Bridgend County Swim Squad, (BCSS) – Croeso i Garfan Nofio Penybont Ar Ogwr
Introduction
Bridgend County Swim Squad is one of the leading competitive swimming clubs in South Wales. The primary objective of the Club is to foster, encourage and develop Swimming. “Swimming” in this context means swimming water polo synchronised swimming open water swimming and diving.
As part of the ongoing membership, training and assessment process, the Bridgend County Swim Squad (“BCSS”, “we”, “our” or “us”) hold and process personal data on various members, including swimmers, coaches, club volunteers and prospective individuals who would like to be a part of the Bridgend county swim squad. We take your data protection rights and our legal obligations seriously. Your Personal Information will be treated in a secure and confidential manner and only as set out below.
The following Fair Processing Notice describes the categories of Personal Information we may process, how your Personal Information may be processed and how your privacy is safeguarded in the course of our relationship with you. It is intended to comply with our obligations to provide you with information about BCSS’s processing of your Personal Information under privacy laws. It does not form part of your contract with us.
Bridgend County Swim squad (“BCSS”) will be the “controller” of your Personal Information. This means that BCSS is responsible for deciding how your Personal Information is used, and for ensuring (in conjunction with other parties involved in the processing of your Personal Information, as explained in this Fair Processing Notice) that your Personal Information is handled in compliance with applicable data protection law.
If you have any questions regarding the processing of your Personal Information or if you believe your privacy rights have been violated, please see “How to Contact Us” to find out how to get in touch.
Personal Information we collect
We process various categories of Personal Information, including the following:
- Contact Information that you provide to us at membership events or competitions, for the purpose of making an enquiry or registering with us to access a download (including Name, Email, Address, Telephone & Mobile number);
- Contact Information and any other information that you choose to provide to us when submitting a query or complaint, for example, if you want to attend an assessment;
- Information relating to any competitions – individuals details for participation and selection including information relating to any specific travel requirements;
- Information about your swimming details including your specific Qualifying Time (QT), Consideration Time , Upper Cut Off times (UCT); and
- Contact Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters (including opens, clicks, preference information, email and other contact information).
- Certain additional information may be collected where this is necessary and permitted by local applicable laws.
Sensitive Personal Information
BCSS does not currently process any Special Category Personal Information.
To the extent permitted by applicable laws BCSS may collect and process a limited amount of information regarding health conditions, special needs and disability (including information relating to any specific medical issues).
How does BCSS collect this data?
BCSS collects and records your Personal Information from a variety of sources, but mainly directly from you, i.e. information you specifically provide to us, for example when you register or make an enquiry regarding any specific swimming coaching or assessment or when you subscribe to an email newsletter, or give us your details an event or a county gathering or the membership form online.
What is the purpose and lawful basis for which data is processed?
Your Personal Information is collected and processed for various purposes within BCSS, in accordance with applicable laws. Where applicable data protection laws require us to process your Personal Information on the basis of a specific lawful justification, we generally process your Personal Information under one of the following bases:
- the processing is necessary for the legitimate interests pursued by BCSS (being those purposes described in the section below), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Information;
- the processing is necessary for compliance with a legal obligation to which BCSS is subject; or
- the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract.
We may also rely on other bases (for example, where the processing is necessary in the performance of a task carried out in the public interest, or where the processing is necessary in order to protect your vital interests or those of another person, or where you have given your consent) on an exceptional basis, where none of the above are applicable.
We have identified the following purposes for processing Personal Information.These purposes each relate to a lawful basis for processing, as required under applicable law. These purposes include:
| No. | Purpose for processing | Lawful basis |
|---|---|---|
| a. | To provide services which you have requested. | Where there is a membership contract in place between you (as an individual) and BCSS , this processing is necessary to perform the required services between you and BCSS Where there is no membership account in place, this processing is necessary for the legitimate interests pursued by BCSS. BCSS considers that it has a legitimate interest in providing our members with the services which they have requested, as this is central to our business. |
| b. | To conduct business with you (including obtaining and disclosing credit and billing information) | Where there is a membership contract in place between you (as an individual) and BCSS, this processing is necessary to perform the contract between you and BCSS BCSS considers that it has a legitimate interest in conducting business with its members, as this is central to our business: membership drives our revenues, helping us to preserve our business operations and grow our business. |
| c. | To correspond with you regarding competitions/ assessments. | Where there is a membership contract in place between you (as an individual) and BCSS, this processing is necessary to perform the contract between you and BCSS. BCSS considers that it has a legitimate interest in conducting assessments and processing the information, as this is central to our objective. Swimming improvements drives our business, helping us to preserve our operations and grow in the future. |
| d. | To provide you with information relating to our services which you have requested us to send to you, and to provide you with information on services which we think may be of interest to you or your organisation. | This processing is necessary for the legitimate interests pursued by BCSS. BCSS considers that it has a legitimate interest in ensuring that our members are kept up to date with information about our services, as this helps us to preserve our operations and grow our business. However, where we are required by law to obtain your consent before sending you such information, we will rely upon such consent as our basis for processing. In any case, if you tell us that you do not wish to receive such communications from us, we will respect your wishes. |
| e. | For market research purposes, to allow us to better understand our members needs and to provide you with better services. | This processing is necessary for the legitimate interests pursued by BCSS BCSS considers that it has a legitimate interest in ensuring that all of our members receive the best possible experience, helping us to preserve our business operations and grow our business. Understanding our members needs is a vital part of ensuring a great customer experience. |
| f. | To help us make our website easier to use, and to make the content more useful to you. | This processing is necessary for the legitimate interests pursued by BCSS BCSS considers that it has a legitimate interest in continually improving our website services in order to preserve our business operations and grow our business, and ensuring that you are provided with information of relevance to you. |
| g. | To provide you with information about technical issues, or to notify you in the event of an incident such as a data breach. | This processing is necessary for the legitimate interests pursued by BCSS BCSS considers that it has a legitimate interest in updating its members on any incidents that may affect them, in order to maintain a good relationship with our members BCSS may also in certain situations have a legal obligation to provide you with such information. |
| h. | Other purposes permitted by applicable laws, including legitimate interests pursued by BCSS where these are not overridden by the interests or fundamental rights and freedoms of staff. |
Retention of Personal Information
BCSS endeavours to ensure that Personal Information is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. However, some Personal Information may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.
