Fife Synchronised Swimming Club Privacy Notice
What we need
Privacy Notice for Fife Synchronised Swimming Club, which is affiliated with the Scottish Amateur Swimming Association (SASA).
Fife Synchronised Swimming Club will be a “controller” of the personal information that you provide to us either in writing, or via online methods (for example SASA’s online membership system, known as Azolve) unless otherwise stated.
When you register as a member of Fife Synchronised Swimming Club or renew your membership (including if you are registering or renewing on behalf of a child under the age of 16), we will ask you for the following personal information:
- contact details – name, address, email address (for children under 16 this is the email address of the parent), and date of birth;
- membership criteria / category – swimmer, non-swimmer, volunteer;
- equality information – disability (if any); and
- any other personal information we may require on an occasional basis, for example, PVG membership, swimming costume sizes for competitions etc.
Why we need your personal information – contractual purposes
We need to collect our members’ personal information so that we can manage your membership. We will use our members’ personal information to:
- provide you with core member services, including insurance, licensing, and PVG checks;
- set up your online membership account with SASA and administer your account online;
- send you membership communications, by post, online or by email, in relation to essential membership services, including but not limited to, membership renewals and membership fees’.
When you book a place with us and attend a training session or course, a coaching course, competition or event, etc., we need to collect your personal information so that we can honour your booking and to enable you to participate in the session, course, competition or event.
If you do not provide us with all of the personal information that we need to collect then this may affect our ability to offer the above membership services and benefits or to book your place.
Why we need your personal information – legitimate purposes
Members’ personal data:
We also process our members’ personal information in pursuit of our legitimate interests to:
- promote and encourage participation in synchronised swimming by sending members’ communications and booking information for upcoming competitions and events. Competitions and events in which we participate may be photographed or filmed for training or live streaming purposes and the images captured from our competitions and events may also be used for promotional, education and development purposes;
- provide access to competitions in synchronised swimming by accepting and managing entries for those competitions and checking yours or your child’s personal information to ensure you are entered into the correct category;
- monitor and develop participation in synchronised swimming by monitoring members’ engagement and participation through attendance and inviting our members to participate in surveys for researching and development purposes;
- develop and maintain our members’ qualifications including sending email communications to members to inform you of upcoming courses, renewal requirements and verify that you have completed any mandatory training and PVG/child protection requirements;
- respond to and communicate with members regarding your questions, comments, support needs or complaints, concerns or allegations in relation to synchronised swimming. We will use your personal information to investigate your complaint, suspend membership and take disciplinary action where appropriate; and
- run the Scottish Swimming membership check which can be found online at https://www.scottishswimming.com/membership/membership-check.aspx to ensure that a member is eligible to compete or officiate at an event.
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us at firstname.lastname@example.org. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for the benefit of you as a member.
Volunteers’ personal data:
We will need to collect personal information relating to criminal convictions or alleged commission of criminal offences where you are required to complete a PVG check under the Protection of Vulnerable Groups (Scotland) Act 2007. This information will include your PVG certificate number, PVG membership number, date of issue and any relevant information in relation to your membership of the PVG Scheme.
If your PVG certificate is not clear, we will have a legitimate interest to collect references and any other applicable information to allow us to consider whether or not you can volunteer in a regulated role with children and/or vulnerable adults.
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us at email@example.com. If we comply with your objection, this may affect our ability to undertake the tasks above for the benefit of you as a volunteer.
Why we need your personal information – legal obligations
We are under a legal obligation to process certain personal information relating to our members and volunteers for the purposes of complying with our obligations under:
- the Companies Act 2006 to maintain a register of our members, which includes our members’ name, address, the date they were admitted to membership and the date on which they ceased to be our member, and hold general meetings, including issuing notices and voting arrangements;
- the Protection of Vulnerable Groups (Scotland) Act 2007 to check that our coaches and volunteers are able to undertake regulated work with children and vulnerable adults, and also to check any swimmer aged 18 or over;
- our Sportscotland regulatory requirements to report on the size, achievement and profile of our members;
- the Equality Act 2010, which requires us to process personal information to make reasonable adjustments where necessary; and
- our synchronised swimming regulatory requirements to teach, develop and practice swimming, diving and synchro; and
- By virtue of affiliation of the Fife Synchronised Swimming Club to SASA, the club and its members acknowledge that they are subject to the laws, rules and constitutions of ASA East Scotland, British Swimming and FINA (the world governing body for the sport of swimming in all its disciplines).
Why we need your personal information – equality monitoring requirements
We are required to use our members’ personal information relating to a disability for equality monitoring purposes. SASA will process such personal information through aggregated and anonymised reports to identify and keep under review the existence or absence of equality of opportunity or treatment between groups of people within the same categories to promote or maintain equality within our sport.
