1. About this Policy
• 1.1 This policy explains when and why we collect personal information about our Clients and Instructors, how we use it and how we keep it secure and your rights in relation to it.
• 1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
2. Who we are ?
2.1 We are Oyster Coast Watersports, (OCW ). We can be contacted through our website www.oystercoastwatersports.co.uk by email at email@example.com by Telephone.on ; +441227806108.
2.2 OCW is a limited company that supplies a variety of Water Activities with operating sites and premises in Whitstable Harbour, Whitstable, Kent CT5 1AB
2.3 OCW is an RYA recognised Teaching Centre, an ASI Accredited Stand up Paddle School and are also licensed with AALS.
3. What information we collect and why. Exactly why we manage personal data is explained below. Type of information, Purpose and Legal basis of processing :
3.1 Client's name, address, telephone numbers, e-mail address(es). For Managing our Clients participation of the Courses or hire and Managing the Instructor roster. Performing OCW ’s contract with our Clients. For the purposes of our legitimate interests in operating the Business. The Clients name and email address is for Creating and managing online Client Records, participation on the Course and the provision of hire, services and events.
3.2 Emergency contact details. For Contacting next of kin in the event of an emergency and for Protecting the Clients vital interests and those of their dependants.
3.3 Date of birth / age related information. For Managing Course categories which are age related.
3.4 Gender. For Provision of adequate facilities for Clients and For the purposes of our legitimate interests in making sure that we can provide sufficient and suitable facilities (including changing rooms and toilets) for each gender.
3.5 Reporting information to the RYA and ASI. For the purposes of the legitimate interests of the RYA and ASI to maintain diversity data required by Sports Councils.
3.6 Consent. We will seek Clients consent prior to their Course or hire. The Client may withdraw their consent at any time by contacting us by e-mail or letter.
3.7 Course Completion - post attendance for checking the Performance of OCW during its contract with the Client.
3.8 Photos and videos of Clients for Putting on OCW’s website and social media pages and using in press releases.
3.9 Bank account details of the Client or other person making payment to OCW for the purpose of ensuring payment is made for services provided.
3.10 Instructor’s name, address, email addresses, phone numbers and relevant qualifications and/or experience. OCW uses this For the purposes of our legitimate interests in ensuring that we can contact those offering instruction and provide details of instructors to Clients. For Managing instruction and conforming to Accreditation requirements at OCW.
3.11 Instructors and Employees Emergency contact details. For Contacting next of kin in the event of an emergency and for Protecting the Instructors and Employees vital interests and those of their dependants.
3.12 Name, e-mail address and telephone number of each Employee entering into and performing contracts with suppliers. For the purposes of our legitimate interests in operating and promoting OCW. Entering into agreements and managing arrangements with suppliers.
3.13 Information published on OCW website, in newsletters and other publications, in OCW marketing materials and made available to the RYA and ASI.
4. How do we protect your personal data ?
• 4.1 We will not transfer your personal data outside the EU without your 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 when you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
• 4.4 For any payments which we take from you online we will use a recognised online secure payment system.
• 4.5 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
5. Who else has access to the information you provide us ?
• 5.1 We will never sell your personal data. We will not share your personal data with any third party without your prior consent (which you are free to withhold) except where we are required to do so by law or as set out in the table above or in paragraphs 5.2 and 5.3 below.
• 5.2 We may pass your personal data to third parties who are service providers, agents or subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). We do this for the purpose of our legitimate interests in operating ! and for performing our contract with you.
However, we disclose only the personal data that is necessary for the third party to deliver the service and we will have a contract in place that requires them to keep your information secure and not to use it for their own purposes. It is possible that third parties may themselves engage others (sub-processors) to process your data. Where this is the case third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own purposes.
• 5.3 We may also pass your personal data to the RYA or ASI for the purposes of carrying out surveys when it is in the legitimate interest of the RYA or ASI to do so. The RYA and ASI may use third parties to carry out the surveys but disclose only the personal data that is necessary for the third party to do so and will have a contract in place that require the third party to keep your information secure and not to use it for their own purposes.
Employees and representatives of suppliers to OCW. For Entering into and performing contracts with suppliers.
6. How long do we keep your information ?
• 6.1 We will hold your personal data on our systems for as long as you are on a course with OCW and for as long afterwards as it is in the OCW s’ legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will review your 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 your personal data except that we will retain your 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. Your rights;
7.1 You have rights under the GDPR:
• (a) to access your personal data
• (b) to be provided with information about how your personal data is processed
• (c) to have your personal data corrected
• (d) to have your personal data erased in certain circumstances
• (e) to object to or restrict how your personal data is processed
• (f) to have your personal data transferred to yourself or to another business in certain circumstances.
7.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner: through their website https://ico.org.uk/concerns/ by telephone: 0303 123 1113.
or write to: 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 at firstname.lastname@example.org .