We will generally retain your Personal Information only so long as it is required for purposes for which it was collected. This will usually be the period of your relationship with us plus the length of any applicable statutory limitation period following the end of such relationship, although some data may need to be kept for longer. For example, we may keep some specific types of data such as membership transactional records and squad reports for different periods of time, as required by applicable law.
Access to data
We will never sell or rent information about you, and we will ensure that our subscribers will only be able to access information if and when it is part of their job, and only for the purposes set out in this privacy policy. Within BCSS, your Personal Information can be accessed by or may be disclosed internally on a need-to-know basis to:
- local BCSS authority (coach/ medical staff) responsible for managing or making decisions in connection with your relationship with BCSS ;
- where necessary for the performance of specific tasks, by BCSS coaches or the administration teams such as the membership services or helpdesk for example, membership details may be used to provide a more personalised customer experience.
Your Personal Information may also be accessed by third parties with whom we work together with their associated companies and sub-contractors for providing us with services, such as hosting, supporting and maintaining the framework of our information systems. Personal Information may also be shared with certain interconnecting systems such as website content management systems. Data contained in such systems may be accessible by providers of those systems, their associated companies and sub-contractors.
Further examples of third parties with whom your data will be shared include tax authorities, regulatory authorities, BCSS insurers, IT administrators, lawyers, auditors, investors, consultants and other professional advisors, and service providers such as our email service providers and web analytics companies. BCSS expects such third parties to process any data disclosed to them in accordance with applicable law, including with respect to data confidentiality and security.
Where these third parties act as a “data processor” (for example, our email service provider ) they carry out their tasks on our behalf and upon our instructions for the above mentioned purposes. In this case your Personal Information will only be disclosed to these parties to the extent necessary to provide the required services.
In addition, we may share Personal Information about you:
- to the extent that we are required to do so by law;
- in connection with any legal proceedings or prospective legal proceedings, including in order to establish, exercise or defend our legal rights; and
Security of data
BCSS is committed to protecting the security of the Personal Information you share with us. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk.
However, please do remember that information transmission over the internet is inherently insecure, and we cannot guarantee the security of information sent over the internet.
Your rights
Right to access, correct and delete your Personal Information.
BCSS aims to ensure that all Personal Information it holds is correct. If the Personal Information which we hold about you needs to be corrected or updated, please let us know. For details on how to contact us, please see “How to Contact Us”. You have the right to request access to any of your Personal Information that BCSS may hold, and to request correction of any inaccurate data relating to you. You furthermore have the right to request deletion of any irrelevant data we hold about you.
From 25 May 2018, you also have the following additional rights:
Data portability – where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that Personal Information is processed by automatic means, you have the right to receive all such Personal Information which you have provided to BCSS in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
Right to restriction of processing – you have the right to restrict our processing of your Personal Information where:
- you contest the accuracy of the Personal Information until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the data;
- where we no longer need the Personal Information for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether BCSS has compelling legitimate grounds to continue processing.
- Where Personal Information is subjected to such restrictions we will only process it with your consent or for the establishment, exercise or defence of legal claims.
Right to withdraw consent – where we are relying on your consent to process data, you have the right to withdraw such consent at any time. You can do this by either contacting us (see “How to Contact Us”),
Right to object to processing justified on legitimate interest grounds – where we are relying upon legitimate interest to process data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your Personal Information infringes applicable law.
For further information regarding your rights, or to exercise any of your rights, please contact us using the details at “How to Contact Us”.
Notice of changes
BCSS may change or update this Fair Processing Notice at any time: we will post the new version on the relevant platform accessible to you (website/ hard copy by post). Should we make any material changes to this Fair Processing Notice, you will be informed of these changes or made aware that we have updated the Fair Processing Notice so that you always know which information we process and how we use this information.
This Fair Processing Notice was last updated and reviewed on 12th October 2022.
How to Contact Us
If you have any questions or complaints about this privacy policy or our treatment of your Personal Information, or would like to exercise any of your rights, please contact us at chair@bridgendcountyswimsquad.co.uk or secretary@bridgendcountyswimsquad.co.uk or alternatively write to The Chairman or BCSS Secretary at:
Bridgend County Swim Squad, Ynysawdre Pool, Heol-Yr-Ysgol, Tondu, Bridgend CF32 9ET