1. About this Policy
1.1 This policy explains when and why we collect personal information about our members, instructors and participants, how we use it and how we keep it secure and your rights in relation to it.
1.4 We will always comply with the 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 are we?
3. What information we collect and why.
|Type of information||Purposes||Legal basis of processing|
|Member’s name, address, telephone numbers, e-mail address(es).||Managing the Member’s membership of the Club. Managing the duty roster.||Performing the Club’s contract with the Member. For the purposes of our legitimate interests in operating the Club.|
|The names and ages of the Member’s dependants.||Managing the Member’s and their dependants’ membership of the Club.||Performing the Club’s contract with the Member.|
|Names, addresses and emergency contact details for Participants.||Contacting next of kin in the event of emergency.||Protecting Participant’s vital interests and those of their Dependants.|
|Date of birth / age related information.||Managing membership categories which are age related.||Performing the Club’s contract with the Member.|
|Gender.||Provision of adequate facilities for members.||For the purposes of our legitimate interests in making sure that we can provide sufficient and suitable facilities (including changing rooms and toilets) for each gender.|
|Reporting information to the RYA.||For the purposes of the legitimate interests of the RYA to maintain diversity data required by Sports Councils.|
|The Participant’s name, boat name and sail number.||Managing race entries and race results. Sharing race results with other clubs, class associations, and the RYA, and providing race results to local and national media. Allocating Dinghy park spaces.||For the purposes of our legitimate interests in holding races for the benefit of Participants. 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 Participants and their boats.||Putting on the Club’s website and social media pages and using in press releases.||Consent. We will seek consent on entry forms and membership application or renewal forms and individuals may withdraw their consent at any time by contacting us by e-mail or letter.|
[Deleted as we no longer use an online membership directory]
|Bank account details of the member or other person making payment to the Club.||Managing the Member’s and their dependants’ membership of the Club, the provision of services and events.||Performing the Club’s contract with the Member.|
|The member’s name and e-mail address, whilst a current member and for up to one year after ceasing to be a member of the club.||Passing to the RYA for the RYA to conduct surveys of members and former members of the Club. See paragraph 5.3 below.||For the purposes of our legitimate interests in operating the Club and / or the legitimate interests of the RYA in its capacity as the national body for all forms of boating.|
|Instructor’s name, address, email addresses, phone numbers, DBS status and relevant qualifications and/or experience.||Managing instruction at the Club.||For the purposes of our legitimate interests in ensuring that we can contact those offering instruction and provide details of instructors to members.|
|Name, e-mail address and telephone number of each Club Officer.||Information published on Club’s website, in Club’s newsletter and other publications, in the Club’s marketing materials and made available to the RYA, in each case as a point of contact at the Club.||For the purposes of our legitimate interests in operating and promoting the Club.|
|Name, e-mail address and telephone number of each Club committee member.||Information published on Club’s website.||For the purposes of our legitimate interests in operating and promoting the Club.|
|Employees and representatives of suppliers to the Club.||Entering into and managing arrangements with suppliers||Entering into and performing contracts with suppliers|
4. Data associated with use of our website
(a) If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
(b) When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
(c) If you have a website editor account and edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
4.2 Embedded content from other websites
(a) Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
4.3 Other Data
(a) For users that register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
(b) If you request a password reset, your IP address will be included in the reset email.
(c) When using our booking system, we collect and store information you submit to us when making a booking, for the purpose of reserving your requested spaces at our event and maintaining a record of attendance.
4.4 If you have an account on our website, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
5. How we protect your personal data
5.1 We will not transfer your personal data outside the UK without your consent.
5.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
5.3 Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
5.4 For any payments which we take from you online we will use a recognised online secure payment system.
5.5 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
6. Who else has access to the information you provide us?
6.1 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 required to do so by law or as set out in the table above or in paragraphs 5.2 and 5.3 below.
6.2 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 send you mailings). 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 that requires them to keep your information secure and not to use it for their own purposes. It is possible that third parties may themselves engage others (subprocessors) to process your data. Where this is the case third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own purposes.
6.3 We may also pass your personal data to the RYA for the purposes of carrying out surveys when it is in the legitimate interest of the club and the RYA to do so. The RYA may use third parties to carry out the surveys but disclose only the personal data that is necessary for the third party to do so and will have a contract in place that require the third party to keep your information secure and not to use it for their own purposes.
7. How long do we keep your information?
7.1 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 Clubs’ legitimate interest to do so or for as long as 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 the establishment exercise or defence of legal claims.
7.2 We securely destroy all financial information once we have used it and no longer need it.
8. Your rights
8.1 You have rights under the GDPR:
(a) to access your personal data
(b) to be provided with information about how your personal data is processed
(c) to have your personal data corrected
(d) to have your personal data erased in certain circumstances
(e) to object to or restrict how your personal data is processed
(f) to have your personal data transferred to yourself or to another business in certain circumstances.
8.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner:
0303 123 1113
Information Commissioner’s Office
Cheshire SK9 5AF