PRIVACY NOTICE FOR OUR MEMBERS We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your membership with us. This notice applies to you if you have registered to become or are a member of our club. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information. References to we, our or us in this privacy notice are to Kidlington & Gosford Swimming Club.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Administration Secretary has overall responsibility for data protection compliance in our organisation.
1. PERSONAL INFORMATION WE COLLECT FROM YOU Depending on the type of membership you register for with us, you may initially provide us with or we may obtain personal information about you, such as information regarding your:
personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers;
date of birth;
membership start and end date;
use of our members only area of our web site via passwords.
records of your attendance.
images in video and/or photographic form.
details of next of kin, family members, coaches and emergency contacts;
records and assessment of any swim rankings, grading or ratings, competition results, details regarding Meets attended and performance
2. SPECIAL CATEGORIES OF PERSONAL INFORMATION We also collect, store and use the following “special categories” of more sensitive personal information regarding you:
information about your health, including any medical condition we need to be aware of for Health & Safety reasons.
3. WHERE WE COLLECT YOUR INFORMATION We typically collect personal information about our members when you apply to become a member of the club, If you are providing us with details of next of kin, carers, family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.
4. USES MADE OF THE INFORMATION Below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.
Purpose: To administer any membership you have with us and managing our relationship with you,
Personal information used: All contact and membership details
Lawful basis: This is necessary to enable us to properly manage and administer your membership with us.
Purpose: To send you information which is beneficial to your membership, including details about competitions and events, and any updates on swimming.
Personal information used: Contact and membership details.
Lawful basis: This is necessary to enable us to properly manage and administer your membership.
Purpose: To send you other information we think you might find useful including our newsletters, information about membership, events, products.
Personal Information used: Contact details and Membership details.
Lawful Basis: Where you have given us consent to do so.
Purpose: To answer your queries or complaints
Personal information used: Contact details and records of your interactions with us
Lawful basis: We have a legitimate interest to provide complaint handling services to you in case there are any issues with your membership.
Purpose: Retention of records
Personal information used: All the personal information we collect.
Lawful basis: We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your membership and run our club and in some cases we may have legal or regulatory obligations to retain records.
Purpose:The security of our IT/SCM systems
Personal information used: Contact details and records.
Lawful basis: We have a legitimate interest to ensure that our IT systems are secure.
Purpose: To conduct data analytics studies to better understand event attendance and trends within the sport
Personal information used: Records of your attendance at any events or competitions
Lawful basis: We have a legitimate interest in doing so to ensure that our membership is targeted and relevant.
Purpose: For the purposes of promoting the club, our events and membership packages.
Personal information used: Images in video and/or photographic form.
Lawful basis: Where you have given us your consent to do so
Purpose: To comply with health and safety requirements
Personal information used: Records of attendance, medical information about your health
Lawful basis: We have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate in sport.
Purpose: To administer your attendance at any courses or programmes you sign up to e.g. coaching or official workshops etc
Personal information used: All contact and membership details. Details of any county membership and performance data.
Lawful basis: This is necessary to enable us to register you on to and properly manage and administer your attendance on the course and/or programme.
Purpose: To arrange for any trip or transportation to and from an event
Personal information used: Identification documents details of next of kin, family members and emergency contacts, health and medical information.
Lawful basis: This is necessary to enable us to make the necessary arrangements for the trip and/or transportation to an event.
Purpose: To use information about your physical or mental health (including any injuries) or disability status, to ensure your health and safety and to assess your fitness to participate in any events or activities.
Personal information used: Health and medical information
Lawful basis: We have a legitimate interest in doing so to provide a safe swimming environment
Purpose: To gather evidence for possible grievance or disciplinary hearings
Personal information used: All the personal information we collect
Lawful basis: We have a legitimate interest in doing so to provide a safe and fair environment for all members and to ensure the effective management of any disciplinary hearings, appeals and adjudications.
Purpose: To comply with legal obligations, for example, regarding people working with children or vulnerable adults to comply with our safeguarding requirements
Personal information used: Information about your criminal convictions and offences
Lawful basis: For DBS records we process it on the basis of legal obligations or based on your explicit consent.
For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to admit you as a member or comply with legal obligations and we may have to terminate your membership. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our ‘contract’ with you. Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time. Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain member benefits to you.
5. DIRECT MARKETING e-mail marketing: from time to time, we may contact you by email with information about forthcoming events we believe you may be interested in. You can then let us know at any time that you do not wish to receive marketing messages by contacting the administration secretary. 6. DISCLOSURE OF YOUR PERSONAL INFORMATION We do not share your personal information with any commercial third parties,only with the following parties:
To any governing bodies or regional bodies for swimming: to allow them to properly administer swimming on a local, regional and national level.
The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY The personal information we collect is not transferred to and stored in countries outside of the UK and the European Union.
8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR? The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 6 years after your last contact with us or the end of your membership. Exceptions to this rule are:
Details regarding unsuccessful membership applicants where we hold records for a period of not more than 12 months;
Information that may be relevant to personal injury claims may be retained until the limitation period for those types of claims has expired. For personal injury claims this can be an extended period as the limitation period might not start to run until a long time after the event.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address.
9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION You have the following rights in relation to your personal information:
the right to be informed about how your personal information is being used;
the right to access the personal information we hold about you;
the right to request the correction of inaccurate personal information we hold about you;
the right to request the erasure of your personal information in certain limited circumstances;
the right to restrict processing of your personal information where certain requirements are met;
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/. To exercise any of the above rights, or if you have any questions relating to your rights, please contact us. If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.
10. CHANGES TO THIS NOTICE We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.