Data Privacy Policy
BOSHAM SAILING CLUB LIMITED DATA PRIVACY POLICY
1. About this policy
1.1 This policy explains when and why we collect personal information about our members and instructors, how we use the information, how we keep it secure and your rights in relation to it.
1.2 From time to time we may need to amend this policy without prior notice, but amendments will not be applied retrospectively and you will be notified of any changes as soon as possible.
1.3 We will always comply with the Data Protection Act 2018 (The Act) when dealing with your personal data. Further details on The Act can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of The Act, we will be the "controller" of all personal data that we hold about you.
2. Who are we?
2.1 We are Bosham Sailing Club Limited (BSC Ltd) and we can be contacted at Bosham Sailing Club, The Quay, Bosham, West Sussex, PO188LU 01243572341 office@boshamsailingclub.com
3. What information do we collect and why?
| Type of information | Purpose | Legal basis of processing |
| Member's/ Non member's name, address, telephone numbers, email address(es) | Managing the Member's membership of the Club. Managing the duty roster | Performing the Club's contract with the Member. For the purposes of our legitimate interests in operating the Club |
| The names and ages of the Member's/ non members dependants | Managing the Member's / non members and their dependants' Membership or bookings with the Club | Performing the Club's contract with the Member |
| Emergency contact details | Contacting next of kin in the event of emergency | Protecting the Member's vital interests and those of their dependants |
| Date of birth / age-related information | Managing membership categories which are age-related | Performing the Club's contract with the Member |
| Gender | Provision of adequate facilities for members. Reporting information to the RYA. | For the purposes of our legitimate interests in ensuring that we can provide sufficient and suitable facilities (including changing rooms and toilets) for each gender. For the purposes of the legitimate interests of the RYA to maintain diversity data required by Sports Councils. |
| The Member's name, boat name and sail number(s) | Managing race entries and race results. Sharing race results with other clubs, class associations, and the RYA, and providing race results to local and national media. Allocating moorings, billets and Dinghy park spaces. | For the purposes of our legitimate interests in holding races for the benefit of members of the Club. For the purposes of our legitimate interests in promoting the Club. For the purposes of our legitimate interests in operating the Club. |
| Photos and videos of members and their boats | Putting on the Club's website and social media pages and using in press releases | Consent. We will seek the Member's consent on their membership application form and each membership renewal form. The Member may withdraw their consent at any time by contacting us by email or letter |
| Radio call signs | Collected for a rally and shared between those participating in the rally | For the purposes of our legitimate interests in ensuring that boats on a rally can maintain contact with each other |
| The Member's name and email address | Creating and managing the Club's online Membership Directory. | Consent. Member's consent to publication of these details by using the SCM portal and changing their profile data from the default setting of "private" to "members" or "public". The Member may withdraw their consent at any time by changing their profile to private. |
| Bank account details of the Member or other person making payments to the Club | Managing the Member's and their dependants' membership of the Club, the provision of services and events | Performing the Club's contract with the Member |
| Member's name and email address | Passing to the RYA for the RYA to conduct surveys of members of the Club (and members of other clubs affiliated to the RYA). The surveys are for the benefit of the Clubs (and other clubs) and / or the benefit of the RYA | For the purposes of our legitimate interests in operating the Club and/or the legitimate interests of the RYA in its capacity as the National Governing Body for all forms of boating |
| Instructor's name, address, email addresses, phone numbers and relevant qualifications and/or experience | Managing instruction at the Club | For the purposes of our legitimate interests in ensuring that we can contact those offering instruction and provide details of instructors to members |
| Member's/ non member's health information for training courses | Managing instruction at the Club | For the purposes of protecting the members' vital interests whilst taking part in training activities and only made available to the Club office staff and the course instructors. |
4.How we protect personal data
4.1 We will not transfer members' personal data outside the EEA without their consent.
4.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
4.3 Please note however that where members transmit information to us over the internet, this can never be guaranteed to be 100% secure.
4.4 For any online payments which we take from members, we will use a recognised online secure payment system.
4.5 We will notify members promptly in the event of any breach of their personal data which might expose them to serious risk.
5. Who else has access to the information you provide us?
5.1 We will never sell members' personal data or share their personal data with any third parties without their prior consent (and which members are free to withhold) except where required to do so by law or as set out in the table above or paragraph 5.2 below.
5.2 We may pass members' personal data to third parties who are service providers, agents and subcontractors for the purposes of completing tasks and providing services to members on our behalf (e.g. to print newsletters and send you mailings). However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep such information secure and not to use it for their own purposes.
6. How long do we keep your information?
6.1 We will hold a member's personal data on our systems for as long as they are a member of the Club and for as long afterwards as is necessary to comply with our legal obligations. We will review members' personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing their personal data except that we will retain their personal data in an archived form in order to be able to comply with future legal obligations. e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
6.2 We securely destroy all financial information once we have used it and no longer need it.
5.Who else has access to the information you provide us?
5.1 We will never sell members' personal data or share their personal data with any third parties without their prior consent (and which members are free to withhold) except where required to do so by law or as set out in the table above or paragraph 5.2 below.
5.2 We may pass members' personal data to third parties who are service providers, agents and subcontractors for the purposes of completing tasks and providing services to members on our behalf (e.g. to print newsletters and send you mailings). However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep such information secure and not to use it for their own purposes.
6. How long do we keep your information?
6.1 We will hold a member's personal data on our systems for as long as they are a member of the Club and for as long afterwards as is necessary to comply with our legal obligations. We will review members' personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing their personal data except that we will retain their personal data in an archived form in order to be able to comply with future legal obligations. e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
6.2 We securely destroy all financial information once we have used it and no longer need it.
- 7.Retaining items in the Public Interest
7.1 It is in the Public Interest that in years to come, a historian or an interested party should be able to see who was a Club member in any given year. It is thus the Club's policy to create a list of all members at renewal each year, along with their date of birth and home postcode (to allow differentiation between persons of the same name). This list is held in perpetuity in the Public Interest, in a separate area of the Club's digital records labelled as 'Archive', away from the Club's day-to-day operational records and therefore falls within the protection of the 'Archiving in the Public Interest' lawful basis in the Data Protection Act.
7.2 If a leaving member notifies the Club of their intention to exercise their 'Right to be Forgotten/Right to Erasure' in the Data Protection Act, then after the period set out in 6.1 above their personal data will be deleted as the Club's Legitimate Interest will have expired.
8.Members' rights
8.1 Members have rights under The Act to access their own personal data
a) to be provided with information about how their personal data is processed
b) to have their personal data corrected
c) to have their personal data erased in certain circumstances
d) to object to or restrict how their personal data is processed
e) to have their personal data transferred to themselves or to another business in certain circumstances.
f) to have their personal data transferred to themselves or to another business in certain circumstances.
8.2 Members have the right to take any complaints about how we process their personal data to the Information Commissioner:
https://ico.org.uk/concerns/
0303 123 1113
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
For more details, please address any questions, comments and requests regarding our data processing practices to our Data Protection Manager, Richard Lewis commodore@boshamsailingclub.
Last updated 11:45 on 14 March 2024
