British Ice Skating Privacy Policy
Last Reviewed: 20/02/2020 Last Updated: 20/02/2020
BRITISH ICE SKATING (‘BIS’)
DATA PRIVACY NOTICE
We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your membership with us. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.
This notice applies to you if you are either:
a) An individual participant of ice skating or coach, official or volunteer who is a registered member of the Association or whose details we have collected from one of our affiliated clubs, bodies or other third-party referral, or a volunteer who is supporting the Association.
b) An individual who has contacted BIS and/or signed up to receive updates about upcoming events, offers and ways to get involved further with the disciplines of ice skating.
References to we, our or us in this privacy notice are to British Ice Skating, the trading name of The National Ice Skating Association of the United Kingdom Limited, a company incorporated in England and Wales with company number 02677064 and whose registered office is at the English Institute of Sport, Coleridge Road, Sheffield, S9 5DA. References to you or your in this privacy notice are to you in your personal capacity as an individual and/or in your capacity as a representative for a third party (such as a club).
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws [as we are not required to do so], but our CEO and Board have overall responsibility for data protection compliance in our organisation.
Contact details are set out in the "Contacting us" section at the end of this privacy notice.
1. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
a) Non-members
When you contact us as a non-member with a query, you may provide us with or we may obtain the following personal information about you:
o personal contact details that allows us to contact you directly such as name, title, home / correspondence / shipping address, e-mail addresses and telephone numbers; and
o details relating to the nature of your query.
b) Members
When you sign up for membership with us, you may provide us with or we may obtain personal information about you, such as information regarding your:
o personal contact details that allows us to contact you directly such as name, title, home / correspondence / shipping address, email addresses and telephone numbers;
o date of birth;
o gender;
o membership details including number, start and end date;
o records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
o any credit / debit card and other payment details you provide so that we can receive payments from you and details of the financial transactions with you;
o records of your attendance at any events or competitions hosted by us or permitted by us;
o images in video and / or photographic form and voice recordings;
o your marketing preferences so that we know whether and how we should contact you; and
o parent / guardian information and contact details.
c) Participants
If you are a skater who is participating in the sport, you may also provide us with, or we may obtain the following additional personal information from you:
o identification documents such as passport and identity cards;
o details of any club membership;
o details of next of kin, family members, coaches and emergency contacts;
o records of any competition results, details regarding competitions or tests attended and performance (including that generated through development pathway);
o any disciplinary and grievance information;
o any details required for the purposes of awarding scholarship funding or grants (including any means testing);
o physical testing data from BIS activities; and
o information from BIS events and BIS-sanctioned events.
d) Coaches and officials
If you are a current coach or official or have registered with us to receive more information about our programmes for coaches or officials, you may also provide us with, or we may obtain the following additional personal information from you:
o your current affiliated club or other organisation (if applicable);
o insurance cover if this is with a third party;
o coaching / teaching qualification or accreditation, including start- and end-dates, and / or officiating history and any skating levels from this or any other ISU-recognised ice skating member federation;
o identification documents such as passport, utility bills, identity cards, etc.; and
o other relevant / required information received for the application process.
2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following “special categories” of more sensitive personal information about you:
o information about your race or ethnicity, religious beliefs and sexual orientation;
o information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
o biometric information about you, for example fingerprints, retina scans.
We may not collect all of the above types of special category personal information about you. In relation to the special category personal data that we do process we do so on the basis that:
o the processing is necessary for reasons of substantial public interest, on a lawful basis;
o it is necessary for the establishment, exercise or defence of legal claims;
o it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
o based on your explicit consent.
In the table below, we refer to these as the “special category reasons for processing of your personal data”.
We may also collect criminal records information from you. For criminal records history, we process it on the basis of legal obligations or based on your explicit consent.
3. WHERE WE COLLECT YOUR INFORMATION
We typically collect personal information about our members when you join or renew your membership to BIS, and when you make a query and / or complaint or when you correspond with us by phone, e-mail or in some other way.
If you are a participant of ice skating, we also may collect personal information about you from any club or other organisation you are affiliated to or from other referrals such as from coaches or talent ID resources and from competition entry forms.
If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.
4. USES MADE OF THE INFORMATION AND THE LEGAL BASIS FOR EACH USE
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. This applies to both children and adults.
Purpose | Personal information used | Lawful basis |
All Members | ||
To administer any membership account(s) you have with us and managing our relationship with you, [including arranging for any insurance] and dealing with payments and any support, service or product enquiries made by you | All contact and membership details, transaction and payment information, records of your interactions with us, and marketing and communication preferences.
| This is necessary to enable us to properly manage and administer your membership contract with us.
|
To arrange and manage any contracts for the provision of any merchandise, products and/or services | All contact and membership details. Transaction and payment information. | This is necessary to enable us to properly administer and perform any contract for the provision of merchandise, products and services.
|
To send you information which is included or to be included within your membership benefits package, including details about your insurance, competitions and events, partner offers and discounts and any updates on ice skating | All contact and membership details.
| This is necessary to enable us to properly manage and administer your membership contract with us.
|
To send you other marketing information we think you might find useful or which you have requested from us, including information about membership, events, participation products and information about our commercial partners | All contact and membership details and marketing preferences. | Where you have given us your explicit consent to do so. |
To answer your queries or complaints | Contact details and records of your interactions with us.
| We have a legitimate interest to provide complaint handling services to you in case there are any issues within the BIS remit. |
To comply with health and safety requirements | Records of attendance. | We have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate in sport. |
For the purposes of promoting the sport, our events and membership packages. | Images in video and/or photographic form. | Where you have given us your explicit consent to do so. |
Retention of records | All the personal information we collect. | We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your membership and in some cases, we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
The security of our IT systems | Your usage of our IT systems.
| We have a legitimate interest to ensure that our IT systems are secure. |
To conduct data analytics studies to better understand event attendance and trends within the sport | Records of your attendance at any events or competitions hosted by us. | We have a legitimate interest in doing so to ensure that our membership is targeted and relevant. |
Participants | ||
To conduct performance reviews, manage performance and determine performance requirements and administer your development and training requirements on any development pathway | All performance and attendance data and information about your health and medical condition.
