West London Penguin Swimming and Water Polo Club Privacy Notice
The West London Penguin Swimming and Water Polo Club (“Club”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.
This Privacy Notice (“Notice”) contains important information about how we will collect, manage and use any personal data that you provide us when using this website, requesting further information about the Club, and before, during or after your membership with the Club. For the avoidance of doubt, references to “you” and “your” in this Notice are to the club member, the parent, legal guardian or other representative of the club member, and any volunteer or other member of the club workforce (as applicable) who provides personal data to us.
We may change this Privacy Notice from time to time. Please check back regularly so that you are aware of the most recent version.
Who are we?
For the purposes of applicable data protection laws (in particular, the UK Data Protection Act 2018 and the UK General Data Protection Regulation (collectively “Data Protection Laws”)) the West London Penguin Swimming and Water Polo Club is the “controller” of your personal data.
Personal data we collect about you
Personal data means any data or information about an individual from which that person can be identified (whether directly or indirectly). It does not include data where the identity has been removed (i.e. anonymous data).
We may collect, use, store and transfer different kinds of personal data about you including:
Information you give us
We will collect personal data about you if you contact us through our website to register your interest in the Club, or by corresponding or speaking with us by phone, email, letter or otherwise.
We may collect and process the following personal data about you:
- your full name and contact details, including your address, email address, telephone number and contact information of anyone you represent;
- your date of birth and gender;
- whether you are a student;
- emergency contact details, including your emergency contact’s name, phone number and email address;
- details of any county, sports or professional affiliation or membership;
- images of you in video and/or photographic form, and voice recordings;
- records of competition results, or details of sports tournaments or events participated in;
- governing body registration details (such as for Swim England, London Water Polo League, British Water Polo League, Ligue Européenne de Natation);
- records of any interactions you have with us (including preferences about how you wish to be contacted); and/or
records of attendance of events hosted by us.
We may also collect and process special category data about you (such as your nationality, race, ethnicity, health or medical information) where we have a legal obligation to do so, and a legitimate interest to provide you and other members of our Club with a safe environment in which to participate in sport.
If you are contacting us on behalf of somebody else, we ask that (i) you do not provide us with their personal data unless they have explicitly agreed to you doing so and you can confirm the same to us, or (ii) you are otherwise legally authorised to act on their behalf (e.g. as a minor’s parent or guardian, or through a power of attorney).
Information provided by third parties or publicly available sources
We may receive personal data about you from various third parties or public sources including (without limitation) governing bodies, sports associations and/or clubs, and schools.
Information provided through cookies or similar technologies
How we may use your personal data
We will use personal data held about you strictly as necessary to operate the Club and provide the Club’s services in accordance with applicable Data Protection Laws. Such uses may include:
- to manage and administer your membership for the relevant section of the Club, including by sending you information about Club activities and events, or to fulfil any other contractual obligation we have with you;
- to complete any necessary or requested registration with applicable governing bodies or sports associations (such as Swim England, London Water Polo League, British Water Polo League, Ligue Européenne de Natation);
- to respond to your queries, requests and/or complaints;
- to comply with health and safety, and any other relevant compliance requirements;
- for administrative and quality assurance purposes;
- on the Club’s website and social media channel for marketing and publicity; and
- in order to establish or defend any legal claims.
Who has access to your data
The following people may see your personal data strictly as required to perform their specific role within the Club and only to the extent permitted by applicable law: Head Coach, Coaching Staff, Team Manager, Welfare Officer, Committee Members including Club Chairperson, Club Secretary and Club Treasurer.
What is our legal basis for using your personal data?
We know how important your personal data is so we will only ever collect and use it for a lawful reason relating to the Club. Generally, this means that we will use your personal data:
- To carry out a contract with you (e.g. by communicating information about your membership, and Club news and events), or because you have asked us to take specific steps (e.g. you have requested further information about the Club and/or your membership, or we are investigating and responding to a complaint).
- Because we have to comply with the law and applicable regulations, e.g. reporting obligations such as of any health, safety or security incidents, or to an authority or governing body.
