Staffordshire Moorlands Athletics Club Data Privacy Policy

Contents

1. About us

2. Introduction

3. Whose data do we collect?

4. The information we collect about you

5. The information provided to us by third parties

6. How we use your information

7. Our legal bases for processing your information

8. Protecting your information

9. Your rights

10. Sharing your data

11. Finding out what information the Club holds about you

12. Data retention

13. Website and Membership Portal Technical Data

14. Facebook and other social media

15. Changes to our Data Privacy Policy

16. Contacting the Club about this Privacy Policy

17. Complaints

Amendments

2018-04

Version 1.0

Original version

2018-12

Version 1.1

Added clarification that no additional personal data passed to EA for currently affiliated members.

Page 9 Section 7.2 Affiliation

1. About us

Staffordshire Moorlands Athletics Club (we, the Club) is a community, amateur sports club which promotes and encourage Cross Country and Road Running, Track and Field Athletics, Fell running and Multi-discipline activities in the district of Staffordshire Moorlands.

In this document you can find out about

• Introduction

• Whose data we collect

• The information we collect about you

• The information provided to us by third parties

• How we use your information

• Our legal bases for processing your information

• Protecting your information

• Your rights

• Sharing your data

• Finding out what information the Club holds about you

• Data Retention

• Website and Membership Portal Technical Data

• Changes to our Privacy Policy

• Contacting the Club about this Privacy Policy

• Commitment to Privacy Policy

• Complaints?

2. Introduction

The Club licenses and manages an on-line Membership Portal for enrolling and administering its membership. It also captures, stores and processes race entry and results information. For the purposes of data protection legislation, the Club is the data controller.

The Club is committed to protecting your privacy and processing your personal data in accordance with the Data Protection Act (DPA) 1998 up to 24 May 2018 and the General Data Protection Regulation (GDPR) on and from 25 May 2018 (Data Protection Legislation). This Privacy Policy explains how the information we collect about you is used and kept securely. It also explains your privacy choices when using our Membership Portal and our website as well as your right to access your information under Data Protection Legislation.

3. Whose data do we collect?

The Club collects personal data from its members and from entrants to the races it organises.

4. The information we collect about you

When you join the Club we may collect the following information about you through our Membership Portal (or in exceptional circumstances via membership form from which we will transcribe the data to the Membership Portal):

• Your User id, password, and email address. We call this your User Data.

• Your name, title, email address, postal address, telephone number, membership type, date of birth, gender, county of birth, nationality, relevant qualifications, licences or clearances you may hold (e.g. coaching, DBS clearance) together with their validity dates and other club affiliations. We call this your Membership Data.

We collect the Membership Data of all members including each member who joins under the family group membership scheme. All members in a family group membership scheme will be linked to the same User Id. If you join as an Associate Member (e.g. parent/guardian to manage a family group membership or helper) we will not collect information about your date of birth, gender, county of birth, nationality and other club affiliations.

• Your IP address (which is a unique identifier that computers and devices use to identify and communicate with each other) which is automatically recognised by the web server.

If you choose to affiliate to England Athletics we will collect from them and store your URN number

If you register for one of our races/race series we will collect from you:

• Your name, email address, telephone number, date of birth, gender and, if any, your EA affiliated club. We call this your Registration Data.

5. The information provided to us by third parties

In the event we use a third party race entry service, the race entry service provider will pass to us the information you entered into the on-line entry form.

England Athletics does not send us your URN but a limited number of officials of the Club have access to certain of your Athletics Data (as defined by England Athletics, see www.englandathletics.org/priva...) and we will retrieve and copy your URN into your Membership Data for administrative purposes and to provide it to you through the Club’s Membership Portal.

6. How we use your information

We may use your User Data and Membership Data for a number of purposes, including:

To administer your membership, payment of subscriptions, and deal with your requests and enquiries.

•  To affiliate you with England Athletics

• To contact you for reasons related to your membership.

To notify you about and to organise: training sessions, training groups, competitions and Club social functions.

To make team selections and enter you into competitions

• To organise and stage races

To monitor trends within the Club and Club races

• To use your IP address to monitor traffic and gather browsing behaviours of visitors to our Membership Portal and website. We will not use your IP address to identify you in any ? way.

Subject to your consent, to send you promotional information related to kit, sports equipment or athletics/running events

We may use your Registration Data for the following purposes:

• To organise and administer races and to compile and publish race results

7. Our legal bases for processing your information

7.1.Legitimate Interest

Members

We will process your Membership Data and User Data on the basis of the following legitimate interests:

Organising training and entering competitions

Organising training, providing coaching and entering teams & individual representatives of the Club into competitions are core activities of the Club and the primary reasons why members join.

