PRIVACY POLICY AND COOKIES POLICY

 

We at the Wirral Sports Forum (WSF) want to make sure all the personal information we have collected about you is safe and secure, whether we collect it through our website at www.wirralsportsforum.co.uk or from other sources.  This Policy set outs our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our WSF Secretary has overall responsibility for data protection compliance in our organisation.  If you have any questions about this Policy or what we do with your personal information, their contact details are set out in the “Contact” section below.
Privacy NOTICES
Collecting specific, relevant personal information is a necessary part of us being able to manage our relationship with you, our members/affiliates.
When we hold or use your personal information as a data controller (see below for a description of what this is) we will provide you with a link to this privacy notice which sets out in detail what information we hold about you (such as your contact details, address, etc.), how your personal information may be used and the reasons for these uses, together with details of your rights. 
Where we collect personal information from about you we will provide a link to this privacy notice at the time we collect the personal information from you. 
We will only provide this privacy notice to you once, generally at the start of our relationship with you.  However if the applicable privacy notice is updated substantially, then we may provide you with details of the updated version.  You are encouraged to check back regularly for updates on the WSF website (www.wirralsportsforum.co.uk).

 

 

 

 

 

 

Copies of our current privacy notices can be found below:

·         Member/Affiliates privacy notice

THE DIFFERENCE BETWEEN DATA CONTROLLERS/PROCESSORS

A data controller is a person who controls how personal information is processed and used.  A data processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller.

This distinction is important.  You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below to see what rights you have).  These rights can generally only be exercised against a data controller of your information. 

In most cases we will not be a data controller of your personal information.  In any case where we are not a data controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the data controller (i.e. the person who controls how we process the personal information).  In these cases we will endeavour to inform you who is the data controller of your personal information so that you can direct any such requests to them.

Also it is only a data controller that will provide you with a privacy notice about your personal information, so where we process your personal information as a data controller we will provide you with a privacy notice.  Where we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.

 

 

HOW DO WE USE YOUR PERSONAL information?

We will use your personal information as described in the privacy notice provided to you, but, for example, we may use your personal information to administer any account(s) you have with us or to send you information we think you might find useful, provided you have indicated that you are happy to be contacted for these purposes.  To see how we use your personal information, please see our current privacy notices, which can be accessed below:

·         Member/Affiliates privacy notice

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Details of how we disclose your personal information are set out in the relevant privacy notice provided to you, but generally it is where we need to do so in order to run our organisation (e.g. where other people process information for us). In such circumstances, we will put in place arrangements to protect your personal information.  Outside of that we do not disclose your personal information unless we are required to do so by law. 

If we transfer personal information about you outside the European Economic Area (EEA), we will let you know and ensure that all reasonable security measures are taken and that any third party processers will be required to process the information in accordance with information protection laws and we will notify you in your privacy notice if we are the information controller.

We do not sell, trade or rent your personal information to others.

HOW LONG DO WE HOLD ON TO YOUR PERSONAL INFORMATION?

Further details of how long we hold onto your personal information for are set out in the relevant privacy notice provided to you, but we will only hold your information for as long as is necessary or where you ask us to delete records we may delete it earlier. 

The duration for which we retain your personal information will differ depending on the type of information and the reason why it was collected. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.

what are Your rights?

Full details of your rights set out in the relevant privacy notice provided to you, but you are entitled by law to ask for a copy of your personal information at any time. You are also entitled to ask us to correct, delete or update your personal information, to send your personal information to you or another organisation and to object to automated decision making. Where you have given us your consent to use your personal information in a particular manner, you also have the right to withdraw this consent at any time. 

To exercise any of your rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contact” section below. You can also unsubscribe from any direct marketing by clicking on the unsubscribe link in the marketing messages we send to you.

You should note that some of your rights may not apply as they have specific requirements and exemptions which apply to them and they may not also apply to personal information recorded and stored by us.  However your right to withdraw consent or object to processing for direct marketing are absolute rights.

If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner’s Office or your local data protection regulator. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.  However, we are here to help and would encourage you to contact us to resolve your complaint first.

linking with third party sites

Our Site may, from time to time, contain links to and from other websites of our.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.

In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

SECURITY

We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information. 

Cookies

Certain parts of our Site use “cookies” to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store on your computer’s hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited. The only personal information a cookie contains is information that you have personally supplied.

