BEMBRIDGE SAILING CLUB

Privacy Policy

Introduction

This policy sets out how Bembridge Sailing Club (the Club, us, we) uses the personal data we collect from members, guests, visitors and others. Under UK data protection legislation the Club is a ‘controller’ of your personal data, and we are obliged to give you the information set out below. ‘Controller’ is a legal term used to describe the organisation that determines the purposes for which personal data are used. In this capacity the Club will store and process your personal data in accordance with this Privacy Policy. We have registered with the Information Commissioner’s Office and our registration number is Z6499084.

If you need to contact us about our use of your personal data please use the contact details set out at the foot of this policy.

Our purposes and our lawful basis for using personal data

The overall purpose for which the Club collects and uses personal data is the successful, safe and efficient management of the Club. You will provide personal data to us as a member or guest of the Club, or when providing goods or services to the Club, or when otherwise in contact with us. Under data protection legislation the Club must have at least one lawful basis for each use of personal data.

An explanation of our reasons for using your personal data and the lawful bases on which we do so (underlined) are set out below:

·         Members, prospective members and temporary members:

We have or will require your name, contact details and certain other basic information that is necessary in order for us to fulfil our contractual obligations to you, or in respect of you, under the Club’s Rules. We collect this data at the point of your application for membership.

The purpose for which we process these data is: the management of your membership of the Club.

The personal data we process for this purpose are: your name, main address, email address, date of birth, date of joining, subscription category, bank details and potentially other information.

We will process any personal data relating to you that are not necessary for us to process for contractual reasons (as above) on the basis that it is in the Club’s and other members’ legitimate interests to do so. We believe that this processing will not result in any significant risk to you and will not prejudice your interests or your fundamental rights and freedoms, taking into account the security measures the Club has put in place to protect your personal data, and your ability to remove certain of your information from the Club’s publications if you wish (see under ‘Your rights’ below). This data will be collected by us from time to time during your use of the Club.

The purpose for which we process these data is: to enable the safe, successful and enjoyable operation of the Club and its activities for members.

The personal data we are likely to process for this purpose are: your Bembridge address (if applicable), telephone numbers, family connections, presence on the Island (if known), attendance (or proposed attendance) on courses, in races and at other Club events, boat details, boat insurance details and water-based qualifications.

In certain specific cases the Club may ask you for sensitive personal data, for example health needs in the case of cadets on sailing courses, and dietary requirements in the case of dinner guests. In such cases we will ask you to consent to our use of that data, and the basis on which we will process that data will be your consent.

The purpose for which we process these data is: to ensure your safety when using the facilities or attending the event concerned.

The personal data we are likely to process for this purpose are: health details, disabilities, and dietary requirements.

·         Instructors and others providing services to the Club

If you are an individual providing services to the Club in a personal capacity, for example as an outside instructor, we will process your personal data to enable us to fulfil our contractual obligations to you. If you are providing services to the Club as the employee or representative of a business that we have contracted to supply those services, we will process your personal data on the basis that it is in the legitimate interests of both the Club and your business that we process your data, and we believe that in view of the limited nature of the data so held there will be no risk caused to you by such processing. We will collect your personal data at the point of engagement.

The purpose for which we process these data is: the safe and successful fulfilment by you and us of your engagement with the Club.

The personal data we are likely to process for this purpose are: your name, address, email address, date of birth, National Insurance number, bank details, and water-based qualifications.

·         Visitors and guests

If you are a guest of a member, we will ask for your consent, or the consent of the sponsoring member on your behalf (which we may ask you to confirm), to process limited but necessary personal data about you to enable you to enjoy your visit to the Club, and to ensure your safety while at the Club. If for any reason you are not asked, your consent will be deemed given by virtue of your presence at the Club. If you are a visitor to the Club we may ask for your name and reason for visiting the Club.

The purposes for which we process these data are: to ensure the security of the Club and its premises, and to ensure your safety, and that your stay at the Club is recorded if necessary.

