WYC Data Privacy Notice : General Data Protection Regulations (GDPR)
At Whitstable Yacht Club (“WYC”, “we” or “us” “the club”) we are committed to facilitating and promoting the sport of sailing and encouraging racing. In order to do this we collect and use personal data.
This Data Privacy Notice describes what personal information we collect or obtain about you and how we use it in line with the General Data Protection Regulations (GDPR) effective 25th May 2018. An important change under the regulations is that we need to provide a clearly written Data Privacy Notice (this document) to explain how we collect and use personal information and to obtain your explicit consent to retain your personal details.
WHY DO WE COLLECT AND USE MEMBERS’ INFORMATION?
By member we include all categories of WYC membership under club rules.
We collect and use information to:
• Administer membership, training and boat records and collect fees due.
• Contact members to keep them informed about sailing or training events and other activities at the club.
• Administer the duty register and notify members of their duties.
• Publish race results.
• Publish the year handbook that includes details of officers, committee members and fleet captains.
• Comply with our rules for notifying members of Committee Meetings, the AGM or any SGM and other formal commitments.
• For gathering aggregate data for RYA and other statistical reporting such as training and session attendance.
WHAT INFORMATION DO WE RECEIVE OR COLLECT?
The categories of personal information that we may collect and hold include:
• Personal information as requested on the appropriate WYC forms whether completed and returned electronically or on paper, such as your name, address, e-mail address, telephone and/or mobile number and the name, address, email address and phone number of your next of kin and/or emergency contact.
• Relevant details of cadet members and children under the age of 18 included in their parent’s membership, and those of the person (parent or legal guardian) responsible for the cadet.
• Characteristics (in particular disability) for RYA reporting purposes.
• Relevant training records of instructional and safety boat staff, such as qualifications, experience and any accompanying notes and observations regarding your performance.
• Medical and dietary information for training courses; details of any other relevant information for WYC’s safe operational purposes.
• Photos or videos of members taking part in club events having signed on our entry forms to agree to us using pictures for publicity purposes.
• Personal information and photos of visitors taking part in open days, championships and other events, having signed our entry or consent forms to agree to us holding this information and to using pictures for publicity purposes.
• No images of children under 18 years of age will be published except with the signed prior consent of a parent or legal guardian, subject to the conditions of the Cadet Parental Consent form.
• Records of prize winners and the engraving of names on cups.
• We may collect and hold additional information on members and visiting sailors for the purpose of protests and protest decisions or for serious breaches of RYA or ISAF rules.
• In accordance with the club’s licence and rules, we keep a note of visitors to the club/bar in the visitors’ book kept in the bar.
• Employees: WYC holds the following personal information about its employees – Name, address, telephone number, references, verification of qualifications, employment history and salary; information used for administrative and payroll purposes. We may also retain employee annual performance review records and records of any informal and formal disciplinary proceedings. We may also hold the following sensitive personal information about employees: racial or ethnic origins; physical or mental health or condition for the purpose of equal opportunities monitoring / health and safety monitoring.
• The results of any confidential DBS criminal records searches which at our request you have provided for us.
WHERE IS THE DATA KEPT?
• Electronic data is stored on the hard drive of club office computers under the supervision of the Sailing Secretary (for members), the Training Administrator (for courses and sailing development) and Club Manager (for employees and general management purposes).
• Technically this data is stored in the “cloud”. WYC computers back up to Google docs cloud and/or Microsoft OneDrive cloud. Emails which may also contain personal information are also stored in the “cloud”.
• All paper records are stored under the supervision of the respective officials as above in the locked club offices in the club house; paper records are not routinely scanned.
• Membership and Training data is accessible only to those members in committees and in club roles who require access for their respective operational purposes.
• Employee data is accessible only to the Club Manager and Commodore.
• The printed year book and WYC web site contain information about club officers and other members of the club responsible in different capacities for sailing and training.
WHO DO WE SHARE MEMBERSHIP INFORMATION WITH?
WYC will not share your personal identifying data with any third party or external body, except those stated in this document (below). We share information within the club for operational or on a need to know basis with appropriate club members as follows:
• To receive the necessary information to fulfil their duties such as fleet captains for the purpose of organising race duties and for training officers to organise and run sailing development and courses.
• Any medical information that is shared in confidence with WYC helps us to make appropriate arrangements, minimise risk for all concerned and consider possible emergencies, especially those which could occur on the water.
• As well as being available in an emergency for First Aid purposes, medical information may be seen by a race officer or a course instructor responsible for safety.
• Aggregate attendance and disability data is shared with the RYA and for other statistical purposes, but this does not include personal information.
• Videos and photos of members and visitors taking part in club events may be posted on our website.
• We may share information on a member or visiting sailor adjudged to have committed a serious breach of RYA or ISAF sailing rules, in accordance with our obligations to national and international sailing organisations as per the sport’s governing body rules.
• In the case of a WYC employee seeking a change of employment we would share relevant information to your prospective employers and any other persons you may refer to us for the purpose of obtaining from us any references or verification of your qualifications or experience.