We use cookies on our Site to enable us to deliver content that is specific to your interests and gives us an idea of which parts of the Site you are visiting and to recognise you when you return to the Site. Reading cookies does not give us access to other information on your computer’s hard-drive and our Site will not read cookies created by other websites that you have visited.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If, however, you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access the Site.

Please note providers of third party content may also use cookies over which we have no control.

LOG FILES

In common with most websites, our Site logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.

We may use this information to analyse trends, administer the Site, track your movement around the Site and gather broad demographic information.

Changes to this policy

Any changes we may make to this Policy in the future will be posted on our Site and, where appropriate, notified to you by e-mail. When we change this Policy in a material way, we will update the version date at the bottom of this page. Please check back frequently to see any updates or changes to this Policy and should you object to any alteration, please contact us as set out in the “Contact” section below.

Contact

In the event of any query or complaint in connection with the information we hold about you, please email davesimmonds@wirral.gov.uk or write to us at:

Dave Simmonds, Community Sports Development Officer, Wirral Sports Development Unit, 1st Floor, Conway Centre, Conway Street, Birkenhead CH41 6JD

Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

WIRRAL SPORTS FORUM

PRIVACY NOTICE FOR OUR MEMBERS/AFFILIATES

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your membership with us. This notice applies to you if you have registered to become or are a member of our club. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.

 

References to we, our or us in this privacy notice are to the Wirral Sports Forum (WSF)

 

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws [as we are not required to do so, but our WSF Secretary has overall responsibility for data protection compliance in our organisation.  Contact details are set out in the “Contacting us” section at the end of this privacy notice.

 

  1. Personal Information we may collect from you

Depending on the type of membership you register for with us, you may initially provide us with or we may obtain personal information about you, such as information regarding your:

  • personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers;
  • date of birth;
  • gender;
  • membership start and end date;
  • references and other information included in, for example a nomination application or cover letter or as part of the application process for membership;
  • any records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
  • any credit/debit card and other payment details you provide so that we can receive payments from you and details of the financial transactions with you;
  • [use of and movements through our online portal, passwords, personal identification numbers, IP addresses, user names and other IT system identifying information;]
  • records of your attendance at any events hosted by us;
  • CCTV footage and other information obtained through electronic means such as swipecard and key fob records;
  • images in video and/or photographic form and voice recordings;
  • your marketing preferences so that we know whether and how we should contact you.
  • identification documents such as passport and identity cards;
  • details of any county membership;
  • details of next of kin, family members, coaches and emergency contacts;
  • records and assessment of any player rankings, grading or ratings, competition results, details regarding [events/matches/games] attended and performance (including that generated through player pathway programme);
  • any disciplinary and grievance information;
  1. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:

  • information about your race or ethnicity, religious beliefs and sexual orientation;
  • information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
  • biometric information about you, for example fingerprints, retina scans.

We may not collect all of the above types of special category personal information about you. In relation to the special category personal data that we do process we do so on the basis that

  • the processing is necessary for reasons of substantial public interest, on a lawful basis;
  • it is necessary for the establishment, exercise or defence of legal claims;
  • it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
  • based on your explicit consent.

In the table below’ we refer to these as the “special category reasons for processing of your personal data”.

 

We may also collect criminal records information about you. For criminal records history we process it on the basis of legal obligations or based on your explicit consent.

 

  1. WHERE WE COLLECT YOUR INFORMATION

We typically collect personal information about our members/affiliates when you apply to become a member/affiliate of the WSF, you register with us at www.wirralsportsforum.co.uk, when you purchase any services or products we offer, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.

We also may collect personal information about you from any third party references you provide as part of the application process for membership.

If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information.  Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it.  They also have the same rights as set out in the “Your rights in relation to personal information” section below.

 

  1. Uses made of the information

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose

Personal information used

Lawful basis

To administer any membership you have with us and managing our relationship with you, including dealing with payments and any support, service or product enquiries made by you

All contact and membership details, transaction and payment information, records of your interactions with us, and marketing preferences.

 

This is necessary to enable us to properly manage and administer your membership contract with us.

 

 

To arrange and manage any contracts for the provision of any services or products

Contact details, transaction and payment information.

 

Records of your interactions with us.

This is necessary to enable us to properly administer and perform any contract for the provision of any services and products you have purchased from us.

