This privacy notice tells you what to expect when we use personal information about you. We want you to be fully informed about how we use your data and your rights. We have used examples throughout, which are not intended to be exhaustive.
For simplicity throughout this notice, ‘use’ means collecting and processing personal data.
2. Who we are
3. How we get your information
Most of the personal information we process is provided to us directly by you for one or more of the following reasons:
- You joined the club
- You took part in a club ride or other event
- You entered an event or competition we organised
- You made an enquiry to us
- You are representing your organisation
Under some of the above reasons we will add to the information you have provided, recording and creating new personal data about you, such as your attendance at a meeting, or your competition result.
We also receive personal information indirectly in these scenarios:
- When you enter our events or competitions through one of our service providers, such as British Cycling’s online entry system
- When a club member or race entrant gives your contact details as an emergency contact
4. How we use your personal information
Purpose and legal basis for processing
The law on data protection sets out a number of bases under which an organisation can use your personal data. Our purposes in using your personal information and the legal bases we rely on are as follows:
- To manage the club, including membership and subscriptions, and where necessary, disciplinary matters. This is in accordance with the legal basis of ‘legitimate interests’, which allows us to process personal information when it is in our interests. Our interests are the proper management of the club and your relationship with us.
- To inform club members about our activities and events they may wish to participate in, in accordance with the legal basis of ‘legitimate interests’, which allows us to process personal information when it is in our interests. Our interests are for you to get the most from your membership.
- To administer competition entries and results, in accordance with the legal bases of ‘contract’ and ‘legitimate interests’. These bases allow us to process personal information when it is necessary for the preparation of, or performance of, a contract with you, or when it is in our interests. Our interests are to publicise the results of our competitions.
- To promote the club, in accordance with the legal basis of ‘consent’, which allows us to process personal information where you have given clear consent for this purpose. Where you have given your consent, you may withdraw it at any time by contacting us at email@example.com
- To keep children and other vulnerable individuals safe, in accordance with the legal basis of ‘legal obligation’, which allows us to process personal information when it is necessary to comply with the law. For example, our obligations to operate Safeguarding under the Working Together to Safeguard Children statutory guidance by the Department for Education.
Should you withdraw consent previously given to us to process your data, this applies to future processing. Past processing is not affected.
5. Use of Personal Data for Promoting the Club
Occasionally, we would like to use your personal data to promote the club, for example on our web site, via social media, or in Spokespiece magazine. This could include your name, photographs or videos, and information about your involvement with the club.
We will only use your personal data for this purpose if you give your consent. However, you may appear in the background of photographs where others are the focus, or in large groups, such as at events.
We will use your information responsibly and carefully. We will not include your full name unless there is a good reason to do so, for example when it is in connection with an event or achievement specific to you, such as winning a race. We will never include your address.
We will not provide your information to third parties. However, if your personal data is used on the internet, we cannot control who might independently share it or use it anywhere in the world.
Consent is a completely free choice for you to make and has no effect on your membership or relationship with us.
If you give your consent, you can withdraw it at any time by contacting firstname.lastname@example.org. After doing so, your personal data will not be used in future. Withdrawing consent is not retrospective and uses of your personal data prior to the withdrawal cannot be changed. For example, publications in circulation and materials printed but not yet circulated.
Please note that where we use your personal data in connection with an event, for example by publishing a list of results and photos from a race, this is not based on your consent. See bullet #3 in section 4.
6. What we need to collect
We need to know basic personal information, including your date of birth and contact information. We may also ask for contacts in the event of an emergency, if you are involved in an incident connected with a club activity, but we do not store that data.
We also hold information about your involvement in club events and competitions. Where club trophies and records are concerned, this includes competitions not organised by us.
7. Who we share your data with
We will not share your information with any third parties for the purposes of direct marketing.
We may share your data with the following types of organisations when it is necessary to do so under an appropriate lawful basis.
- Service providers that help us provide services to you, such as processing online competition entries.
- Cycling bodies to maintain their records of competition results, or where you wish to take advantage of benefits they offer that are available to our members.
- Local authorities and other relevant parties with regard to Safeguarding.
- The police, legal professionals and our insurers, where criminal or civil law considerations arise, including where we need to seek advice.
In some circumstances we are legally obliged to share information. For example, under a court order.
8. How long we keep it
Whenever we use your personal data, we’ll keep it only for as long as is necessary for the purpose for which it was collected, which will continue after the end of your membership or inquiry, or after the competition. At the end of that period, your data will be securely deleted. Where we are able to be more specific, we have done so below.
Club membership records are kept by us for the length of your membership and then for three years after membership ceases.
Where you enter a competitive event, your data will be kept by us for as long as is required by the event’s governing body. For example, Cycling Time Trials (CTT) requires us to keep your data for four years, or until your 22nd birthday, whichever is later.
9. Your data protection rights
Under data protection law, you have a range of rights over the use of your personal information. The rights available to you depend on the legal bases under which we process your information.
This is an overview of the range of rights that may be available to you:
Right to rectification
You have the right to ask us to change incorrect or incomplete personal data about you. This right is always available.
Right to erasure
You have the right to require us to delete your personal data in certain circumstances.
Right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances.
Right to object to processing
You have the right to object to processing where our purpose for processing your personal information relies upon it being in our legitimate interests.
Right of access
You have the right to obtain a copy of your personal data on request. This right always applies, but some information may be exempt.
To protect the confidentiality of your information, we will verify your identity before actioning any request you make to exercise your rights.
If we are unable to action your request, we will explain to you the reasons for our refusal
10. Contacting us about use of your personal data
We hope this privacy notice helps explain how we use your personal data and your rights. If you have any questions or concerns, please contact our Membership Secretary who will be pleased to help you. You can contact them at email@example.com.
11. Your right to complain
If you are unhappy with how your personal data has been used, or you are unhappy with our response to any requests or concerns regarding the use of your personal data, you have the right to make a complaint to the Information Commissioner’s Office (ICO). The ICO is the UK independent supervisory authority for data privacy. We would appreciate the opportunity to try and address your complaint and would request that you please contact us using the details in section 10, before contacting the ICO, however this is your decision.
You can contact the ICO online at https://ico.org.uk/concerns/ or by calling them on 0303 123 1113, or on 029 2067 8400 if you are a Welsh speaker.
12. Updates to our privacy notice
Any updates we make to this privacy notice will be published on this page www.gloscitycc.co.uk/privacy-policy/ and where appropriate, we will notify you by email. This notice was last updated on 26/04/2019.