Data Privacy Policy

 

  1. About this Policy
    1. This policy explains when and why we collect personal information about the members and coaches, how we use it and how we keep it secure and your rights in relation to this.
    2. We may collect, use and store your personal data, as described in this Data Privacy Policy and as described when we collect data from you.
    3. We reserve the right to amend this Data Privacy Policy from time to time without prior notice.  You are advised to check our website or check our club noticeboard regularly for any amendments.
    4. We will always comply with General Data Protection Regulation (GDPR) when dealing with your personal data.  Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk).  For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
  2. Who we are
    1. We are Gravesend and Northfleet Swimming Club (GNSC).  We can be contacted at [email protected]
  3. What information we collect and why

Types of Information

Purposes

Legal basis of processing

Swimmer’s name, address, telephone numbers, email address(es)

Managing the Member’s membership of the club.

Performing the Club’s contract with the member.

For the purposes of our legitimate interests in operating the club.

Parent’s name, address, telephone number, email address(es)

Managing the Member’s membership of the club

Performing the Club’s contract with the member.

For the purposes of our legitimate interests in operating the club

Emergency contact details

Contacting next of kin in the event of an emergency.

Protecting the swimmer’s interest.

Date of birth/age related information.

Managing swimming/race categories which are age related.

Performing the club’s contract with the swimmers.

Gender

Provision of adequate facilities for swimmers.

For the purposes of our legitimate interest in making sure that we provide sufficient and suitable facilities (including changing rooms and toilets) for each gender and for chaperones at race meets.

For the purposes of the legitimate interests to maintain diversity data required by the Sports Council.

The swimmers SWIM ENGLAND number

Managing race entries and race results. 

Sharing race results with other clubs, swimming club associations and On Deck app.

For the purposes of our legitimate interests in holding and attending race meets for the benefit of members of the Club.

For the purposes of our legitimate interests in promoting the Club.

For the purposes of our legitimate interests in operating the Club.

Photos and videos of swimmers.

Putting on the Club’s website and social media pages and from time to time press releases.

Consent.  We will seek the member’s consent on their membership application form and each membership renewal form and the member may withdraw their consent at any time by contacting us by either email or letter.

The Member and parent/carer name and email address

Creating and managing the Club’s online membership directory.

Consent.  We will seek the member’s consent on their membership application form and each membership renewal form.  The member may withdraw their consent at any time by contacting us by email or letter to tell us that they no longer wish to appear in the membership directory. (Excel and On Deck)

Bank Account details of the members or other person making payment to the cub.

Managing the members and the parents membership of the club, the provision of services and events.

Performing the club’s contract with the member

The member’s name and email address whilst a current member and for up to 1 year after ceasing to be a member of the club.

Membership Co-ordinator to conduct a survey of member and former members of the club. (See paragraph 5.3)

For the purposes of our legitimate interests in operating the club.

Coaches and teachers name, address, email addresses, phone number and relevant qualifications and/or experience.

Managing instruction at the club for Swim Mark Quality Mark.

For the purposes of our legitimate interests in ensuring that we can contact those offering coaching/teaching and provide details of coaches to members.

Name, email address and telephone number of each club officer.

Information published on the club’s website, newsletter and other publications in the marketing materials in each case being a point of contact at the club.

For the purposes of our legitimate interests in operating and promoting the club.

Name, email address and telephone number of each club committee member.

Information published on the club’s website.

For the purposes of our legitimate interests in operating and promoting the club.

 

  1. How will we protect your data?
    1. We will have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse or unauthorised alteration of destruction.  Paper copies to be kept in a locked cabinet in a locked cupboard and any IT data will be password protected with only access by committee personnel.   
    2. Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
    3. For any payments which we take from you online we will use a recognised online secure payment system.
    4. We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
  2. Who else has access to the information you provide us?
    1. We will never sell your personal data.  We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where we are required to do so by law or set out in the table above or in paragraphs 5.2 and 5.3 below.
    2. We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf e.g. to print newsletters and to send you mailings.  We do this for the purpose of our legitimate interests in operating the club and for performing our contract with you.  However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place to keep your information secure and not to use it for their own purposes.  It is possible that third parties may themselves engage others (sub processors) to process your data.  Where this is the case third parties will be required to have contractual arrangements with their sub processors that ensure your information is kept secure and not used for their own purposes. 
    3. We may also pass your personal data to the SWIM ENGLAND for the purposes of carrying out surveys when it is in the legitimate interests of the club to do so.  If a third party is used to conduct the surveys, we will only disclose personal date that is necessary for the third party to do so and will have a contract in place that require the third party your keep your information secure and not to use it for their own purposes. 
    4. Member information is stored and used within the swim application that the club uses to manage the club. This application is provided by TeamUnify and has a website and phone application called OnDeck. 
  3. How long do we keep your information?
    1. We will hold your personal data on our systems for as long as you are a member of the Club and for as long afterwards as it is in the Club’s legitimate interest to do so or for as long as it is necessary to comply with our legal obligations.  We will review your personal data every year to establish whether we are still entitled to process it.  If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and establishment, exercise or defence of legal claims.
    2. We securely destroy all financial information once we have used it and no longer need it.
  4. Your rights
    1. You have rights under the GDPR
      1. To access your personal data
      2. To be provided with information about how your personal data is processed
      3. To have your personal data corrected
      4. To have your personal data erased in certain circumstances
      5. To object to or restrict how your personal data is processed.
      6. To have your personal data transferred to yourself or to another business in certain circumstances.
    2. You have the right to take any complaints about how we process your personal data to the Information Commissioner:

https://ico.org.uk/concerns

0303 123 1113

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

For more details, please address any questions, comments and requests regarding our data processing practices to our Data Protection Manager via [email protected]