This includes activities such as making team selections, submitting the entries for the team/Club representatives to the competition organisers, corresponding with members (for example providing notification of upcoming events, determining availability to compete & arranging logistics of travel to competition venues).

For these purposes we may share your Membership Data with:

• Club coaches, team managers and members assisting them, club members organising training groups (e.g. Ultra-distance, Ladies fitness, Fell running), club members offering transport to competition venues;

Leagues, county associations (and county schools’ associations) and other competition providers for entry in events;

Facility providers to manage access to the track or training session venues.

• Other EA registered coaches which the Club engages to run or supplement coaching sessions

You may opt out of (and back in to) receiving correspondence about training and competitions at any time but by default we assume that as a member you will want to receive this information.

Organising and staging Races

Organising and staging races (including but not only the Christmas Cracker and the Summer Series) is a core activity of the Club. As a voluntary organisation we rely on members to help with the activities involved in staging a race (for example marking out the course, recording finishing positions, marshalling).

For this purpose we may use your Membership Data to communicate with you to seek volunteers to be part of the race organisation/management team and we may share your Membership Data with the designated race director and the club members who come together to form the race organisation/management team.

Managing the Club and its Membership

In joining the Club members are bound by the Club Constitution. A Management Committee is elected to further the interest of the Club and to manage it in accordance with the Constitution. The Management Committee, any sub-committees it appoints including co-opted or delegated members not themselves members of the Management Committee, may use your Membership Data when necessary for the purpose of managing the Club and its Membership including (but not only) the following activities:

• Processing of membership applications, renewals and payments,

• Provide information to members about club activities, membership renewals or invitation to social events,

• Contacting members in connection with Club business

• Co-ordinating and overseeing the core objectives of the Club (EA Affiliation, Training, provision of coaches, Competition Entry and Staging Races),

• Recruitment of new members,

• Website and Membership Portal management and maintenance, for which purpose we may appoint third party service providers as data processors

• Publicising and promoting the Club including publishing race results & race reports (including photographs) and aggregated and/or anonymised Membership Data

• Monitoring Club trends using anonymised and/or aggregated Membership Data

• Other activities necessary for the good governance of the Club and the achievement of its objectives as defined in its Constitution.

We may share limited contact information of members holding relevant roles to prospective members.

We may also pass anonymised and/or aggregated Membership Data to relevant third parties such as governing bodies, local authorities, sponsors and organisations involved in provision of sport and competition where necessary to secure services, grants, funding or club reserved places in major events (e.g. London Marathon organisers/sponsors).

If you joined the Club as part of a family group membership or you are a junior member registered by your parent/guardian, then for the purposes of membership renewal and Membership Data maintenance we will share your Membership Data, via the on-line Membership Portal with the Membership Portal User recorded in your Membership Data as the User who originally/last entered (or updated) your Membership Data.

Providing a self service Membership Portal

The Club collects and uses Membership Data as set out in this Privacy Policy. To provide members with the ability to access and modify their own Membership Data, to see the data the Club holds about them and to facilitate membership registrations and renewals the Club provides its members with a self service Membership Portal.

We use your User Data to

• Provide access to the on-line membership portal through which you can join, renew membership, update and amend your Membership Data including setting your mailing list preferences and changing your affiliation need. If your User Id is associated with multiple members (i.e. you manage a family group membership and registered multiple members, we will also provide access to the Membership Data for each member in your group.

• Monitor use of the Membership Portal

• Maintain the Membership Portal and User Data, including diagnosing and fixing any issues reported to us by Users.

When you access the Membership Portal we place cookies on your computer. Please see section 13 below for details and information on how you can control this technical data.

Race Entries

If you enter one or more of the Club’s races we will use your Registration Data on the basis of the

following legitimate interests:

Administering the race (or series of races) and publishing the Results

An athlete entering a race and who completes the entry form, whether on paper or on-line, and pays the entry fee will expect the Registration Data they provide to be used to allocate them a bib number, assign them to the correct age category and be used in the published results.

The athletes will also expect the race organisers to comply with any requirements of the governing body or other authorities entitled to impose regulations.

For the purpose of administering the race and collating and publishing the results we may pass Registration Data to the governing body or any affiliated organisation for the purpose of insurance, licences or for publishing results either for the event alone or combined with or compared to other events.

We may also use the Registration Data to contact you if we have any queries about your data or your participation in the race which prevents accurate calculation of the results (e.g. illegible entry form, missing date of birth)

Published results may including your name, your gender, your EA club affiliation, your age category and your race finishing position and time. For a series of races it also includes your overall series score and position. We call the data used for publishing the results your Results Data. Results Data is retained indefinitely for historical and archive purposes and may be shared with local newspapers, race results web sites.