To send you information which is included within your membership benefits package, including details about advanced ticket information, competitions and events, partner offers and discounts and any updates on events linked to the WSF

Contact and membership details.

This is necessary to enable us to properly manage and administer your membership contract with us.

 

To send you other marketing information we think you might find useful or which you have requested from us, including our newsletters, information about membership, events, products and information about our commercial partners

Contact details and

marketing preferences.

Where you have given us your explicit consent to do so

To answer your queries or complaints

Contact details and records of your interactions with us

We have a legitimate interest to provide complaint handling services to you in case there are any issues with your membership.

Retention of records

All the personal information we collect.

We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your membership and run our club and in some cases we may have legal or regulatory obligations to retain records.

We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.

For criminal records history we process it on the basis of legal obligations or based on your explicit consent.

The security of our IT systems

Your usage of our IT systems and online portals.

 

We have a legitimate interest to ensure that our IT systems are secure.

To conduct data analytics studies to better understand event attendance and trends within the sport

Records of your attendance at any events or competitions hosted by us.

We have a legitimate interest in doing so to ensure that our membership is targeted and relevant.

For the purposes of promoting the club, our events and membership packages.

Images in video and/or photographic form.

Where you have given us your explicit consent to do so  N.b. Our  best practice would be to obtain consents where we intend to use any images or footage of members in any promotional campaigns, particularly where there are children involved.

To comply with health and safety requirements

Records of attendance, possible CCTV footage and other information obtained through electronic means such as swipecard and key fob records, medical information about your health

[biometric information about you, for example fingerprints, retina scans]

 

We have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate.

We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.

To administer your attendance at any courses or programmes you sign up to

All contact and membership details,

transaction and payment data.

 

Details of any county membership and performance data.

 

This is necessary to enable us to register you on to and properly manage and administer your attendance on the course and/or programme.

To arrange for any trip or transportation to and from an event

Identification documents details of next of kin, family members and emergency contacts, transaction and payment information, health and medical information.

This is necessary to enable us to make the necessary arrangements for the trip and/or transportation to an event.

We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above

To comply with legal obligations, for example, regarding people working with children or vulnerable adults to comply with our safeguarding requirements

Information about your criminal convictions and offences

 

For criminal records history we process it on the basis of legal obligations or based on your explicit consent.

 

For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you do not provide us with the requested personal information we may not be able to admit you as a member/affilaite or we may not be able to properly perform our contract with you or comply with legal obligations and we may have to terminate your membership.  For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you.

 

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.

 

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain member benefits to you.

 

  1. DIRECT MARKETING

Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about events/meetings we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages by contacting the WSF secretary

 

  1. Disclosure of your PERSONAL information

We share personal information with the following parties:

 

  • Any party approved by you.
  • To any governing bodies or regional bodies for the sports covered by the WSF: to allow them to properly administer the sports on a local, regional and national level.
  • The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
  • Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

 

  1. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

[The personal information we collect is not transferred to and stored in countries outside of the UK and the European Union.]

 

  1. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements.  Generally, where there is no legal requirement we retain all physical and electronic records for a period of [6] years after your last contact with us or the end of your membership.  Exceptions to this rule are:

 

  • CCTV records which are held for no more than [30 days] unless we need to preserve the records for the purpose of prevention and detection of crime;
  • Details regarding unsuccessful membership applicants where we hold records for a period of not more than [12] months;
  • Information that may be relevant to personal injury or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after the event.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address. Alternatively, you can contact us by using the details set out in the “Contacting us” section below.

 

  1. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

 

  • the right to be informed about how your personal information is being used;
  • the right to access the personal information we hold about you;
  • the right to request the correction of inaccurate personal information we hold about you;
  • the right to request the erasure of your personal information in certain limited circumstances;
  • the right to restrict processing of your personal information where certain requirements are met;
  • the right to object to the processing of your personal information;
  • the right to request that we transfer elements of your data either to you or another service provider; and
  • the right to object to certain automated decision-making processes using your personal information.

 

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example, we do not use automated decision making in relation to your personal data.  However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

 

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

 

  1. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

 

  1. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email davesimmonds@wirral.gov.uk or write to us at:

 

Dave Simmonds

Community Sports Development Officer

Wirral Sports Development Unit

1st Floor

Conway Centre

Conway Street

Birkenhead CH41 6JD

 

 

 

Version dated 1st April 2018

 

 

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