Privacy Notice for County
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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 relationship with us. 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
This notice applies to you if you are either:
- an individual or club member who has contacted us to receive updates about funding, information on upcoming competition(s) / event(s) / course(s) and other ways to get involved further with sport in your County;
- a participant at one of our partner led development events or workshops [NB. often data is collected by us through feedback forms at the competition(s) / event(s) / course(s), but where only the delivery partner is data controller of the personal data for the participant and we are simply processing lists of attendee’s personal data on behalf of the partner we will not send a privacy notice to the participant]; or
- an individual client (such as a sole trader or partnership) or an employee of a corporate client who (i) has contacted us to purchase our services/products; or (ii) we have contacted you about the services/products we offer.
- any others?
References to we, our or us in this privacy notice are to Somerset ASA (postal address c/o the County Secretary).
We are appointing a Data Protection Officer to oversee our compliance with data protection laws who has overall responsibility for data protection compliance in our organisation. Contact details are set out in the "Contacting us" section at the end of this privacy notice.
1. Personal Information We May Collect From You
You may provide us with or we may obtain personal information about you, such as information regarding your:
- personal contact details that allow us to contact you directly such as name, title, addresses, email addresses and telephone numbers;
- date of birth;
- gender;
- any identification documents;
- details of family members and emergency contacts;
- records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
- details you provide about your experience in the sport and your interests in getting further involved in the sport;
- any feedback you provide in a survey;
- records of your attendance at any events, competitions or workshops delivered by us or our sports partners;
- images in video and/or photographic form and voice recordings;
- any payment or bank details you provide so that we can receive payments from you or you can receive funding from us and details of the financial transactions with you;
- use of and movements through our online portal, passwords, personal identification numbers, IP addresses, user names and other IT system identifying information;
- any funding application details;
- all information included as part of an application process;
- performance including any feedback provided to us by yourself, members of staff or other third parties;
- the location in which you participate in competition / event / workshop activities;
- your marketing preferences so that we know whether and how we should contact you;
2. Special Categories of Personal Information
We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:
- information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
- information about your trade union memberships
- information about your health, including any medical condition, health and sickness records, medical records and health professional information, medications and treatment; and
- biometric information about you, for example fingerprints, retina scans.
We may not collect all of the above types of special category information about you. In relation to the special category personal data that we do process we do so 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.
In the table below, we refer to these as the “special category reasons for processing of your personal data”.
We may also collect criminal records information from you. For criminal records history we process it on the basis of legal obligations or based on your explicit consent.
3. Where We Collect Your Information
We typically collect personal information when you
- create an account on our website www.somersetasa.org;
- sign up for our newsletter;
- make an application for funding;
- make a query and/or complaint;
- correspond with us by phone, e-mail or in some other way;
- attend one of the competitions, events or workshops hosted by us or one of our delivery partners and/or activity providers;
- apply to become a member or temporary member, either directly from
- you, and / or
- the ASA (which includes its subsidiaries), Swim England and British Swimming which each hold details provided on your membership registration form with other information they hold ; or obtained from or about you, and / or
- your affiliated Swim England Club, League, Association (Somerset list) and / or
- your affiliated Swim England Region (South West link)
We may sometimes collect additional personal information
- from third parties including former clubs or other organisations you may have volunteered for or via background check agencies
- throughout the period of your membership
- from any third party references you provide as part of an application process or
- from any feedback provided to us about your performance whilst participating in a competition / event / workshop or as a volunteer.
