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Thread: Registrar .re1 file and concern about PII

  1. #1
    Active Member rhysem's Avatar
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    Registrar .re1 file and concern about PII

    Hi all,

    I'm having a discussion with our registrar about providing the .re1 file to meet directors. This is a file that a registrar can generate that contains all swimmers currently registered in the LMSC - name, club, USMS ID, and birthdate. This is tremendously helpful for meet directors not using ClubAssistant for online registration, as it pre-populates their Meet Manager file with valid swimmer information and greatly reduces the errors introduced when typing the information in from paper forms.

    My registrar expressed a concern about releasing this Personally Identifiable Information to Meet Directors. It's not a question I've ever thought about before - this was standard practice in my previous LMSC for a number of years, but has not been done in Illinois since I became TTR and our current registrar took office. You can make, I think, a reasonable argument that joining USMS and ILMSA and providing that info doesn't give USMS or ILMSA a license to distribute that to any meet director upon request; on the other hand, the tools provide registrars the ability to obtain that information for ANY purpose.

    Has anyone worked with their registrar to develop a policy or procedure related to this?

    THANKS,

    Mike Abegg
    Illinois Masters Top Ten Recorder
    Pacific Masters Officials Chair

  2. #2
    Very Active Member jseidler's Avatar
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    Re: Registrar .re1 file and concern about PII

    Hi Mike ... the LMSC is supposed to have a privacy policy. Look at the policy and see if distributing the required information for meet directors is a permissible use of the data. The new registrar might not be aware of the policy.
    Jeanne Seidler, Wisconsin LMSC Vice Chair, Top Ten Recorder, Sanction Chair
    USMS Records and Tabulations Committee Chair

  3. #3
    Active Member rhysem's Avatar
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    Re: Registrar .re1 file and concern about PII

    Actually I don't see where the LMSC Standards or the other sections of the GTO REQUIRE an LMSC to have a Privacy Policy. Which is not to say that an LMSC shouldn't, only that there doesn't appear to be a standard that requires it.

    in light of which, I think the USMS Privacy Policy (which explicitly includes Affiliates which explicitly includes LMSCs) would be adequate policy. Although the specific answer to the question might be debatable...to my read the language doesn't clearly PERMIT nor PREVENT us from providing registration information to meet directors for athletes not registered for the meet.

    so if anyone else has had an actual discussion on this point recently, I'd love to know how it went.

    Mike

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    Re: Registrar .re1 file and concern about PII

    What is interesting is that any information you would get in the RE1 file you would receive on a paper entry form if you were not using an online vendor. I have been attending and swimming in USMS events for 37 years and I can tell you that all of the information that the RE1 file provides is the same information that the entry form makes mandatory for swimmers to enter the events. In fact in goes one step further and has address and phone number to be submitted with the entry which the RE1 file does not provide. Also the same information is provided on your USMS card that the Meet Director requests a copy of to enter the meet. I get the confidential and privacy policy but Meet Directors should be educated to not use any of this information other than to run the meet as efficiently as possible and to follow USMS Rules, Regulations, and Policys.

    In the Michigan LMSC, we host and run 15 sanction meets a year. We want to make the Meet Director experience as easy and efficient as possible. We require all meet hosts to import the RE1 file unless they use Club Assistant because you don't need to do that because that is done during the registration process. The meets in the past that have not used the RE1 file have had numerous mistakes that take time to correct and have the Top Ten Recorder, Registrar, and Meet Director trying to correct problems and errors that resulted in manually inputting data under pressure during the day of the meet during deck enter registration. Trying to read sloppy writing and entering data quickly can guarantee mistakes. This past December we encountered this because the RE1 file was not used.
    Last edited by Frank Thompson; February 14th, 2017 at 11:05 AM.
    Skip Thompson

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    Very Active Member jroddin's Avatar
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    Re: Registrar .re1 file and concern about PII

