The Data Protection Act 2018 controls how your personal information is used by organisations and is the UK’s implementation of the EU’s General Data Protection Regulations (GDPR).
Everyone responsible for using personal data has to follow strict rules called ‘data protection principles’. They must make sure the information is:
- used fairly, lawfully and transparently
- used for specified, explicit and legitimate purposes
- used in a way that is adequate, relevant and limited to only what is necessary
- accurate and, where necessary, kept up to date
- kept for no longer than is necessary
- handled in a way that ensures appropriate security, including protection against unlawful or authorised processing, access, loss, destruction or damage
References to We, Our, or Us, in this privacy notice are to Brighton Swimming Club
This notice applies to athletes, parents/guardians, coaches and volunteers if you have registered to become, or are, a member of our club. It explains:
- how we may use the personal information we collect before, during and after your membership with us.
- what your rights are for the purposes of data protection.
- how we comply with the law on data protection
- what your rights are.
For the purpose of the Data Protection Act 2018, the Data Controller of any of your personal information is Brighton Swimming Club.
We are not required to appoint a Data Protection Officer.
This policy outlines the types of personal data Brighton Swimming Club may store and use and store
Any questions regarding this policy, our privacy practices, query or complaint should be sent to the Club Hon. Secretary – email@example.com
Personal information we may 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;
- records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us; any credit/debit card and other payment details you provide so that we can receive payments from you and details of the financial transactions with you;
- records of your attendance at any events hosted by us;
- images in video and/or photographic form and voice recordings;
- your marketing preferences so that we know whether and how we should contact you.
- identification documents such as passport and identity cards;
- details of next of kin, family members, coaches and emergency contacts;
- records and assessment of any swimmer rankings, gradings or ratings, competition results, details regarding galas attended, performance and qualifications.
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 we may not be able to properly perform our contract with you or comply with legal obligations.
There may be other personal information that you are not obliged to provide to us, but if you do not provide it then we may not be able to properly perform our contract with you.
You can withdraw your consent and request erasure of your data at any time prior to the completion of your membership application which you may do by contacting us as described above.
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, which you may do by contacting us as described above.
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.
Special categories of personal information
We may also collect, store and use the following ‘special category data’ about you:
- information about your race or ethnicity and gender
- medical information about you which is collected purely for the purpose of ensuring your health and safety when competing and which will not be transferred to any third party save as specifically authorised by you, or in a medical emergency.
- information about any relevant impairments that you may have.
We may not collect all of the above types of ‘special category data’ about you however, if we do process such data it will be on the basis that:
- the processing is necessary for reasons of substantial public interest, on a lawful basis;
- it is necessary for the establishment, exercise or defence of legal claims;
- it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or based on your explicit consent.
For volunteers we may also collect criminal records information from/about you, this will be completed by the use of the Disclosure Barring Service.
16 or Under
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
Where we collect your information
We typically collect personal information about our members when you apply to become a member of the Club, when you take part in a competition controlled either by us or by another organisation, when you work as a volunteer for us, or when you purchase products and services from us, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.
In becoming a registered athlete, coach, official or volunteer, you will provide certain information to third parties including Swim England, Swim England Southeast Region, Institute of Swimming, and British Swimming. This information may be shared with us.
If you are providing us with details of next of kin, 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.
Summary of types of data used
|Purpose||Perform our Contract with you||Comply with Legal Obligations||Pursue Legitimate Interests||Personal Information Used|
|Administer membership and maintain relationship||X||X||Contact and membership details, transaction and payment information, records of your interactions with us and marketing preferences.|
|Marketing Information e.g. ticket information, competitions, partner offers and discounts, and updates on swimming||X||Contact and membership details, marketing preferences.|
|To deal with queries or complaints||X||X||Contact details, records of your interaction with us.|
|Retention of records||X||X||X||All the personal information we collect|
|Data analytics – record keeping, research and analysis||X||Records of attendance and performance at events or competitions|
|Promotion of club activity and athlete success||X||Images in video and/or photographic form where you have given us your explicit consent to do so.|
|To comply with health and safety requirements||X||X||X||Contact and membership details. Special category information.|
|Ensure safeguarding and wellbeing of members in relation to medical history||X||X||X||Contact and membership details. Special category information. DBS information.|
|For the purpose of equal opportunities monitoring||X||X||Contact and membership details. Special category data.|
|Maintain contract requirements for employed members||X||X||X||Contract of Employment.|
|Emergency contacts||X||X||Next of Kin / emergency contact details|
How and why your information is used
The table below describes the main purposes for which we process your personal information, the categories of your information involved and the lawful basis for being able to do this.
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:
- Specific consent – where you have provided specific consent to us using your personal information in a certain way, such as to send you email or texts.
- Legitimate Interest – to send information on activities and events which have been arranged as part of membership.
- Performance of a contract – to allow us to provide member services associated with the day to day running of the club and its activities such as requests for payments, registers, and fees.
- Legal obligation – to fulfil legal obligations for health and safety, insurance and child protection purposes.
Disclosure of your personal information
Personal information may be shared with the following:
- Any party approved by you;
- To the governing body (Swim England) or regional body or county affiliation to allow them to properly administer the sport on a local, regional and national level;
- Other service providers and advisors: for example, email marketing specialists, payment processes, professional advisors, data analysis and IT services (including CRM, website, video and teleconference services);
- External funding providers;
- Our Partners and Activity Providers;
- 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.
In addition to this, any event which you enter into may process and hold personal data which is required in order for you to participate.
This policy does not cover how your data is processed in relation to external bodies.
Transferring your personal information internationally
Your personal information is not transferred to and stored in countries outside of the UK and the European Union.
Retention of personal information
The duration for which personal information is retained will differ depending on the type of information and the reason why it is collected 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 requirements we retain all physical and electronic records for a period of 2 years after your last contact with us OR 2 years beyond the duration 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 or discrimination claims which may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation might not start to run until a long time after the event.
- We will continue to store individuals’ performance data which form part of the club’s competitive records.
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. You may be able to update some of the personal information we hold about you through the ‘Contact Us’ details given above.
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 held about you;
- The right to request the correction of inaccurate personal information held 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;
- The right to object to the processing of your personal information;
- The right to request the transfer of elements of your data either to you or another service provider;
- The right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However some rights have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.
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’ by using the details given above.
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.
Changes to this notice
This privacy notice may be updated from time to time. When a change to this notice is made in a material way, the version date at the bottom of this page will be updated. For significant changes to this notice, reasonable notice will be given 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.
Date: 21 January 2022