The Club will post the Results on its website within a reasonable time after the race and athletes may address queries or report errors to the Club using the link provided. Any errors reported in this way will be investigated and if appropriate and within the rules or the race, corrected. If a correction is not made the Club will explain its reasoning to the Athlete.

7.2.Consent

Where you have opted in to

• Affiliating to England Athletics

• Receiving any of the marketing or promotional communications

we will process your Membership Data on the basis of your consent.

We do not share any of your data with third parties for marketing or promotional reasons.

Affiliation

If you want to compete for the Club you will need to be affiliated to the governing body, in our case England Athletics (EA).

If, when you join the Club (or at any time after) you indicate that you wish to be affiliated (and you are not transferring as an already EA affiliated member from another club) we will arrange the affiliation for you and pass your name, date of birth, gender, email address, postal address, telephone number (as provided by you through the Membership Portal) to England Athletics.

Please refer to England Athletics for information on how it uses and safeguards your data.

If you affiliate to England Athletics we will collect from them your URN and add it to your Membership Data.

Exception: if you were already affiliated to EA through the Club before 25th May 2018 EA already holds your data and the Club will not pass further personal data to EA nor update, change, or delete any of your personal data held by EA. If you opt to continue with and pay for your affiliation when it is due for renewal the Club will pass your payment through to EA and notify them through EA’s online portal that you have paid. Please refer to England Athletics for information on how it uses and safeguards your data.

Marketing or Promotional Communications

Subject to your separate consent we may also use your data for the following marketing purposes:

- - - -

Sending you information about promotions and offers from sponsors

Sending you the club news letter (or notice that it has been published on the Club Website) Sending you information about selling club kit, merchandise or fundraising

Sending information about races staged by other clubs (other than competitions entered by the Club)

We will only send you the marketing communications you consent to receive using the preference settings which you can manage and change at any time through the Membership Portal.

If you are currently receiving marketing communications from the Club and no longer wish to do so, please change your preference settings through the Membership Portal or let us know by contacting us at membership@staffsmoorlands-ac.co.uk.

8. Protecting your information

The Club does not own its own computer infrastructure. We contract with a hosting service for the provision of the software applications and computer infrastructure used to store and process the information.

The servers and the applications we use are managed by our hosting service provider in accordance with our instructions. The servers on which the data is currently stored are leased by our hosting service provider and located in a secure facility within in the UK.

Our hosting provider uses relevant, up-to-date industry procedures to protect your personal information. We also protect the security of your data using Secure Sockets Layer (SSL) encryption technology.

For practical reasons members may also process your personal data on their own devices:

• Registration Data and Results Data may initially be captured and processed on laptop computers, which may belong to the member(s) of the club who has/have volunteered to help with the activity, before being transferred to the servers.

• Coaches and team managers processing race entry forms when submitting entries to competitions on behalf of the Club may need to transfer Membership Data to their own devices. They will be made aware of and required to acknowledge the Acceptable Use Policy.

• Coaches, team managers and other members assisting with Club events may store relevant contact information from your Membership Data on their mobile phones or other communications devices.

The Club members processing personal data on their own devices are made aware, through our Acceptable Use Policy, of the rules which includes an obligation to restrict the use of the data to the purposes for which it was collected, require them to safeguard it as they would safeguard their own personal data and to delete it once the purpose no longer requires it.

We will not transfer your data outside of the European Economic Area.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. The Internet is not generally a secure medium for communication and therefore we cannot guarantee the security of any information you send to us over the Internet.

9. Your rights

You have the following rights under data protection legislation:

I. to access a copy of the information comprised in your personal data;

II. to object to processing of your personal data that is likely to cause or is causing damage or distress;

III. to prevent processing for direct marketing;

IV. to object to decisions being taken by automated means;

V. in certain circumstances, to have inaccurate personal data rectified, blocked, erased or destroyed; and

VI. to claim compensation for damages caused by a breach of data protection legislation.

10. Sharing your data

We may share your personal data with Club members and third parties as set out in this Privacy Policy, including data processors. We will not transfer your data to any other third parties without obtaining your consent.

The Club may also share your personal information with the police and other law enforcement agencies for the purposes of crime prevention or detection.

11. Finding out what information the Club holds about you

Under the Data Protection Legislation, you can ask to see any personal information that we hold about you. Such requests are called subject access requests. If you would like to make a subject access request, please email the Club using address: dataprotection@staffsmoorlands-ac.co.uk

You may also need to provide two forms of identification, for example, driving licence, utility bill or passport and, if appropriate, any particulars about the source or location of the information you are requesting.