• We may also disclose your personal information to third parties if under a clear, legal duty to disclose or share your personal data in order to comply with any lawful obligation.
WHEN AND HOW DO WE DESTROY THE DATA?
• WYC Membership and Training data will be retained and updated each year as appropriate on renewal.
• Where the data is obtained from you as an instructional qualification or in some other capacity we may keep and process the data for so long as you continue, to our knowledge, to hold that qualification or other capacity and wish to be available for service to the club.
• Where your membership lapses we will within a reasonable time of the lapse occurring cease actively processing your data but may retain your data in perpetuity for the purpose of facilitating the renewal by you of your membership or in the case of continuing administrative need such as unpaid fees, a dispute, or boat disposal.
• Personal information will be deleted on computers and/or shredded from any file.
• Committee members and fleet captains will be reminded to delete / shred contact details on termination or non renewal of membership.
Please note. You may ask WYC members to make contact with you for reasons other than those in connection with WYC and its activities. In these circumstances WYC will not be able to impose or exercise controls concerning your personal identifying data.
USE OF SOCIAL MEDIA
Whitstable Yacht Club as an organisation does not use any social networking forum, however WYC Facebook, Instagram and Twitter are in common use by members. All WYC members should take notice that they should not make any post which includes personal information of another member that has been entrusted to the club without their specific permission or post any communication by whatsoever method between the Club and a member.
HOW YOU CAN ACCESS YOUR PERSONAL DATA
Under the data protection regulations, you have the right to request information that we hold. To make a request please contact the Data Protection Officer via the Club office.
You have the right to:
• Access this information within a month of making the request.
• Have mistakes corrected and in certain circumstances, erased or destroyed.
• Object to processing data that is likely to cause damage or distress, for example, any form of discrimination, damage to your reputation or any significant economic or social disadvantage.
• Complain to the Information Commissioner’s Office (ICO).
• Withdraw your permission given under the WYC Data Privacy Notice (this document).
• Prevent process for the purpose of direct marketing, albeit WYC does not use data for direct marketing.
• Object to decisions being taken by automated means, albeit WYC operational and duty decisions are taken only by the responsible club members.
• WYC employees who wish to exercise this right (to access their personal data) should write to the Club Manager. If, as the result of a subject access request, any personal information is found to be incorrect it will be amended. The Club will deal promptly with subject access requests and will normally respond within 30 days.
COMPLAINTS PROCEDURE (TRAINING)
• WYC is a Recognised RYA Training Centre for which, on request, there is a formal complaints procedure. This Notice of Privacy applies to a WYC Complaints Form when duly completed and submitted. The Complaints Form includes the contact details of the RYA SE area regional officer. The RYA may contact students when this is necessary for quality assurance of RYA training, for example in the investigation of a complaint or incident. In these instances, the information is used solely for the requested purpose and would not be entered on the RYA central database.
RESPONSIBILITIES
• It is the responsibility of all WYC members and employees to ensure that personal information provided to the Club, for example current address, is accurate and up to date. To this end employees are required to inform the Club immediately when changes occur.
• Employees whose role involves the collection, maintenance and processing of personal information about other employees, instructional staff, members, trainees and suppliers or any other individuals with whom the Club has dealings are responsible for following the Club’s procedures on data protection.
• If as a member you choose to opt out of sharing your information, it is your responsibility to make alternative arrangements to ensure that you are aware of and fulfil your club duties. Please note that your obligation under the club’s rules to carry out the duties allocated must still be adhered to.
• For the purpose of GDPR, overall responsibility for ensuring that the Club complies with its data protection obligations rests with the Club Manager, Whitstable YC, 3-4 Sea Wall, Whitstable, Kent CT5 1BX, or office@wyc.org.uk, tel 01227 272942, overseen by the General Committee.
YOUR CONSENT TO THIS PRIVACY NOTICE
An important change to data protection brought in by GDPR is that we need to obtain your explicit consent to retain your personal details. This means you opt in to WYC holding your personal data rather than opt out.
WYC membership forms, training application forms and parental consent forms for cadets will include a box with this declaration. This is to provide your consent for us holding your personal identifying data and also, explicitly, to sharing it with other members to fulfil their respective roles.
DECLARATION FOR MEMBERS
I confirm I have read and understood the Data Privacy Notice as posted on the WYC website and that I agree to WYC holding my personal identifying data as provided on my membership form…
NAME OF WYC MEMBER – please print:
. …………………………………………………………………………….
I agree / do not agree with the information on my form being shared with other WYC club members for operational purposes or on a need to know basis as set out in the Privacy Notice.
If you choose to opt out of sharing your information, it is your responsibility to make alternative arrangements to ensure that you are aware of and fulfil your club duties. Please note that your obligation under the club’s rules to carry out the duties allocated must still be adhered to.
Signed…………………………………….. …….Date…………………
Questions, comments and requests regarding WYC’s Data Privacy Notice should be addressed to Club Manager Whitstable Yacht Club, 3-4 Sea Wall, Whitstable, Kent CT5 1BX or office@wyc.org.uk, tel 01227 272942