4. Uses Made of Your Personal Information
The table 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 | Personal information used | Lawful basis |
---|---|---|
To administer any membership account(s) you have with us and managing our relationship with you, including dealing with enquiries made by you | All contact details, records of your interactions with us, and marketing preferences. Use of and movements through our online portal. |
This is necessary to enable us to properly manage and administer your account with us. |
To send you marketing information we think you might find useful or which you have requested from us, including our newsletters, information about competitions / events / workshops and and any offers from or about our partners and activity providers to further progress your interest in the sport. | Contact details and marketing preferences. Details you provide about your experience in the sport and, your interests in getting further involved in the sport; |
Where you have given us your consent to do so. |
To deal with your queries or complaints. | Contact details and records of your interactions with us. | We have a legitimate interest to provide complaint handling services to you in case there are any issues with the service we provide. |
Retention of records | All the personal information we collect. | 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 any account you have with us and in some cases we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
To conduct data analytics studies to better understand competition / event / workshop attendance and trends within sport in the County | Records of your attendance at any competitions / events / workshops hosted by us and/or our delivery partners | We have a legitimate interest in doing so to ensure that our competitions, events and workshops continue to improve and are targeted and relevant. |
To produce and maintain our website and for the purposes of promoting sport in the County and beyond, our campaigns and events and the work we do as a County body. | Images in video and/or photographic form and voice recordings. | Where you have given us your explicit consent to do so. [Note: We follow Wavepower best practice and obtain consents where we intend to use any images or footage of participants in any promotional campaigns, particularly where there are children involved.] |
To comply with health and safety requirements | Records of attendance and health and medical information | 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. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To use information about your physical or mental health (including any injuries) or disability status, to ensure your health and safety and to provide appropriate adjustments to our sports facilities. | Health information including any medical condition, medications and treatment. |
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
For the purposes of equal opportunities monitoring | Name, title, date of birth; gender, information about your race or ethnicity, and health information. | We have a legitimate interest to promote a sports environment that is inclusive, fair and accessible. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To administer your attendance at any competitions, events, courses or programmes you sign up to, for drug and alcohol testing and to assess your suitability for any activities or events we host. | All contact details. Date of birth, gender, health and medical information. Details of family members and emergency contacts. |
This is necessary to enable us to register you on to and and arrange for the effective delivery of our development programmes and events. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To manage the process of applying to us for funding | All details provided in your funding application. | This is necessary to enable us to properly manage and assess your application. |
To make payments to you where we have agreed to fund a project | Transaction and payment data | This is necessary to make payments to you. |
To arrange and manage contracts for the provision of services / products | Transaction and payment data, contact details | This is necessary to enable us to properly manage and perform any contract for services and products. |
To comply with legal obligations, for example, regarding people working with children or vulnerable adults. | Information about your criminal convictions and offences. | For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
[Insert any other processing activities] |
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 of our body or we may not be able to properly perform our arrangements with you or comply with legal obligations and we may have to terminate your position as a member of our body. 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, which you may do by contacting us as described in the "Contacting us" section below.
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 benefits to you.
5 Direct Marketing
Email, post, SMS, MMS, RCS marketing: from time to time, we may contact you by email, post, SMS, MMS, RCS with information about products and services we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages by completing this form [link] / emailing the County Secretary (link to contact details]. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.
6. Disclosure of Your Personal Information
We share personal information with the following parties:
- Any party approved by you.
- To any governing bodies or regional bodies or affilated Clubs for the sports covered by our County to allow them to properly administer the sports on a local, regional and national level.
- Other service providers and advisors: for example, email marketing specialists, payment processors, professional advisors, data analysts, CCTV contractors and IT services (including Customer Relationship Management, membership administration, competition, website, video and tele-conference services);
- External funding providers: for the purposes of assessing and administering grants and funding.
- Our supply chain partners and sub-contractors, such as couriers, import / export agents, shippers,
- Our Partners and Activity Providers: for the purposes of providing you with information on any tickets, special offers, opportunities, products and services and other commercial benefits provided by our commercial partners where you have given your express consent for us to do so and / or for the purposes of arranging any competitions, events or workshops you have registered your interest in.
- 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.
- [any others]
We do not disclose personal information to anyone else except as set out above.
7 Transferring Your Personal Data Internationally
The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws. For further details please contact us by using the details set out in the "Contacting us" section below.
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.
Exceptions to this rule are:
- CCTV records which are held for no more than 30 days unless we need to preserve the records for the purpose of prevention and detection of crime; and
- Information that may be relevant to personal injury claims, discrimination claims 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 period might not start to run until a long time after the event.
- Information that may be relevant to projects that we fund may be retained for longer periods in order to allow us to assess the longer-term impact of our support for sports projects.
- [any others]
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 Swim England Online Membership System. Alternatively, you can contact us by using the details set out in the "Contacting us" section below.
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;
- the right to object to the processing of your personal information;
- the right to request that we transfer elements of your data either to you or another service provider; and
- 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 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 use this Web Form for Data Subject Requests which will be processed on receipt via our Privacy Portal, or you may contact us by using the details set out in the "Contacting us" section below.
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.
11 Contacting Us
In the event of any query or complaint in connection with the information we hold about you, please email the County Secretary (link) or write to The County Secretary at Rose Cottage, Nortons Wood Lane, Clevedon BS21 7AE.
Draft Version for 25 May 2018