This policy explains when and why we collect personal information about our members and instructors, how we use it and how we keep it secure and your rights in relation to it.
About this Policy
We shall always comply with the General Data Protection Regulation ( GDPR ) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
Who are we?
We are The Royal Dart Yacht Club. We can be contacted at firstname.lastname@example.org and Priory Street, Kingswear, Dartmouth, TQ6 0AB
Explaining the legal basis on which we rely
The law on data protection defines a number of specific reasons for which a company may collect and process your personal data. The RDYC uses three of these reasons;
In specific situations we can collect and process your data with your consent. An example of this is where we request your consent to keep you informed via newsletters.
- Contractual Obligations
In certain circumstances we need your personal data to comply with our contractual obligations. An example of this is if you order some club merchandise, we will collect your address details in order to deliver the item.
- Legitimate Interest
In specific situations we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running the club and which does not materially impact your rights, freedom or interests. An example of this would be the emails or letters that we may need to send to you in support of your membership and account.
When do we collect your personal data?
There are a variety of occasions where we may collect your data. These include:
When you elect to subscribe to our newsletter and updates
When you register an account through our website
When you join, or apply to join the RDYC
- You become a member of the RDYC
- You join any RDYC committee or volunteer for the RDYC in any other capacity
- You become an instructor, trainer, coach, race official or other RDYC appointment holder
- You join us as a member of staff or agree to become a contractor for us
When you join or participate in, or any child for whom you are responsible joins or participates as a member of any of our club run sailing development programmes
When you participate in any club organised Regatta or regular sailing programme
When you register interest in a club event
- A dining event or club run bar function
- A Special Interest Group (SIG) led event
- A lecture facilitated by the club
When you book a club event on behalf of yourself and other friends
- Specify event attendee’s
- Choose event options
- Make a payment for the event
- Request further information from the club
When you undertake any training or social event run by the club
When you hire any of the clubs spaces, such as the cottage and quarter deck
When you purchase any club merchandise
When you enter any club prize draw or competition
When you contact us by any means with queries, complaints etc.
When you choose to complete a club survey that we send to you
When you send us information and data such as member experiences and photographs for use in the club website and Masthead magazine
When you use our facilities, which have CCTV systems, operated for the security of both members and the club. These systems may record your image during your visit.
What sort of personal data do we hold?
As a club member we will hold, your name, title, address, telephone numbers, date of birth, email address, joining referee names, associated family member details, occupation and emergency contact details.
We may also hold your photograph, boat details, boat Insurance details, radio call signs, a selection of areas of personal interest and any boating related qualifications that you provide or are achieved through participation in a club event.
Copies of documents you provide in support of a membership application (e.g. passport or drivers licence).
Should you also participate in a club run competition or respond to a general club request to members, we may also collect photographs and personal interest accounts, information that you provide to the club, for inclusion in the club website and magazine.
If you participate in a club run sporting activity, we may collect health information that could affect your participation. This will only be collected with your express consent.
If you attend a dining function, we may collect dietary records and details of your dietary requirements.
When you make a payment for an event or membership renewal or application, we do not hold card or bank account information in our systems. This financial information is collected by regulated Card Payment Services organisations in order that we may fulfil your request for membership renewal or application, or participation in a club sponsored event.
If you hire a club asset or make use of a storage facility we may hold data pertaining to equipment, insurance.
Information that may be provided on your behalf or at your request. Examples include bookings for training courses or other events on your behalf. If you are a minor and your parent or legal guardian provides us with information about you on your behalf. If we take up references for you or seek verification of qualifications from any referee you may have put forward.
The information about you that we may receive from other sources may include; details of your membership of other sporting bodies, e.g. class associations.
As an employer the RDYC has a specific and separate policy covering the data privacy requirements of employee’s. This is defined in the RDYC Data Protection Privacy Notice.
Why do we collect this personal data?
When we collect information from you directly, we explain the reason for collecting this information at the time of collection. If you register an account or become a member, you will also have the ability to login and review the current status of your personal data, the consents that you have provided, the contracts that are in place and the legitimate interests that support the RDYC use of your personal data.
To fulfil a contract with you:
- To administer your membership and to provide membership information and membership benefits to you
- To notify you about changes to our membership benefits, products, facilities or services
- To provide you with any products and services that you request from us including: items purchased from us, event participation, equipment loans, coaching and training services
- To permit data access and communication from Special Interest Group co-ordinators
When it is in our legitimate interests, and our interests are not overridden by your own interests:
- To notify you of any changes or proposed changes to the club constitution, rules, regulations or best practice in relation to the club
- To notify you of any changes or proposed changes to boating and other related activities which we feel may be of interest to you
- To ask questions for the purposes of obtaining member feedback on the operation of the club such that the club may continue to develop and support its members
- To provide you, with information about services we feel may interest you that are similar to those that you have already obtained, purchased or enquired about
- We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of the club’s legal rights, your legal rights and the legal rights of others
When we have obtained your consent to do so:
- When you have opted in to receive email newsletters and other club related information
Where do we store your personal data?
Your information may be held at our offices, or on secure servers either owned by the RDYC or by one of our data processing partners. On occasions your information may be transferred to or stored at other locations, for instance when participating in events.
How do we protect your personal data?
We will not transfer your personal data outside the EU without your consent.
We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
Where we have given you (or where you have chosen) a password or PIN which enables you to access certain parts of the RDYC website or to use any RDYC App, you are responsible for keeping this password or PIN confidential. We ask you not to share passwords and PINs with anyone.
For any payments which we take from you online we will use a recognised online secure payment system.
We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
e event of any breach of your personal data which might expose you to serious risk.
Who else has access to the information you provide us?
We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where we are required to do so by law or as set out in the table above or in paragraphs below.
We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). We do this for the purpose of our legitimate interests in operating the club and for performing our contract with you. However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. It is possible that third parties may themselves engage others (sub – processors) to process your data. Where this is the case third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own purposes.
We may also pass your personal data to the Royal Yachting Association (RYA) for the purposes of carrying out surveys when it is in the legitimate interest of the club and the RYA to do so. The RYA may use third parties to carry out the surveys but disclose only the personal data that is necessary for the third party to do so and will have a contract in place that require the third party to keep your information secure and not to use it for their own purposes.
How long do we keep your information?
We will hold your personal data on our systems for as long as you are a member of the club and for as long afterwards as it is in the club’s legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
We securely destroy all financial information once we have used it and no longer need it.
You have rights under the GDPR:
- To access your personal data
- To be provided with information about how your personal data is processed
- To have your personal data corrected
- To have your personal data erased in certain circumstances
- To object to or restrict how your personal data is processed
- To have your personal data transferred to yourself or to another business in certain circumstances
You have the right to take any complaints about how we process your personal data to the Information Commissioner:
Helpline on 0303 123 1113.
Information Commissioner’s Office
Cheshire SK9 5AF
For more details, please address any questions, comments and requests regarding our data processing practices to our Honorary Secretary email@example.com