12. Data retention

Any data that we collect from you will be deleted in accordance with timescales set out below:

Data type* Retained until/Deleted Justification

Membership Data

Retained until the end of the 3rd membership year (31st March) following the year in which you leave the Club or until all fees owed to the Club have been paid whichever is latter, when it will be deleted.

Need to collect fees owed and to administer promotions for new members and process re-joiners

User Data

Deleted promptly following request to delete the User account

Note that associated Membership Data will be retained/deleted as above

Results Data

Retained indefinitely

Archive and historic reasons.

Registration Data

Retained until the close of registration of the same event the following year and then deleted unless you re-entered the event.

To simplify administration of regular entrants, of which significant number

13. Website and Membership Portal Technical Data

In this section you will find information on what cookies may be set when you visit the Club Membership Portal or the Club website and how to manage and disable them. The use of cookies does not give us access to the rest of your computer and only the site that created the cookie can read it.

By using the Club Website or the Membership Portal site you consent to the relevant cookies being set on your device.

13.1. Membership Portal (membership.staffsmoorlands-ac.co.uk)

When you use the Membership Portal we place a small cookie on your computer. This cookie contains the identity of the application and the club’ server domain (i.e. the identify of who placed the cookie) and a unique session id which is set when you log in with your User Id and password. When you log out of the Membership Portal or close the browser session completely the cookie will be disabled and become unusable.

Each time you visit the Membership Portal it will check whether there is an active cookie for the current browser session. If there is not because you have logged out, completely ended the browser session in which you last visited the site or you have deleted cookies from you computer you will need to log in again. If you did not completely close your browser session or log out the cookie will still be active and the Membership Portal will use it to identify you are and you will not need to log in again. This type of cookie as known as a Session Cookie.

We do not use cookies to remember you between browser sessions and we do not use cookies to collect any personal data.

13.2.Website (www.staffsmoorlands-ac.co.uk)

When you visit our website (either as a public user or whether you log in) we will place a Session Cookie and use it as described above for the Membership Portal.

In addition we use Google Analytics to monitor the traffic to our website and the patterns of use, such as, but not only, pages visited, number of repeat and new users.

Google Analytics (GA) is a web usage monitoring service provided by Google. To provide the service Google places:

• a cookie record the time of your first visit to website, the time of your most recent visit to the website and the time of your current visit;

• a cookie to record how long you stayed on the website;

• a cookie to record how you located our website (i.e. Google search, keyword, link from other page etc).

In order to determine first time and repeat visits to the site some of the GA cookies are persistent. This means they will remain active after you log out or completely terminate the browser session.

We only share the information obtained through the use of Google Analytics with Google. For more information on Google’s use of your information, please visit the Google Privacy and Data Sharing pages.

The cookies we use for these purposes do not track your Internet usage after leaving our website and we do not store your personal information. They will also not be used in connection with any other information to identify you in any way.?

To prevent Google Analytics cookies being set, you may wish to install the Google Analytics Opt- Out Browser Add-On (http://tools.google.com/dlpage...).

13.3. Can I opt out of cookies?

The Club will not use cookies to collect personally identifiable information about you. Yes you can restrict or block the cookies which are set by our websites, and you can do so by accessing your Internet browser settings. The ’Help’ function within your browser should tell you how.

For general information about cookies and how to disable them, please visit: http://www.aboutcookies.org or http://www.allaboutcookies.org

Please be aware that restricting cookies may impact on the functionality of our website and especially the Membership Portal.

For information on how to manage cookies on a mobile phone, games console or internet-enabled television, you should refer to the operations manual specific to each device.

14. Facebook and other social media

Some members of the club have set up a Facebook page under the banner of the Club. The page is a public page and anyone anywhere with access to Facebook may view, post articles and other items which they believe will be of interest to other runners.

The Club does not use the Facebook page for collecting any personal information or for sharing personal data it has collected and it does not rely on Facebook for conducting Club business.

Members are advised that the Facebook page should be used only for their own domestic and leisure reasons related to their enjoyment of running, showcasing their achievements and communicating with other like minded people. Members who use the site are responsible for maintaining their own Facebook profile and security settings and should never request or post their own or any other person’s personal data.

15. Changes to our Data Privacy Policy

We regularly review our Data Privacy Policy and updates will appear on this page when necessary. This Privacy Policy was last updated in April 2018.

16. Contacting the Club about this Privacy Policy

If you have any questions or comments about this Privacy Policy please email us at: dataprotection@staffsmoorlands-ac.co.uk

17. Complaints

If you have any concerns or complaints in relation to how the Club collects and/or processes your personal data, you should contact the Club secretary in the first instance. If you are dissatisfied with how your concern/complaint is dealt with by the Club, you have the right to report your concern/complaint to the Information Commissioners Office (www.ico.org.uk).

SMAC-DPPolicy 2018-12