Exeter City Swimming Club: Privacy Policy
Introduction
Welcome to Exeter City Swimming Club's ("ECSC") privacy notice. ECSC is an unincorporated charity established by constitution adopted 25 July 2005 and amended 6 August 2007.
ECSC respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
1.Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how ECSC collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service from us or take part in a competition or offer run by ECSC.
We collect data relating to children and at the end of this notice we have set out details of our policies on data we hold about children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
This privacy notice is issued on behalf of ECSC.
ECSC is the controller and responsible for this website.
The ECSC Committee is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact The Club Secretary using the details set out below.
Contact details
Full name: Exeter City Swimming Club:
Email address: info@exeterswimming.com
Postal address: 31 Seymour Road, Newton Abbot, TQ12 2PT
Telephone number: 07710443007
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
The data protection law in the UK changed on 25 May 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2.The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
What personal information does ECSC collect about you?
We may collect, use, store and transfer different kinds of personal data about our swimmers and their parents/guardians which we have grouped together as follows:
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Identity Data - Swimmer name, date of birth, gender, sportswear size and other measurements, physician name and contact details, medical information and biometric data (if relevant and with parental consent), information about club membership and membership in sports bodies and associations, ability group, attendance history, competition results, medical insurance information, emergency contact, videos, photos, any additional comments, notes or information about a swimmer provided by you.
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Swimmer meet results.
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Swim England/ASA registration data for swimmers and the club workforce/volunteers.
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Background and criminal record checks results for the club workforce/volunteers, with consent.
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Contact Data - Parent / legal guardian name, date of birth, and contact details, such as address, email and phone number.
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Financial Data - including bank account and payment card details.
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Transaction Data - including details about payments to and from you and other details of products and services you have purchased from us, including gift aid.
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Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
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Profile Data includes your username and password on any member portal, purchases or orders made by you, your interests, preferences, feedback and survey responses.
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Usage Data includes information about how you use our website and services.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you (i.e. your or your swimmer’s membership with the club) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with normal services offered to club members). In this case, we may have to cancel your or your swimmer’s membership, but we will notify you if this is the case at the time.
3.How is your personal data collected?
We use different methods to collect data from and about you/your swimmer including through:
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Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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apply for membership;
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create an account on our website or on one of our third-party servicer provider websites, such as TeamUnify;
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enter swimming competitions; or
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provide us with feedback.
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Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
4.How we use swimmer and parent/legal guardian personal data
ECSC uses this information for the following purposes:
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To operate the club and allow swimmers and their parents / guardians to easily register for and attend swim meets, sign up for jobs, access swim time histories and swimming practice photos and videos, practice management, for event management, communication, billing and collection of fees, and other services they request (whether via a service provider, such as TeamUnify, or otherwise through ECSC’s own hosted website platform);
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For internal club record keeping;
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To comply with national and regional sports bodies’ (e.g., Swim England/ASA) registration and membership requirements; and
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Where we need to comply with a legal or regulatory obligation, or otherwise to protect ECSC’s legal rights or to prevent fraud or illegal activity.
Marketing
You have the right to withdraw consent to marketing at any time by contacting us on the contact details provided at paragraph 1 above. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your general membership of ECSC.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside ECSC for marketing purposes.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy for further details.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5.Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
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Service providers acting as processors based in the United Kingdom who provide IT and database services for swimmers and swimming competitions, such as TeamUnify.
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Swim England and the Amateur Swimming Association.
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Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services to ECSC.
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HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6.Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to the club workforce/volunteers, committee members and other third parties who have a legitimate need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7.Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or accounting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
By law we have to keep basic information about our paying members (including Contact, Identity, Financial and Transaction Data) for six years after they cease being paying members for tax purposes.
In some circumstances you can ask us to delete your personal data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8.Your legal rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.