The West London Penguin Swimming and Water Polo Club (“Club”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.
Who are we?
For the purposes of applicable data protection laws (in particular, the UK Data Protection Act 2018 and the EU General Data Protection Regulation 2016/679 (collectively “Data Protection Laws”)) the West London Penguin Swimming and Water Polo Club is the “controller” of the personal data that you provide to us. This means that we are responsible for deciding how we hold and use 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. 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 (where relevant in the circumstances):
your full name and contact details, including your address, email address, telephone number and contact information of anyone you represent;
- your data of birth and gender;
- whether you are a student or not;
- emergency contact details, including your emergency contact’s name, phone number and email address;
- details of any county and/or other 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 (LEN));
- records of any interactions you have with us;
- records of attendance of events hosted by us; and/or
- your contact preferences, including whether and how you would like us to keep you informed about the Club’s activities and development
Note: we may collect and process special category data about you, such as your nationality, race or ethnicity, and/or health and 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, other 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, and otherwise in accordance with applicable Data Protection Laws. Such uses may include:
- to manage and administer your membership with the relevant section of the Club, including by issuing communications and information to you about relevant Club activities and events, or to fulfil any other contractual obligation we have with you;
- to complete any necessary and/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 (LEN));
- 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 Administrators, Welfare Officer, Committee Members including Club Secretary and Club Treasurer.
Communications with you.
We may, with your express consent, contact you via text (including messaging apps such as WhatsApp), e-mail or post to provide you with information about your membership and/or the Club, and any other events, competitions, products or services which we think may be of interest to you.
You can unsubscribe from such communications at any time by:
(i) clicking the “Unsubscribe” link at the bottom of any promotional email you receive;
(ii) replying to the email asking the Club representative to remove you from the email list;
(iii) voluntarily exiting the relevant messaging app group where you are an Admin or if you are not an Admin, requesting that the Administrator of the group remove you; or
(iv) by contacting us using the “Contact” section of the website and directing your unsubscribe request to the Club “Secretary/Webmaster”.
What is our legal basis for using your personal data?
There are a number of lawful reasons for us to process your personal data:
- If you request further information about the Club and/or your membership, our lawful reasons for processing your personal data shall be necessity to fulfil to contractual obligations we have to you and/or we have a legitimate interest in doing so. This means that we can process your personal data if (i) we have a genuine and legitimate reason in doing so; and (ii) are not harming any of your rights and interests.
- We may process your personal data if we are required to do so in order to comply with our legal and compliance obligations, to establish and defend our legal rights, or to prevent and detect crimes such as fraud or misuse of or damage to our property, or to ensure the health and safety of our members and the activities/services offered.
- If you agree to be sent promotional communications by email, we will only do so with your consent. If you have given us your consent, you can withdraw your consent at any time as described in the “Communications with you” section above.
Sometimes your personal data may be used for statistical research but only in a form that no longer identifies you.
How long will we hold your personal data for?
We will hold your personal data for only as long as is necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any legal or other reporting requirements. 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, unless you give us express permission to keep your contact details when you leave the Club. 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 (LEN)).
- Other service providers relating to the Club and/or your membership such as sports event organisers, payment processors, sponsors or suppliers of IT services (such as video or tele-conferencing or email marketing service providers).
- The government and/or regulators where required to do so by law or 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.
By submitting your personal data to us, you agree to this transfer, storing and processing.
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).
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. Please include “data protection” in the subject line of your email so it’s clear what your query relates to.
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/.
How you can access and update your personal data.
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.