1. About this Policy
1.1 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.
1.2 We may collect, use and store your personal data, as described in this Data Processing Policy and as described when we collect data from you.
1.3 We reserve the right to amend this Data Processing Policy from time to time without prior notice. You are advised to check our website https://www.manorparksc.co.uk/ or our Club noticeboard regularly for any amendments (but amendments will not be made retrospectively).
1.4 We will 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.
2. Who are we?
2.1 We are Manor Park Sailing Club. We can be contacted at :
3. What information we collect and why.
Type of information -- Purposes / Legal basis of processing
Member's name, address, telephone numbers, e-mail address(es). -- Managing the Member's membership of the Club, Managing the duty roster,Performing the Club's contract with the Member & for the purposes of our legitimate interests in operating the Club.
The names and ages of the Member's dependants -- Managing the Member's and their dependants' membership of the Club Performing the Club's contract with the Member.
Emergency contact details -- Contacting next of kin in the event of emergency Protecting the Member's vital interests and those of their dependants
Date of birth / age related information -- Managing membership categories which are age related
Performing the Club's contract with the Member.
Gender -- Provision of adequate facilities for members. For the purposes of our legitimate interests in making sure that we can provide sufficient and suitable facilities (including changing rooms and toilets) for each gender.
Reporting information to the RYA. -- For the purposes of the legitimate interests of the RYA to maintain diversity data required by Sports Councils.
The Member's name, boat name and sail number -- Managing race entries and race results. Sharing race results with other clubs, class associations, and the RYA, and providing race results to local and national media. Allocating moorings and compound spaces. For the purposes of our legitimate interests in holding races for the benefit of members of the Club.
Photos and videos of members and their boats -- Putting on the Club's website and social media pages and using in press releases.
Consent : We will seek the Member's consent on their membership application form and each membership renewal form and the Member may withdraw their consent at any time by contacting us by e-mail or letter.
The Member's name and e-mail address -- Creating and managing the Club's online Membership Directory.
Consent : We will seek the Member's consent on their membership application form and each membership renewal form. The Member may withdraw their consent at any time by contacting us by e-mail or letter to tell us that they no longer wish their details to appear in the Membership Directory.
Bank account details of the member or other Managing the Member's and their dependants' membership of the Club, MPSC do not retain any individuals bank details
Member's name and email address -- Passing to the RYA for the RYA to conduct surveys of members of the Club (and members of other clubs affiliated to the RYA). The surveys are for the benefit of the Clubs (and other clubs) and / or the benefit of the RYA. For the purposes of our legitimate interests in operating the Club and / or the legitimate interests of the RYA in its capacity as the national body for all forms of boating
Instructor's name, address, email addresses, phone numbers and relevant qualifications and/or experience. -- Managing instruction at the club. For the purposes of our legitimate interests in ensuring that we can contact those offering instruction and provide details of instructors to members.
4. How we protect your personal data
4.1 We will not transfer your personal data outside the EEA without your consent. MPSC uses 'Zoho' as its chosen database platform for its membership system.
Zoho data-centres are SAS 70 Compliant and Zoho Corporation is a licensee of the TRUSTe® Privacy Program.
For a company Head-quartered in the EEA (European Economic Area) this is a critical concern. The (UK) Data Protection Act says that Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. This is the eighth data protection principle, but other principles of the Act will also usually be relevant to sending personal data overseas.
Zoho, as many Cloud providers, store their data outside the EEA so this piece of legislation impacts your decision making. There is a scheme called The Safe Harbor Scheme – it is recognised by the European Commission as providing adequate protection for the rights of data individuals in connection with the transfer of their personal data to signatories of the scheme in the USA.
Zoho is Safe Harbor compliant, therefore Zoho complies with requirements of the UK Data Protection Act
Information on Zoho's commitment to GDPR compliance can be found at : https://www.zoho.eu/gdpr.html
4.2 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. We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
4.3 Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
4.4 For any payments which we take from you online we will use a recognised online secure payment system.
MPSC uses Paypal for its online debit/credit card payments and 'GoCardless' for direct debit arrangements.
4.5 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
5. Who else has access to the information you provide us?
5.1 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 required to do so by law or as set out in the table above or paragraph 5.2 below.
5.2 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). 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.
6. How long do we keep your information?
6.1 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 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.
6.2 We securely destroy all financial information once we have used it and no longer need it.
7. Your rights
7.1 You have rights under the GDPR:
(a) to access your personal data
(b) to be provided with information about how your personal data is processed
(c) to have your personal data corrected
(d) to have your personal data erased in certain circumstances
(e) to object to or restrict how your personal data is processed
(f) to have your personal data transferred to yourself or to another business in certain circumstances.
7.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner:
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 Membership Secretary @ email@example.com.
If you have any queries, questions or comments on the information contained in this leaflet, kindly contact the Legal Team on 023 8060 4223 or firstname.lastname@example.org.
RYA Responsibility Statement:
The RYA Legal Team provides generic legal advice for RYA members, affiliated clubs and Recognised Training Centres. The information contained in this Guidance represents the RYA's interpretation of the law as at the date of this edition. The RYA takes all reasonable care to ensure that the information contained in this Guidance is accurate and that any opinions, interpretations and guidance expressed have been carefully considered in the context in which they are expressed. However, before taking any action based on the contents of this Guidance, readers are advised to confirm the up to date position and to take appropriate professional advice specific to their individual circumstances.
Last updated 17:01 on 9 February 2020