Privacy Policy
PRIVACY NOTICE
In May 2018, the regulations surrounding how companies and organisations can hold your personal data changed. This Notice tells you how we handle your Personal Data and the rights you have, when we hold it. This Notice is intended to comply with the provisions of the General Data Protection Regulation EU 2016/679 (GDPR) which governs how Personal Data is processed within the European Economic Area (EEA).
Who are we?
We are East Herts Gymnastics Club, a not-for-profit limited by guarantee registered company. Our address is 18b Mimram Road, Hertford SG14 1NN.
You will find our contact details at the end of this Notice.
We are the “data controller” for the purposes of GDPR. This means that we decide how your Personal Data is processed and for what purposes.
Your personal data – what is it?
Personal Data is data that relates to a living individual who can be identified from that data. We might be able to identify you from the data itself or by linking that data to other information we have access to. GDPR tells us how we must process your Personal Data.
How do we process your Personal Data?
We comply with our obligations under GDPR in the following ways:
- by keeping Personal Data up to date. (It is the responsibility of individuals and organisations to ensure the data held by us are accurate and up-to-date. Individuals should notify us of any changes, to enable personnel records to be updated accordingly. It is the responsibility of East Herts Gymnastics Club to act upon notification of changes to data, amending them where relevant.)
- by storing and destroying it securely;
- by not collecting or retaining unnecessary or excessive amounts of data;
- by protecting Personal Data from loss, misuse, unauthorised access and disclosure; and
- by ensuring that appropriate technical measures are in place to protect Personal Data.
What is the legal basis for processing your personal data?
- We use the information we hold about you for a variety of purposes which are outlined below. Data protection law requires us to tell you what our legal reason is for each purpose.
Contractual purposes
When you ask us to provide you a service, such as club [membership or registration], gymnastics classes, competitions, trips or other activities [or you buy a product from us] we usually need to use information about you to provide this [product] or service, for example:
• To contact you to confirm arrangements.
• To notify you about changes to terms and conditions.
• To tell you when it is time to renew membership or re-register for activities
• To process payments or send you receipts required.
• To provide you with the benefits and services to which you have subscribed. We do so because it is necessary for the performance of a contract.
We use your Personal Data for the following purposes:
- To manage membership information and process payments for the organisation we run.
- To inform you of news, events, activities or services which we think you might like to hear about.
- To share your contact details with our staff, other authorised people for the purpose of contacting you in the event of an emergency, to record your attendance and deliver the service we provide.
- To be placed on a waiting list so we can contact you when a space becomes available.
- To collect and store this information we use Class4Kids. You can view their privacy policy here https://www.class4kids.co.uk/privacy
- The categories of personal information we process include:
- Contact details* (gymnast and parent and emergency contacts)
- Gymnast date of birth* and school year
- Gymnast gender
- Any relevant medical conditions and/or disabilities and additional related information
- Other relevant individual needs for example, information about learning, religious or other support needs.
- Any individual risk assessments (gymnasts and others if applicable)
- Details of any reasonable adjustments or steps taken to support your individual needs
- IGA membership details* (which are confirmed by IGA when you join or renew)
- Gymnast attendance and achievement records
- Any communications from, to or relating to you
- Details relating to standards of conduct
- Any accident or incident reports including details of injuries
- IP address, browser identifier and the time of access (if you use our website)
- Bank details (If you are making regular payments to us or we are making payments to you e.g. for volunteer expenses)
- Experience, qualifications, training and confirmation that you have completed a criminal record check (prospective or existing volunteers).
- The information marked with an * above is essential for us to provide your membership. It is your choice whether you provide all the information we have requested but not providing information may affect our ability to meet you or your child’s needs and to protect their well-being.
Sharing your personal data
Your Personal Data will be treated as strictly confidential and will be shared only with organisations whose services are required in order to provide the services we offer. We use other companies to help us process your Personal Data so that we can offer you the best possible service.
Data must not be transferred to countries outside the European Economic Area without the explicit consent of the individual.
When you give your consent to our holding of your Personal data you agree to us sharing your Personal Data (including special categories of Personal Data – where we have your explicit consent) with third party processors and sub-processors located inside the EEA.
In accordance with our legal obligations, we may share information with local authorities for example, where we have safeguarding concerns.
On occasions, we may need to share information with the police.
We may also need to share information with our legal advisers for the purpose of obtaining legal advice.
We may share some informational with our insurance company, for example, where there is a serious incident at the club, they also need information to insure the gymnasts with the insurance company
If you have unpaid fees while your child is at the gym, we may share information with the courts and legal advisers in order to recover any overdue fees.
Your consent remains valid.
Please speak to East Herts Gymnastics Club if you would like to withdraw any consent given.
How long do we keep your Personal Data?
We keep your Personal Data for as long as you are a member of our organisation. After you leave, we will keep your information for no longer than we reasonably need. Usually, this will be for no longer than a period of one year. This is for accounting purposes or in case of any legal/insurance claims or complaints.
If you have requested to be placed on our waiting list, your data will be held until a space becomes available. You have the choice to withdraw your consent for us to hold this information at any time, in which case it will be removed.