Details of any affiliated club.
| This is necessary to enable us to properly manage and administer your development through the pathway. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To make decisions about your progression and development through any pathway and to assist with the delivery of rankings and allocation of competition entries | All performance and attendance data and information about your health.
Details of any affiliated club. | This is necessary to enable us to properly manage and administer your development through the performance programme. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To administer and monitor your application for and attendance at events and competitions | All non-medical performance and attendance data.
| This is necessary to enable us to register you onto and properly manage and administer your development through the pathway. |
When the responsibility of BIS to arrange for any trip or transportation to and from an event | Identification documents, details of next of kin, family members and emergency contacts, transaction and payment information, health and medical information. | This is necessary to enable us to make the necessary arrangements for the trip and/or transportation to the event. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To administer any drug and alcohol testing | Health and medical information. | We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To use information about your physical or mental health (including any injuries) or disability status, to ensure your health and safety and to assess your fitness to participate, to provide appropriate adjustments to our sports facilities and to monitor and manage sickness absence | Health and medical information. | We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. We publish requirements of physical testing for BIS Squads and require the result data for the transparency and consistency of decision-making. |
To gather evidence for possible grievance or disciplinary hearings | All the personal information we collect including any disciplinary and grievance information. | We have a legitimate interest in doing so to provide a safe and fair environment for all members and to ensure the effective management of any disciplinary hearings, appeals and adjudications. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
For the purposes of equal opportunities monitoring | Name, title, date of birth, gender, sex, sexual orientation, disability information, religion, information about your race or ethnicity, health and medical information and performance data. | We have a legitimate interest to promote a sports environment that is inclusive, fair and accessible. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
Coaches and officials | ||
To administer your attendance at any courses or programmes or officials lists | All contact and membership details, transaction and payment data.
Details of your current rink, coaching/teaching qualifications and / or officiating history. | This is necessary to enable us to register you on to and properly manage and administer your development through the course and/or programme and to support the business requirements of the organisation. |
To conduct performance reviews, managing performance and determining performance requirements | All performance and attendance data and information about your health.
Details of your current affiliated club or other, coaching / teaching qualification and / or officiating history. | This is necessary to enable us to properly manage and administer your development through the course and/or programme. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To make decisions about your progression and accreditation status | As above. | As above. |
To comply with legal obligations, for example, regarding people working with children or vulnerable adults to comply with our safeguarding requirements and self-declaration information | Information about your criminal convictions and offences.
| For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
When the responsibility of BIS to arrange for any trip or transportation to and from an event | Identification documents, details of next of kin, family members and emergency contacts, transaction and payment information, health and medical information. | This is necessary to enable us to make the necessary arrangements for the trip and/or transportation to the event. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may
For some of your personal information you will have a legal, contractual or other requirement or obligation for your to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to admit you
as a member or we may not be able to properly perform our contract with you or
comply with legal obligations and we may have to terminate your position as a
member. For other personal information you
may not be under an obligation to provide it to us, but if you do not provide
it then we may not be able to properly perform our contract with you.
Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contacting us" section below. Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain member benefits to you.
5. DISCLOSURE OF YOUR PERSONAL INFORMATION
We share personal information with the following third parties:
o Any party approved by you;
o To the ISU, ISU member federations and ISU member federation clubs: to allow them to properly administer the sports on an international level;
o Other service providers: for example, email software suppliers, payment processors, data analysis, promotional advisors, contractors or suppliers and IT services (including CRM, website, video- and teleconference services);
o The Government, statutory agencies including UKAD and our regulators: where we are required to do so by law or to assist with their investigations or initiatives;
o Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
We do not disclose personal information to anyone else except as set out above.
6. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY
The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws.
An example of this includes, but is not limited to, entering participants to competitions outside of the EU.
For further details please contact us by using the details set out in the "Contacting us" section below.
7. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?
The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 6 years after your last contact with us. Exceptions to this rule are:
o Information that may be relevant to personal injury claims, or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after you have participated in BIS activities.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address. You may in future be able to update some of the personal information we hold about you through access to a membership portal. Alternatively, you can contact us using by using the details set out in the "Contacting us" section below.
8. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal information:
o the right to be informed about how your personal information is being used;
o the right to access the personal information we hold about you;
o the right to request the correction of inaccurate personal information we hold about you;
o the right to request the erasure of your personal information in certain limited circumstances;
o the right to restrict processing of your personal information where certain requirements are met;
o the right to object to the processing of your personal information;
o the right to request that we transfer elements of your data either to you or another service provider; and
o the right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below.
If you are unhappy with the way we are using your personal information, you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.
9. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
10. CONTACTING US
In the event of any query in connection with the information we hold about you, please email [email protected] or write to us at BIS, c/o English Institute of Sport, Coleridge Road, Sheffield, S9 5DA.
In the event of any complaint in connection with the information we hold about you, please contact the Information Commissioner through the following web address: https://ico.org.uk/concerns/
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