PRIVACY NOTICE FOR OUR MEMBERS
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 membership with us This notice applies to
you if you have registered to become or are a member of our club. 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.
References to we, our or us in this
privacy notice are to the Worthing Pier
Angling Club.
We have [not] appointed a Data
Protection Officer to oversee our compliance with data protection laws [as we
not required to do so, but our [Data Protection Compliance Manager] 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
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:
o personal contact details that allows us to contact you
directly such as name, title, email addresses and telephone numbers;
o date of birth;
o gender;
o membership start and end date;
o references and other information included in a CV or cover
letter or as part of the application process for membership;
o records of your interactions with us such as telephone
conversations, emails and other correspondence and your instructions to us;
o 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;
o [use of and movements through our online portal, passwords,
personal identification numbers, IP addresses, user names and other IT system
identifying information;]
o records of your attendance at any events hosted by us;
o CCTV footage and other information obtained through
electronic means such as swipecard and key fob records;
o images in video and/or photographic form and voice
recordings;
o your marketing preferences so that we know whether and how
we should contact you.
o identification documents such as passport and identity
cards;
o details of any county membership;
o details of next of kin, family members, coaches and
emergency contacts;
o records and assessment of any player rankings, grading or
ratings, competition results, details regarding [events/matches/games] attended
and performance (including that generated through player pathway programme);
o
any disciplinary and
grievance information
2.
SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and
use the following “special categories”
of more sensitive personal information regarding you:
o information about your race or ethnicity, religious beliefs
and sexual orientation;
o information about your health, including any medical
condition, health and sickness records, medical records and health professional
information; and
o
biometric information about
you, for example fingerprints, retina scans.
We may not collect all of the
above types of special category personal information about you. In relation to
the special category personal data that we do process we do so on the basis
that
o the processing is necessary for reasons of substantial
public interest, on a lawful basis;
o it is necessary for the establishment, exercise or defence
of legal claims;
o 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
o
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 about 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 about our members when you apply to become a member of the club,
you register an account with us at https://app.clubmate.co.uk/c/worthingpieranglingclub,
when you purchase any services or products we offer, when you make a query
and/or complaint or when you correspond with us by phone, e-mail or in some
other way.
We also may collect personal
information about you from any third party references you provide as part of
the application process for membership.
If you are providing us with
details of referees, next of kin, beneficiaries, 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.
4.
Uses made of the 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 you
have with us and managing our relationship with you, including dealing with
payments and any support, service or product enquiries made by you |
All contact and membership details, transaction and payment
information, records of your interactions with us, and marketing preferences. |
This is necessary to enable us to properly manage and
administer your membership contract with us. |
|
To arrange and manage any
contracts for the provision of any services or products |
Contact details, transaction and payment information. Records of your interactions with us. |
This is necessary to enable us to properly administer and
perform any contract for the provision of any services and products you have
purchased from us. |
|
To send you information which is
included within your membership benefits package, including details about
advanced ticket information, competitions and events, partner offers and
discounts and any updates of fishing |
Contact and membership details. |
This is necessary to enable us to properly manage and
administer your membership contract with us. |
|
To send you other marketing
information we think you might find useful or which you have requested from
us, including our newsletters, information about membership, events, products
and information about our commercial partners |
Contact details and marketing preferences. |
Where you have given us your explicit consent to do so. |
|
To answer 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 your membership. |
|
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 your membership and run
our club 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. |
|
The security of our IT systems |
Your usage of our IT systems and online portals. |
We have a legitimate interest to ensure that our IT systems
are secure. |
|
To conduct data analytics
studies to better understand event attendance and trends within the sport |
Records of your attendance at any events or competitions
hosted by us. |
We have a legitimate interest in doing so to ensure that
our membership is targeted and relevant. |
|
For the purposes of promoting
the club, our events and membership packages. |
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 |
Records of attendance, CCTV footage and other information
obtained through electronic means such as swipecard and key fob records,
medical information about your health [biometric
information about you, for example fingerprints, retina scans] |
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 administer your attendance at
any courses or programmes you sign up to |
All contact and membership details, transaction and payment data. Details of any county membership and performance data. |
This is necessary to enable us to register you on to and
properly manage and administer your attendance on the course and/or
programme. |
|
To arrange for any trip or
transportation to and from an event |
Identification documents details of next of kin, family members
and emergency contacts, transaction and payment information, health and
medical information. |
This is necessary to enable us to make the necessary
arrangements for the trip and/or transportation to an event. 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 assess your fitness to participate in
any events or activities we host and to provide appropriate adjustments to
our sports facilities. |
Health and medical information |
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 gather evidence for possible
grievance or disciplinary hearings |
All the personal information we collect |
We have a legitimate interest in doing so to provide a safe
and fair environment for all members and to ensure the effective management
of any disciplinary hearings, appeals and adjudications. 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. |
|
For the purposes of equal
opportunities monitoring |
Name, title, date of birth gender, information about your race or ethnicity and health
and medical 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 comply with legal
obligations, for example, regarding people working with children or
vulnerable adults to comply with our safeguarding requirements |
Information about your criminal convictions and offences |
|
|
|
|
|
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 and we may have to terminate your membership. 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 member benefits to you.
5.
DIRECT MARKETING
Email, post and SMS marketing: from time to time, we may contact you by email, post or
SMS 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
via https://app.clubmate.co.uk/c/worthingpieranglingclub.
6.
Disclosure of your PERSONAL
information
We share personal information
with the following parties:
o Any party
approved by you.
o To any governing
bodies or regional bodies for the sports covered by our club: to allow them to properly administer the sports on a
local, regional and national level.
o Other service
providers: for example, email marketing
specialists, payment processors, data analysis CCTV contractors, promotional
advisors, contractors or suppliers and IT services (including CRM, website,
video- and teleconference services);
o Our supply chain partners and sub-contractors, such as
couriers, import/export agents, shippers,
o Our Commercial
Partners: 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
o The Government or
our regulators: where we are required to
do so by law or to assist with their investigations or initiatives.
o Police, law
enforcement and security services: to
assist with the investigation and prevention of crime and the protection of
national security
7.
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 or the end of your membership. Exceptions to this rule are:
o 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;
o Details regarding unsuccessful membership applicants where
we hold records for a period of not more than 12 months;
o
Information that may
be relevant to personal injury or 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.
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 our membership portal. Alternatively, you
can contact us by using the details set out in the "Contacting us" section below.
8.
YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights
in relation to your personal information:
o the right to be informed about how your personal
information is being used;
o the right to access the personal information we hold about
you;
o the right to request the correction of inaccurate personal
information we hold about you;
o the right to request the erasure of your personal
information in certain limited circumstances;
o the right to restrict processing of your personal
information where certain requirements are met;
o the right to object to the processing of your personal
information;
o the right to request that we transfer elements of your data
either to you or another service provider; and
o
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 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.
9.
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.
In the event of any query or
complaint in connection with the information we hold about you, please email simon.clark90@yahoo.co.uk
or write to us at 14 Radnor rd, Worthing BN13 1DN