- For legitimate legal purposes such as providing you with special offers, discounts and about the Club which may be of interest to you; updating and maintaining our records, preventing or detecting fraud or abuses of our website, and seeking ways we can improve our membership or communications.
- Where required by external parties we deal with (such as an insurer or the police), or where necessary for the establishment, exercise or defence of any legal claims.
Sometimes your personal data may be used for statistical research but only in a form that no longer identifies you.
Special offers and promotions
We think you will love hearing about any special offers, discounts or promotions about the Club and related goods and services from time to time. So, unless you have told us that you do not wish to be contacted for this purpose, we will send these to you by email.
If you no longer wish to receive such special offers, discounts and promotions, you can simply:
(i) click on the “Unsubscribe” link at the bottom of any email you receive;
(ii) reply to the email asking the Club representative to remove you from the email list;
(iii) voluntarily exit the relevant messaging app group where you are an Admin or if you are not an Admin, request that the Administrator of the group remove you; or
(iv) contact us using the “Contact” section of the website and directing your unsubscribe request to the Club “Secretary/Webmaster”.
How long will we hold your personal data for?
We will hold your personal data for only as long as is necessary to carry out the purpose for which we collected it. While retention periods will vary depending on the type of personal data collected and the reasons for collection, in most instances, we shall only hold your information for the duration of your membership. Where there are no such legal requirements to determine the appropriate retention period, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we are processing it and whether we can achieve those purposes through other means.
Sharing your personal data with third parties
We may share your personal data with selected third parties including:
- Governing and/or regional bodies relating to swimming and/or water polo (such as Swim England, London Water Polo League, British Water Polo League, Ligue Européenne de Natation).
- Other service providers relating to the Club or your membership such as sports event organisers, payment processors, sponsors or suppliers of IT services (e.g. video or tele-conferencing or email marketing service providers).
- The government and/or regulators where 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, or to otherwise protect person or property.
- Any other party approved by you from time to time.
We require all third parties to respect the security of your personal data, and only store and process it in accordance with Data Protection Laws.
We will NOT sell your personal data to any third parties.
International transfers of personal data
Your personal data may be transferred to, stored at, and processed by individuals in, destinations outside of the UK where required to provide goods and services requested by you, e.g. registration for an international water polo competition or registration of an international player transfer.
We will take all steps reasonably necessary to ensure that your data is treated securely and that any such data is transferred in accordance with this Privacy Notice and applicable Data Protection Laws. In addition, where personal data is being transferred to a national or international sports association or governing body, we will comply with any data transfer terms specified by the relevant association or body.
By submitting your personal data to us, you agree to this transfer, storage and processing of your personal data.
You have certain rights in relation to the personal data we hold about you, which include the right to:
- request access to your personal data;
- request correction of your personal data;
- request erasure of your personal data;
- object to the processing of your personal data;
- request restriction of processing your personal data;
- request transfer of your personal data; and
- withdraw consent (although please note that any requested withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent, and in some instances we may still hold and process relevant personal data to the extent permitted by another lawful basis).
If you would like to exercise any of these rights, please contact us using the details in the ‘Contact Us’ section below. We may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal data and ensure that we are only releasing personal data to those entitled to receive it.
If you wish to raise a complaint in relation to our processing of your personal data, you can contact us using the details below.
You also have the right to lodge a complaint with the data protection regulator, the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/.
Changes to this Privacy Notice
We may update this Privacy Notice from time to time. Any changes we may make to this Privacy Notice will be posted on this page and, where we consider appropriate, notified to you by email.
If you have any questions regarding this Privacy Notice, wish to exercise any of your rights, or would like to make a complaint, please contact us using the “Contact” section of this website and direct your question/feedback/complaint to the Club “Secretary/Webmaster”.
We note that we have not appointed a Data Protection Officer as we are not required to do so. Please contact our Club Secretary as described above and your request shall be handled promptly.
This Privacy Notice is dated 16 March 2021.