GDPR Policy

Introduction

Welcome to Honiton Swimming Club’s (“HSC”) privacy notice.

​HSC 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 HSC 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 HSC.

​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 HSC.

HSC is the controller and responsible for this website.

The HSC 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

Contact Us

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 HSC 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:

  • Identity Data – Swimmer name, date of birth, gender, sportswear size, 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, emergency contact, videos, photos, any additional comments, notes or information about a swimmer provided by you.
  • Swimmer meet results.
  • Swim England/ASA registration data for swimmers and the club workforce/volunteers.
  • Background and criminal record checks results for the club workforce/volunteers, with consent.
  • Contact Data – Parent / legal guardian name, date of birth, and contact details, such as address, email and phone number.
  • 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.
  • Profile Data includes your username and password on any member portal, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • 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:

  • 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:
    • apply for membership;
    • create an account on our website
    • enter swimming competitions; or
    • provide us with feedback.

4.How we use swimmer and parent/legal guardian personal data

​HSC uses this information for the following purposes:

  • 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;
  • For internal club record keeping;
  • To comply with national and regional sports bodies’ (e.g., Swim England/ASA) registration and membership requirements; and
  • Where we need to comply with a legal or regulatory obligation, or otherwise to protect HSC’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 HSC.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside HSC 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.

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.

  • Service providers acting as processors based in the United Kingdom who provide IT and database services for swimmers and swimming competitions,
  • Swim England and the Amateur Swimming Association.
  • 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 HSC.
  • 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