, including one or more member clubs of the NHL, the NHL Players’ Association and/or other signatory to the Declaration of Principles where relevant and appropriate for the purposes of investigating and responding to your Disclosure).
Even if you do not provide your name or contact information to Deloitte or the NHL, it may still be possible for Deloitte and/or the NHL or other NHL Entities (as described below) to identify you or other parties based on the contents of your Disclosure. However, you will not be specifically identified as the individual making the Disclosure and neither Deloitte nor the NHL will attempt to identify you using any other information.
While you are not required to provide your name and contact information, it may assist the NHL in investigating and responding to your Disclosure.
What Information is Collected:
The personal information collected will depend on the information you choose to share and the manner in which you make a Disclosure through the NHL Hotline. Information collected through the Hotline may include your name and contact information, club affiliation (if applicable), the names of people involved in the incident, a description of the incident, the names of any witnesses and any supporting evidence or documents, and any other information you provide when making a Disclosure or in response to any request for additional information.
After you make a Disclosure, you will be provided with a Disclosure ID and PIN which can be used to follow up on the status or to add additional information to your Disclosure. When you first log in to the Hotline website, you will be asked to create a password for your Disclosure ID. You are responsible for ensuring the confidentiality of your Disclosure ID and password. We strongly recommend that you select a unique password that is difficult to guess and that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls, or email messages).
How Your Information is Used:
A Deloitte analyst will use the information contained in your Disclosure to create a report summarizing the incident (the “Disclosure Report”). The Disclosure Report will be provided to the NHL Disclosure Review Committee, which will review the information and determine what follow up investigation and/or response may be necessary based on the information contained in the Disclosure Report.
Deloitte will not include the name or contact information of the person making the Disclosure in any Disclosure Report(s) shared with the NHL Disclosure Review Committee without that individual’s consent. However, it may still be possible to identify the person making the Disclosure and/or other parties based on the contents of the Disclosure. If you consent to the sharing of your name and contact information with the NHL, the NHL (or other NHL entities as described below) may contact you directly as appropriate for the purposes of investigating and/or responding as necessary to the information contained in the Disclosure Report.
If you make a Disclosure by email, Deloitte will reply to your email to provide you with a Disclosure ID (an alphanumeric reference number) and PIN number. Similarly, if you make a Disclosure by phone or voicemail and choose to share your name or contact information, Deloitte will use your information to provide you with a Disclosure ID. Deloitte will not use the contact information you provide to contact you directly once a Disclosure ID has been assigned, and any follow-up communications from Deloitte about your Disclosure will be made through the Hotline website.
If you make a Disclosure by voicemail, your voice message is used and retained by Deloitte solely to create your Disclosure Report.
How Your Information is Shared:
Access to personal information provided through the Hotline reporting platform and to Disclosure Reports is limited to authorized Deloitte and NHL personnel on a need-to-know basis.
Where relevant and appropriate, the NHL may share Disclosure Reports with one or more member clubs of the NHL, the NHL Players’ Association and/or other signatory to the Declaration of Principles (collectively with the NHL, “NHL Entities”) for the purposes of investigating and responding to a Disclosure. Even if you do not consent to provide your name or contact information to the NHL Entities, it may still be possible for them to identify you or other parties based on the contents of your Disclosure.
Deloitte and the NHL Entities may be required to disclose certain information (including your identity) to law enforcement, to the extent the nature of the information reported in the Platform involves an ongoing or imminent commission of a crime, or imminent harm to you or others or where otherwise required by applicable law (which may include lawful access by US or Canadian law enforcement or government authorities). We also may share your information where reasonably necessary to protect our rights or property.
How Your Information is Stored:
Your information will be maintained on a confidential basis by the NHL and Deloitte on servers located in Canada. Deloitte and the NHL have adopted physical, technical, and administrative safeguards to help protect against theft, loss, misuse, and unauthorized access to or disclosure of the information we collect and receive.
Questions? Contact Us.
If you have any questions regarding the personal information practices of the NHL’s Hotline, or to request access to your personal information, please contact NHLhotlineprivacy@nhl.com.