GDPR (General Data Protection Regulation)
Alloa ASC Club Privacy Notice Version 1 May 2018
What we need
Alloa ASC is a Scottish swimming club which is affiliated to Scottish Swimming. Alloa ASC provides training for children, masters swimmers and disability swimmers.
Alloa ASC will be a “controller” of the personal information that you provide to us unless otherwise stated.
Members’ personal data:
When you or your child register as a member of Alloa ASC or renew your membership (including if you are registering or renewing on behalf of a child under the age of 16), we will ask you for the following personal information:
contact details – name, address, email address, date of birth, gender and emergency contact information ;
membership criteria / category – for example, athlete, parent, volunteer, etc.;
participation details – for example, parent, athlete, etc.; and
equality information – for example, disability;
Why we need your personal information – contractual purposes
Members’ personal data:
We need to collect our members’ personal information so that we can manage your membership. We will use our members’ personal information to:
provide core swimming club services, including keeping registers of you or your swimmer’s attendance at swimming training, entering swimmers into galas, keeping your registration with Scottish Swimming up to date and;
send you membership communications by email or squad text in relation to essential membership services, including but not limited to, training and gala updates, general meeting notices, membership renewals, membership fees’ information, etc
If you do not provide us with all of the personal information that we need to collect then this may affect our ability to offer the above membership services and benefits.
Why we need your personal information – legitimate purposes
Members’ personal data:
We process our members’ personal information in pursuit of our legitimate interests to:
promote and encourage participation in swimming by sending members’ communications and information for upcoming galas, competitions and events. Our galas, competitions and events may be filmed or photographed and your personal information may also be used in images captured from our competitions and events, which we use for promotional, education and development purposes;
provide competition in swimming by accepting and managing entries for our competitions and checking your personal information to ensure you are entered into the correct category;
monitor and develop participation in swimming by monitoring members’ engagement and participation through the use of personal best recording and attendance registers and inviting our members to participate in surveys for researching and development purposes;
develop and maintain our members’ qualifications, including sending email communications to members to inform you of upcoming courses, renewal requirements and verify that you have completed any mandatory training and PVG / child protection requirements;
respond to and communicate with members regarding your questions, comments, support needs or complaints, concerns or allegations in relation to swimming. WE follow and comply with Scottish Swimming’s standard policy on complaint handling and we will use your personal information to investigate your complaint, to suspend membership, take disciplinary action, etc.; and
provide you with clothing complete with our Alloa ASC logo and name.
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact our President or Secretary using the forms on our website. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for the benefit of you as a member.
Some of our members have a specific role with Alloa ASC.
For those members we will need to collect personal information relating to criminal convictions or alleged commission of criminal offences where you are required to complete a PVG check under the Protection of Vulnerable Groups (Scotland) Act 2007. This information will include your PVG certificate number, PVG membership number, date of issue and any relevant information in relation to your membership of the PVG Scheme.
If your PVG certificate is not clear, we will have a legitimate interest to collect references and any other applicable information to allow us to consider whether or not you can volunteer in a regulated role with children and/or vulnerable adults.
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact our Child Welfare Officer using the contact form on our website. If we comply with your objection, this may affect our ability to undertake the tasks above for the benefit of you as a volunteer.
Why we need your personal information – legal obligations
We are under a legal obligation to process certain personal information relating to our members, volunteers and coaches for the purposes of complying with our obligations under:
the Protection of Vulnerable Groups (Scotland) Act 2007 to check that our coaches and volunteers are able to undertake regulated work with children and vulnerable adults; and
the Equality Act 2010, which requires us to process personal information to make reasonable adjustments where necessary.
Other uses of your personal information
We may ask you if we can process your personal information for additional purposes. For example, if we are taking members on a trip or training camp. Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.
Who we share your personal information with
If your personal information is included in any images or videos taken by us at our competitions and events, we may share this with Scottish Swimming for promotional and/or journalistic purposes.
We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include the Health & Safety Executive, Disclosure Scotland, and Police Scotland for the purposes of safeguarding children.
We may also share personal information with our professional and legal advisors for the purposes of taking advice.
Alloa ASC do not currently employ third party suppliers to provide services.
In the event that we do, on an exceptional basis, share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.
Scottish Swimming members’ personal data
As an affiliated club of Scottish Swimming we are required to ensure that all of our members are members of Scottish Swimming as a condition of our affiliation.
We will share the required personal information with Scottish Swimming who will become a controller of your personal information when they receive it. Scottish Swimming’s privacy notice explains how they use your personal information and can be accessed here https://www.scottishswimming.com/media/2455353/privacy-notice_members_february2018_final.pdf .
Swimmers’ / Participants’ personal data
We may publish the results of our competitions on our website. This may include competitors’ name, age, gender, event and times.
How we protect your personal information
Your personal information is stored on our electronic filing system and our servers based in the EU, and is accessed by our committee members, coaches and volunteers for the purposes set out above.
We have not been required to transfer your personal information outwith the EU for any purposes, including competitions or overseas training camps. Where your personal information is transferred outwith the EU, we will provide you with information regarding the safeguards that we have put in place with the recipient country to protect your personal information.
How long we keep your personal information
Members’ personal data
We will only keep your personal information for as long as necessary to provide you with membership services. Unless you ask us not to, we will review and possibly delete your personal information where you have not renewed your membership with us for 3 years.
Swimmers’ personal data
We keep our swimmers’ personal information for a period of 3 years after the end of their membership with Alloa ASC.
You can exercise any of the following rights by writing to our President using the form on our website.
Your rights in relation to your personal information are:
you have a right to request access to the personal information that we hold about you by making a “subject access request”;
if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information;
you have a right to request that we restrict the processing of your personal information for specific purposes; and
if you wish us to delete your personal information, you may request that we do so.
Any requests received by Alloa ASC will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner’s Office at www.ico.org.uk