    Quote Originally Posted by Frank Thompson View Post
    What is interesting is that any information you would get in the RE1 file you would receive on a paper entry form if you were not using an online vendor. I have been attending and swimming in USMS events for 37 years and I can tell you that all of the information that the RE1 file provides is the same information that the entry form makes mandatory for swimmers to enter the events. In fact in goes one step further and has address and phone number to be submitted with the entry which the RE1 file does not provide. Also the same information is provided on your USMS card that the Meet Director requests a copy of to enter the meet. I get the confidential and privacy policy but Meet Directors should be educated to not use any of this information other than to run the meet as efficiently as possible and to follow USMS Rules, Regulations, and Policys.

    In the Michigan LMSC, we host and run 15 sanction meets a year. We want to make the Meet Director experience as easy and efficient as possible. We require all meet hosts to import the RE1 file unless they use Club Assistant because you don't need to do that because that is done during the registration process. The meets in the past that have not used the RE1 file have had numerous mistakes that take time to correct and have the Top Ten Recorder, Registrar, and Meet Director trying to correct problems and errors that resulted in manually inputting data under pressure during the day of the meet during deck enter registration. Trying to read sloppy writing and entering data quickly can guarantee mistakes. This past December we encountered this because the RE1 file was not used.
    Except that pre-populating the MM database with the RE1 file gives the meet director access to ALL swimmers from the LMSC and not just those who enter the meet. That is, somebody not entering the meet is not furnishing this data to the meet director and I think that is the question/concern that Mike has.

    Jeff

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    Re: Registrar .re1 file and concern about PII

    Quote Originally Posted by jroddin View Post
    Except that pre-populating the MM database with the RE1 file gives the meet director access to ALL swimmers from the LMSC and not just those who enter the meet. That is, somebody not entering the meet is not furnishing this data to the meet director and I think that is the question/concern that Mike has.

    Jeff
    The only thing that is confidential is the birth date and that would be a concern. You can get all the other information on the USMS website because its open to the public here by clicking on any LMSC and then clicking on the LMSC size registration.

    http://www.usms.org/lmsc/?utm_campai...local_programs

    There have been times that swimmers have left out the birth dates and I have been able to find all of them on various search engines on the internet but mostly found them on Facebook. The point I was trying to make to Mike is that all of this information has been required by Meet Directors and almost all Meet Directors require a copy of the USMS card and the birthday is furnished on it. So even if its confidential, our USMS rules require that we give this information to Meet Directors so they can run the meet. Rather than manually putting in all of the data, the RE1 file makes it easier and more efficient to run the meet.

    If the Registrar does not give the RE1 file to the Meet Director, they are not making it easier to run the meet because they will have to do all the work manually unless they have an online vendor and even then they can have access to all of the information anyway.

    The way you could protect this confidentially with birth date is to have Hytec design a way for the Registrar to have access to that 1 field in the meet file and make sure the Meet Director could not access it. Then you would have to design the USMS cards to not have the birth dates on them. Also USMS would have to stop making USMS lists on the USMS website open to the public so you could not see the swimmers full registered name, Club, and USMS #.

    I am not sure if this would be sensible with all of the IT work that would have to be performed to accomplish this confidentially.
    Skip Thompson

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    Active Member rhysem's Avatar
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    Re: Registrar .re1 file and concern about PII

    Actually Jeff hit the nail on the head - the idea that merely joining an LMSC gives Meet Directors access to the name/DOB pairing for you is where the PII concern comes from. (Swimmers registering for the meet are explicitly agreeing to provide this info to the Meet Director.) We've decided to tread carefully for now by providing this only for Meet Directors who request it and don't already use Club Assistant - at least minimizing the room for error. We'll also create a notice that will accompany the file, noting that the Meet Director must exercise caution in using the information since it contains PII.

    It would be helpful to have some acknowledgement on the National level of the concern, however, particularly since the USMS Privacy Policy can be fairly read either way on this issue.

    Mike

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