Privacy Policy
PRIVACY NOTICE FOR All EKGC 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.
We do not sell or rent or otherwise pass on your personal information to any organisation, unless you expressly ask us to.
References to we, our or us in this privacy notice are to
East Kilbride Gymnastics Club
References to you in this privacy notice are to you yourself, the parent/carer, and/or the child member of the club.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so.
- 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:
- personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers;
- date of birth;
- gender;
- membership start and end date;
- records of your attendance at any events hosted by us;
- CCTV footage and other information obtained through electronic means;
- images in video and/or photographic form
- details of any BG/SGA membership;
- details of next of kin, family members and emergency contacts;
- records and assessment of any competition rankings, grading or ratings, competition results, details regarding events attended and performance (including that generated through performance pathway programmes);
- any disciplinary and grievance information;
We may collect and process the following data about you:
- Information provided voluntarily by you. For example, when you register for information, apply for a particular service or make a comment or complaint
- Information that you provide when you communicate with us by any means such as email, letter or telephone call
- SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:
- information about your childs health, including any medical condition, health and sickness records, medical records and health professional information as provided either directly by you or from information that you supply to Scottish Gymnastics/British Gymnastics.
- 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
- the processing is necessary for reasons of substantial public interest, on a lawful basis;
- it is necessary for the establishment, exercise or defence of legal claims;
- 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
- based on your explicit consent.
In the table below’ we refer to these as the “special category reasons for processing of your personal data”.
- 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 as a member of the club, 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 British Gymnastics, especially emergency contact details, any allergy or health issues that may affect performance/behaviour in the club.
If you are providing us with details of family members and emergency contacts they have a right to know and to be aware of the 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.
- 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 package, including details about competitions and events, fundraising activities, partner offers and discounts and any updates on club matters or British Gymnastics information.
Contact and membership details.
This is necessary to enable us to properly manage and administer your membership contract with us.
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.
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.
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, medical information about your health
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 classes, courses or programmes you sign up to
All contact and membership details,
transaction and payment data.
Details of any squad 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.
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 criminal convictions and offences
For criminal records history we process it on the basis of legal obligations or based on your explicit consent.
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.
The information provided will be sensitively saved and destroyed according to our statutory requirements and retention policy.
- DISCLOSURE OF YOUR PERSONAL INFORMATION
We share personal information with the following parties:
- Any party approved by you.
- British Gymnastics and Scottish Gymnastics: to allow them to properly administer the sports on a local, regional and national level.
- Other service providers: for example, payment processors, CCTV contractors;
- The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
- Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
6. 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:
- CCTV records which are held for no more than 28 days unless we need to preserve the records for the purpose of prevention and detection of crime;
- Details regarding applicants where membership is not taken up, where we hold records for a period of not more than 12 months;
- 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 can contact us by using the details set out in the “Contacting us” section below.
7. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal information:
- the right to be informed about how your personal information is being used;
- the right to access the personal information we hold about you;
- the right to request the correction of inaccurate personal information we hold about you;
- the right to request the erasure of your personal information in certain limited circumstances;
- the right to restrict processing of your personal information where certain requirements are met;
- the right to object to the processing of 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. 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.
8. 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.
9. CONTACTING US
In the event of any query or complaint in connection with the information we hold about you, please contact the club directly:
E-mail – information@ekgc.org
Where the processing of your personal data is based on your consent, in most circumstances you have the right to withdraw that consent at any time and the Club will act on your instructions.
If you have any concerns about how we process your personal data or wish to discuss how to exercise your rights, you should contact the Club using the contact details above.
Alternatively, you may wish to complain directly to the Information Commissioners Office. You can do this by writing to them at:
Information Commissioners’ Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone: 0303 123 1113.
Or you can report a concern at the following link: https://ico.org.uk/concerns/