Your rights and your Personal Data
Unless we have an exemption under GDPR, you have the following rights with respect to your Personal Data: -
● The right to request a copy of the Personal Data which we hold about you, without any charge.
● The right to request that we correct any Personal Data found to be inaccurate or out of date.
● The right to request that your Personal Data is erased where it is no longer necessary for us to keep it.
● The right to withdraw your consent to the processing we carry out at any time.
● The right to request that we provide you with your Personal Data and, where
possible, to send that data directly to another data controller.
● The right, where there is a dispute in relation to the accuracy or processing for your Personal Data, to ask us to restrict further processing.
● The right to object to the processing of Personal Data.
Legal Obligations
We have a duty of care to ensure it is safe for you or your child to take part in gymnastics activity and to keep you/them safe while participating. Some individuals may be at risk of harm from participating in gymnastics activity as a result of a pre-existing condition. It is vital that you let us know if there is any reason why taking part in gymnastic activity may be unsafe prior to participation. With your agreement, we will review any information you provide and undertake risk assessments in consultation with you and any appropriate trained professionals e.g. medical consultants. When we ask participants to provide relevant health information such as details of medical conditions, medication needs, allergies or injuries, this is because we have a legal obligation. If you are selected for a role at the club, we will usually obtain a reference from any appropriate organisation or individual you have nominated. When you tell us about any special needs such as disabilities or other support information we may use relevant information to comply with our legal obligations under the Equality Act 2010. We will review any information you have provided to help us identify any actions we can take to support inclusion. We may need to ask you for more information to help us to best meet your or your child’s needs. We will keep a record of any steps we take to support inclusion. If you wish to volunteer or work for us, we may need to ask you to complete a criminal record check as we have a legal obligation to do so. We jointly control the checking process with IGA which is responsible for the assessment of any content on the check and will only share information with us where it is appropriate. For example, if you are considered by IGA to be unsuitable to take on the role, we may share relevant and proportionate information about criminal offences where it is deemed that while you are not considered unsuitable to take on the role if it is considered necessary for safeguarding purposes. When we retain information about you, even after you are no longer taking part in gymnastics activity, this is often because we are required to do so by law such as records we are required to keep for business and accounting purposes. Sometimes we are also legally obliged to share information about you with third parties. More information is provided below.
Legitimate interests
We rely on legitimate interests for the following purposes:
• Responding to communications, concerns or complaints and seeking feedback from you about our services. We will use the information you provide to respond to any comments or questions you raise and where appropriate to undertake investigations into any complaints or concerns. On occasion, we may contact you to seek your views on the services we provide.
• Holding emergency contact information When you join the club, we collect contact details. We also ask you to provide an emergency contact which we will only use in exceptional circumstances if we are unable to contact your primary contact e.g. a parent.
• Maintaining attendance registers, achievement records and waiting lists For health and safety purposes and club records, we need to maintain a register of those in attendance at training or other club activities. If there are no places in the club, we can place you on our waiting list and will contact you using the details you provide to inform you when a place is available.
• Entering you into a competition and providing results If you wish to take part in a club competition, your information (usually your name, date of birth and gender) will be used to enter you into the appropriate category and your score will be recorded. Results of competitions are normally published on the IGA website. If you wish to enter a competition organised by another gymnastics body, including IGA and British Gymnastics, home country NGB, Regional and County Gymnastics Association we
will provide your information to the organiser to enable you to take part in the competition or event that they are organising.
• Collecting additional information to support a participant attending a club trip
Occasionally we organise residential events or trips. If you or your child registers for one of these events, we will need to collect additional information, that may vary depending on the specific activities and whether they involve meals and travel. Additional information we require may include passport information and any other relevant information necessary to provide support whilst away from home.r
• Monitoring performance and undertaking fitness assessments If you or your child are/is a competitive/elite/squad gymnast, we will need to collect additional information about you/them. We track and monitor gymnast’s performance in training, trials and competition and undertake regular fitness assessments. We may require additional information about lifestyle and education if you or your child are/are training at an elite level and require time out of school or lifestyle.
• To monitor that you have completed any required safeguarding training and criminal record checks If you undertake a role where a criminal record check and safeguarding training are required, we will receive confirmation from IGA that your check is approved and that you have completed the required safeguarding training.
• Filming for coaching purposes On occasion, we may film gymnasts e.g. during a gymnastics session for coaching purposes. Videos taken at training sessions for individual coaching purposes will not be used for any other purpose without prior consent.
• Photography and filming at club events to promote the club We may take photos at club events to promote the club on our website, club social media account and in communications. At our club events such as our annual club competitions and club display, we may film the event to create a DVD. Any images of children will be published in line with our safeguarding policy. We may take photos at competitions and other events to promote the club on our website, club social media account and in communications. Any images of children will be published in line with our safeguarding policy.
• Running and monitoring our club website and social media; We do not use any tracking or analytics on our website. Your IP address will be logged by our web server but we would not be able to identify you from this information alone.
Further processing
If we wish to use your Personal Data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use. We will do this before we start processing for the new use. We will set out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Contact Details
If you have a problem, complaint or, if there is something you don’t understand, please contact us first using the following:
East Herts Gymnastics Limited at easthertsgymnasts@gmail.com