The personal data we are likely to process for these purposes are: your name and reason for visiting the Club in the case of visitors, and in the case of guests your family names and the name of your Club member contact, and in the case of events, any disabilities or dietary requirements.

·         Suppliers and other business contacts:

We will process your personal data on the basis that it is in the legitimate interests of both the Club and the supplier/business to do so, and we believe that in view of the limited nature of the data so held there will be no risk caused to you by such processing.

The purposes for which we process these data are: the purchase of and payment for goods and services by the Club, or the management of other business arrangements.

The personal data we are likely to process for these purposes are: your name, business email address and business telephone number.

·         All individuals

·         CCTV: We have installed CCTV on the Club premises to ensure the security of the Club and its premises, to protect the Club’s and Club members’ property, and to deter theft. Your presence at the Club may be recorded by the cameras we have installed, and the resulting images and footage will be reviewed from time to time by authorised Club staff, and in certain cases we may be obliged to pass certain recorded images or footage to the police. It is in the legitimate interests of the Club and its members to record and monitor activities on the Club’s premises for these reasons.

The purpose for which we process these data is: to protect the property of the Club and that of its members.

The personal data we process for this purpose are: still images or video footage.

·         Emergencies: On hopefully rare occasions it may be necessary to contact others (including those providing medical help) to inform them of an accident or other life-threatening event, where you are not capable of making contact yourself. In such a case we will endeavour, where possible, to make the necessary contact ourselves on the basis of your vital interests.

The purposes for which we process these data are: to secure immediate medical assistance, inform relatives and help save lives.

The personal data we are likely to process for this purpose are: your name, age, condition and location.

·         Legal requirements: On occasion we may be obliged to process or to disclose personal data to other parties for legal reasons, or where there is a legal obligation on the Club to do so, or for the detection or prevention of crime.

Help us keep your details up to date

Members: Please let us know promptly of any changes to your personal data by contacting us. You can make many of the changes yourself by visiting your entry in the members’ section of the Club website, and we encourage you to do this.

Consequences of not providing personal data we ask you to provide

If you do not provide the basic personal data necessary to become or remain a member of the Club (your name, an address, email address, date of birth and bank details) you will not be able to become (or remain) a member.

If you do not provide details of any health requirements when booking courses we may not be aware of particular risks to your (or your child’s) health posed by the conditions and any particular steps necessary to secure the correct medical assistance.

If you do not provide details of any dietary requirements when booking for meals you may be given food or drink to which you have an allergic reaction or personal dislike.

Who do we share personal data with?

For members, we may disclose your personal data to any of the following persons to ensure the safe and successful operation of the Club, and your enjoyment of the Club’s facilities: staff, other Club members, independent contractors, insurance companies, suppliers, local contacts, other sailing clubs, the RYA and other sailing and boating organisations, the coastguard and the emergency services. In each case we will disclose only such data as is necessary for the purpose, and only where we are either obliged to do so, or where disclosure is necessary to achieve the purpose.

We may also, by reason of the service they provide, allow your personal data to be processed by our third party data and communications service providers. These providers will act as data processors under a data processor contract which contains the controls and restrictions required by law on the part of data processors.

We may change the service providers we use in future. If we do, we will update this Privacy Policy to reflect the change.

As noted above, we may occasionally be required by law, court order or governmental authority to disclose certain types of personal data. Examples of the type of situation when this would occur would be in the administration of justice, or where we have to defend the Club legally.

Transferring your personal data outside the European Economic Area (EEA)

Generally, we only store and use, and permit others to store and use, your personal data within the EEA. However, some of the data and communication service providers we use are based (or process data) outside the EEA. If personal data is transferred outside the EEA there is a risk that it will not be protected to an equivalent standard as in this country. So, before permitting your data to be transferred outside the EEA we will ensure that suitable safeguards are in place. We will usually do this by ensuring that standard contractual clauses approved by the European Commission are included in our contracts with service providers. As an alternative, some US service providers may have self-certified as providing adequate safeguards under the EU-US Privacy Shield. We can let you know which safeguarding scheme applies (and give full details) in respect of any service provider on request.

