Release, August 2020
Kingston ASC Privacy Notice
Kingston Amateur Swimming Club (Kingston ASC), also referred to throughout as “club”, is the oldest of its kind in Glasgow. Originally formed in 1892 it is a friendly family club, whose aim is to train swimmers of all ages for fun and competition. The club is based at Castlemilk Pool on the South Side of Glasgow. Kingston ASC is affiliated with our governing body, Scottish Swimming, and all its procedures and Child Wellbeing and Protection Policies follow Scottish Swimming guidelines. In recognition of good governance practice, the club currently holds Scottish Swimming’s SwiMark accreditation.
What we need
Kingston ASC will be a “controller” of the personal information that you provide to us in this form, through forms requesting competition information or contact details for social events; or through our website.
When you register as a member of Kingston ASC or renew your membership (including if you are registering or renewing on behalf of a child under the age of 16 yrs, we will ask you for the following personal information:
- personal details – name, gender, address, email address, phone number, date of birth, medical information, emergency contacts;
- membership criteria / category – for example, swimmer, parent, volunteer
When you volunteer with Kingston ASC, we will also ask you for the following personal information:
- participation details – technical official, coach, committee member, general volunteer;
- registration details – PVG membership, coaching qualifications etc
Our club management software “Team Unify” will also securely hold members card details.
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 you with core member services, insurance, PVG checks, entry to competitions in accordance with Scottish Swimming regulations;
- retrieve information from your online membership account and use the details for communications and competition information;
- send you membership communications by post or email in relation to essential membership services, including but not limited to, general meeting notices, membership renewals, membership fees’ information;
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.
Participants’ personal data:
When you book a place with us to attend a coaching course, competition, event, training course, we need to collect your personal information so that we can honour your booking and to enable you to participate in the course, competition, event.
If you do not provide us with all of the personal information that we need to collect then this may affect our ability to book your place.
Why we need your personal information – legitimate purposes
Members’ personal data:
We also process our members’ personal information in pursuit of our legitimate interests to:
- promote and encourage participation in swimming by sending to members communications and booking information for upcoming competitions and events. Our 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 competitions and camps, and inviting our members to participate in surveys for researching and development purposes;
- invite our members as award winners or guests to our annual awards night, which includes asking our members to nominate individuals for awards and shortlisting such individuals to select the winners, who we may contact by email;
- 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 swim training. We will use your personal information to investigate your complaint, to suspend membership, take disciplinary action, where appropriate.
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 us on firstname.lastname@example.org . 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.
Volunteers’ personal data:
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 us on email@example.com. 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, participants, swimmers, etc. 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;
- our Swim Scotland regulatory requirements to facilitate annual returns by 30th April to make sure the club will keep its affiliation;
- the Equality Act 2010, which requires us to process personal information to make reasonable adjustments where necessary.
Why we need your personal information – marketing.
Where you are happy for us to do so, we would like to contact you by email with information about swimming, our latest news and upcoming events / competitions / courses via our club email communication Kingston Splash.
You may change your preferences at any time or request that we stop sending you email communications by contacting us at firstname.lastname@example.org . There is also an ‘unsubscribe’ button at the bottom of every email communication we send.
Other uses of your personal information
We may ask you if we can process your personal information for additional purposes. For example, residential camps. 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.
In the event that we do 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.
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.
When you join Kingston ASC you will be asked to register 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 personal information on our website and social media, such as competition results and acceptance into competitions.
How we protect your personal information
Your personal information is stored on our electronic filing system (Hy-Tek Team Manager), on our cloud based account with Team Unify, our servers based in the UK and on the personal computers of authorised club volunteers and paid coaches and is accessed by our paid coaches/volunteers for the purposes set out above.
How long we keep your personal information
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 six years.
We keep a record of swimmers “club records” which includes name, date achieved and age at time of achievement.
You can exercise any of the following rights by writing to us at email@example.com
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 Kingston 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
As a result of the worldwide Coronavirus pandemic, we may need to record information regarding whether you are displaying from any symptoms of COVID-19, have been in recent contact with anyone who has tested positive or is displaying symptoms of COVID-19, have any underlying health conditions or have, or are in close contact with anyone who has, been advised to shield. This information would be required to ensure the safety of members attending Kingston ASC.
Why we need your data
Our lawful basis for processing health information relating to COVID-19 is:
- to protect your vital interests; and/or
- for the legitimate interests of members attending Kingston ASC to ensure individuals’ safety and prevent the spread of the virus.
As health information falls within the definition of “special categories of personal data” under applicable data protection legislation, we also need a special condition to process such information. We may need to process this health information:
- to protect your vital interests where you cannot consent;
- for reasons of public interest in the area of public health, including protecting against serious cross-border threats to health where we have a legal duty of confidentiality to you; and/or
- with your explicit consent (if required).
Information we may collect about you
We may collect data from you in relation to COVID-19:
- From a return to water self declaration and/or a regular health check survey – detailing whether you have symptoms of COVID-19, if you have come into contact with someone with COVID-19, history of having COVID-19, and underlying health conditions.
- Should you report contracting COVID-19 through to the COVID Officer or Club Committee Member.
Who we share your personal data with
We may be required to share personal information with statutory or regulatory authorities and organisations to comply with public health obligations. In the event that we do share personal information with third parties, we will only share such personal information as is 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.
Where a case of COVID-19 is recorded within the club, your personal information will not be shared with other members directly, however members will be advised that a case has occurred, whilst keeping personal information anonymous as far as possible.
How long will we store COVID-19 specific data?
We will only keep your personal information for as long as necessary in line with legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.