Other uses of your personal information
We may ask you if we can process your personal information for additional purposes. Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.
Who we share your personal information with
If your personal information is included in any images or videos taken by us at our competitions and events, we may share this with SASA, members of the Scottish media, sponsors, Sportscotland and Sports Partners (including Scottish Leisure Trusts, Scottish Local Authorities, Swimming Clubs, Scottish Disability Sport, Scottish Universities) for promotional and/or journalistic purposes.
We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include the Health & Safety Executive, Disclosure Scotland, and Police Scotland for the purposes of safeguarding children.
We may also share personal information with our professional and legal advisors for the purposes of taking advice.
As an affiliated club of SASA we are required to ensure that all of our members are members of SASA as a condition of affiliation. We will share your name and membership number and category with SASA who will become a “controller” of your personal information when they receive it. SASA’s privacy notice explains how they use your personal information and can be accessed here http://www.scottishswimming.com/membership/data-protection
In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.
Scottish Swimming employs Azolve to administer our membership database, as part of which Azolve contracts third party payment providers to process our payments on their behalf. Azolve and its payment providers process our members’ personal information on our behalf as “processors” and are subject to written contractual conditions to only process that personal information under our instructions and protect it.
For members who are attending UKCC courses run by Scottish Swimming, they use a platform called Onefile to administer the courses. The Onefile system holds basic personal details (name, email, date of birth) and processes learners’ personal information on our behalf as “processors” and are subject to written contractual conditions to only process that personal information under our instructions and protect it.
How we protect your personal information
Your personal information is stored on SASA’s electronic filing system and their servers based in Europe, and is accessed by SASA staff and our volunteers for the purposes set out above. A volunteer will also keep a hard copy of contact telephone numbers on Poolside in case of any emergencies arising during a session.
How long we keep your personal information
We will only keep your personal information for as long as necessary to provide you with membership services. Unless you ask us not to, we will review and possibly delete your personal information where you have not renewed your membership with us for six years.
We will keep certain personal information of members for longer in order to confirm your identity, when you were a member of Fife Synchronised Swimming Club and for how long. We need to do this to comply with the Companies Act 2006, which requires us to keep a register of members in the event of a claim against Fie Synchronised Swimming Club.
You can exercise any of the following rights by writing to us at firstname.lastname@example.org or by logging on to Azolve at https://scottishswimming.azolve.com/account.mvc/login
Your rights in relation to your personal information are:
- you have a right to request access to the personal information that we hold about you by making a “subject access request”;
- if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information;
- you have a right to request that we restrict the processing of your personal information for specific purposes; and
- if you wish us to delete your personal information, you may request that we do so.
Any requests received by Fife Synchronised Swimming Club will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner’s Office at www.ico.org.uk.
As a result of the worldwide Coronavirus pandemic, we may need to record information regarding whether you are displaying any symptoms of COVID-19, have been in recent contact with anyone who has tested positive for or is displaying symptoms of COVID-19, have any underlying health conditions or have been, or are in close contact with anyone who has been, advised to shield. This information would be required to ensure the safety of members attending Fife Synchronised Swimming Club.
Why we need your data
Our lawful basis for processing health information relating to COVID-19 is:
- to protect your vital interests; and/or
- for the legitimate interests of members attending Fife Synchronised Swimming Club to ensure individuals’ safety and prevent the spread of the virus.
As health information falls within the definition of “special categories of personal data” under applicable data protection legislation, we also need a special condition to process such information. We may need to process this health information:
- to protect your vital interests where you cannot consent;
- for reasons of public interest in the area of public health, including protecting against serious cross-border threats to health where we have a legal duty of confidentiality to you; and/or
- with your explicit consent (if required).
Information we may collect about you
We may collect data from you in relation to COVID-19:
- From a return to water health screening survey and/or a regular health check survey – detailing whether you have symptoms of COVID-19, if you have come into contact with someone with COVID-19, history of having COVID-19, and underlying health conditions.
- Should you report contracting COVID-19 to the COVID-19 Lead Officer.
Who we share your personal data with
We may be required to share personal information with statutory or regulatory authorities and organisations to comply with public health obligations. In the event that we do share personal information with third parties, we will only share such personal information as is strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.
Where a case of COVID-19 is recorded within the club, your personal information will not be shared with other members directly, however members will be advised that a case has occurred, whilst keeping personal information anonymous as far as possible.
How long will we store COVID-19 specific data?
We will only keep your personal information for as long as necessary in line with legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
FOR FURTHER INFORMATION PLEASE SPEAK TO A COMMITTEE MEMBER.