How long we keep your personal data

Full Members: We will keep the personal data that you provide to us for the duration of your membership and for a period of six years thereafter, but at any time (a) we will delete data that are no longer necessary for us to keep, and (b) you may require us at any time to delete data that are not necessary to enable us to fulfil our obligations to you under the Club’s Constitution and Rules, and we will delete those data on request. After a period of six years following the termination of your membership we will delete all your personal data save your name and the years of your joining and leaving, which we will keep on an archive basis for a period of at least fifty years (unless you instruct us otherwise).

In the case of a member whose membership has been suspended or terminated under Rule 15 or 16 of Part 2 of the Club Rules, the member’s personal data will be retained by the Club for as long as necessary for the Club to be able to enforce the restrictions placed upon the member by the Club Rules as a result of such suspension or termination.

Temporary members: We will keep your personal data for the duration of your temporary membership and thereafter for as long as necessary for the Club to be able to enforce the restrictions on the frequency of temporary membership under the Club Rules.

Guests: We will keep your personal data for the duration of your visit and thereafter for as long as necessary for the Club to be able to enforce the restrictions on the frequency of guest visits under the Club Rules, and to comply with legal obligations relating to licensing.  Your name will be entered by the member whose guest you are in the guest book, and we keep the guest books indefinitely as part of the Club’s archives (and only for archive purposes).

Outside instructors and other suppliers: We will keep your personal data while you remain under contract to the Club, or remain a representative of the supplier to the Club, and for a period of six years thereafter.

Business Contacts: We will keep your data for as long as it is in our legitimate interests to do so.

All individuals: We retain images recorded on the CCTV system for as long as is necessary to ensure the security of Club and Club members’ property, and if applicable for as long as required for legal reasons.

Security

We are careful to protect the security of your personal data. We use a variety of tested security technologies and internal procedures to help protect your personal data from unauthorised access, use, or disclosure. We can give members and others further details of our security systems and procedures on request.

Your rights

Members: You can at any time remove from other members’ view any of your personal data that appear in your entry in the members’ directory on the Club website (except your name), and any changes you make will also feature in the next following publication of the Blue Book.

All individuals:

You have the following rights at law in relation to your personal data:

·         The right of access to a copy of the personal data we hold about you;

·         The right to require us to correct any inaccuracies in your personal data;

·         The right to object to decisions about you being taken by automated means (although the Club does not make any decisions by automated means);

·         Where we have sought your consent, the right to withdraw your consent at any time; and

·         The right to ask us not to process your personal data for the Club’s marketing purposes.

You also have the following rights at law in relation to your personal data in certain circumstances:

·         The right to restrict or object to our use of your personal data;

·         The right to require us to provide a copy of your personal data to others;

·         The right to require us to erase your personal data.

If you contact us to exercise your rights we will respond as required under data protection legislation, but please note that not all rights are absolute. Sometimes they may not apply, or other legal obligations or third party rights will take precedence.

If you contact us by telephone, email or by any other remote means we may require proof of ID before acting.

You can find out more about your rights on the Information Commissioner’s Office website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Who can you complain to if you are not happy about how we use your personal data?

If you have any complaints about how we use your personal data, we ask that you contact us in the first instance using the contact details below. We’ll do our best to resolve the matter. However, you do also have the right to lodge a complaint with the Information Commissioner’s Office at any time.

Changes to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will revise the “last updated” date at the bottom of this Privacy Policy and we will take reasonable steps to make you aware of any material changes to it. We also recommend that you revisit this page regularly to keep informed of our current privacy practices.

Cookies

Our website (www.bembridgesailingclub.org) is hosted by WordPress. Please see the information provided by WordPress as to how cookies are used by our website via this link: https://en.support.wordpress.com/cookies/

How to contact us

If you have any questions regarding this policy or our handling of your personal data, or any data requests, please contact the Club’s General Manager /Secretary at: sec@bembridgesailingclub.org. You also have the right to address any complaint about our handing of your personal data to the Information Commissioner’s Office:  https://ico.org.uk/ Helpline number 0303 123 1113.

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