• Ramsbottom Running Club

    Privacy Policy

    This policy is effective as of 5th April 2019

     

    Ramsbottom Running Club is committed to respecting and protecting your online privacy. This includes your right to know what we do with the personal information you share with us. It also guides our policies regarding the management of your data, including how the information is collected, how it is processed, and for what purposes.

     

    It is important to us that we communicate our policies and procedures with you clearly and in a manner that provides clarity to you as a member of the Club.

     

    As such, this policy covers the following key areas:

    1. Background Information

    2. Why we need your data

    3. Categories of Data

    4. What data we collect

    5. What data we share

    6. How we contact you

    7. How we protect your information

    8. Retention Periods

    9. Your rights

     

    1. Background Information

     

    Ramsbottom Running Club is a community sports club which is affiliated to UK Athletics. The Club’s status is an ‘unincorporated association’, and is managed and governed by a committee of volunteers. The club operates in accordance with our constitution.

     

    Ramsbottom Running Club collects, manages, and processes all associated membership data and our designated Data Protection Officer is Rowan Ardill (Chairperson).

     

    Questions about this privacy policy may be submitted to Ramsbottom Running Club via: members@ramsbottomrunningclub.co.uk

     

    or by post to the following address:

     

    Ramsbottom Running Club

    FAO: Data Protection Officer

    15 Shilton Street

    Ramsbottom, Bury

    BL0 9NG

     

    2. Why We Need Your Data

     

    In order that we can provide you with the best membership experience and for our Club’s ongoing development it is critical we collect certain information from you so that we know who our members are. There are many reasons for this, from simple stuff like providing essential information in relation to your membership of the Club to enabling us to facilitate your participation in events and races.

     

    The General Data Protection Regulation (GDPR) and Data Protection Act 2018 (DPA) require that all information we collect must be done so under a specific lawful basis.

     

    There are six clearly-defined lawful bases for processing information, and we categorise the majority of our data processing under two of those: Contract and Legitimate Interests.

     

    2.1. Contract

    When you become a member of Ramsbottom Running Club we need certain information about you to enable us to provide you with the full range of benefits of being a member of the Club including, but not limited to the ability to purchase club kit, participation in the annual Club Championships and inclusion in other club activities such as social events.

     

    This lawful basis also includes any administrative or service-related emails, for example, to confirm your membership with the Club or to alert you of an update to this Privacy Policy or other policies that are relevant to you. These therefore do not offer an option to unsubscribe as they are necessary to provide the services you requested.

     

    If you do not provide the information required then we will not be able to offer you the full range of benefits that come with being a member of the Club.

     

    2.2. Legitimate Interests

    Outside of your direct participation in Ramsbottom Running Club sessions, events and races we also wish to develop the reach and impact of the club and as such have a legitimate interest to process certain information with this aim. This includes things like carrying-out research to:

    - understand who is or isn’t participating in club sessions, races, events and activities

    - understand our ability to make the club as welcoming as possible

    - capturing and sharing images of our sessions, races and events taking place, helping us to inspire other people to engage in club activities.

     

    2.3. Other Bases

    Although extremely rare, there can be occasions where we are required to process information under one of the other four lawful bases: Consent, Legal Obligation, Vital Interest, Public Task.

     

    3. Categories of Data

     

    We utilise the following definitions for the types of data we collect:

     

    3.1. Identity

    Full name, gender, date of birth, images, medical/health information, ethnicity

     

    3.2. Contact

    Postal address, telephone number, email address, emergency contact name, emergency contact number

     

    3.3. Incident

    As part of our continual review of incidents we maintain a record of relevant details.

     

    3.4. Survey

    Any data submitted to us as part of our research activities.

     

    3.5. Club Imagery

    Filming and photography captured at our club sessions, events and races.

     

    4. What Data We Collect

     

    There are a number of ways where either you are able to explicitly share data with us or we are able to collect it as a result of your actions:

     

    4.1. When you become a member

    We collect information about you that allows us to support your participation in club sessions, races and events. We use this information to:

     

    - ensure we know about any relevant medical conditions that may affect your safe participation

    - ensure we know who to contact in the case of an incident or emergency concerning you while you are participating in club activities

    - process your results in relation to your participation in Club Championship events

     

    We also collect information around your activity levels, disability, ethnicity and other relevant personal information that may help us support your participation more appropriately.

     

    4.2. Surveys

    From time-to-time we send out surveys that allow us to develop an understanding of the extent to which Ramsbottom Running Club is fulfilling its aims and objectives.

     

    4.3. Incident reports

    Compiled by our volunteer Welfare Officer in the event of an incident. Relevant data is collected and uploaded directly to our secure online incident reporting system. In some cases we are required to pass on relevant information to external agencies such as the Health & Safety Executive, Local Authority Safeguarding Team or the Police.

     

    4.4. Cookies

    Some third-party services we use, such as our website provider Strikingly, may place cookies in your online browser. To manage the collection of information through cookies or other equivalent technology you can use the settings on your browser or mobile device.

     

    4.5. Social Media

    When you engage with Ramsbottom Running Club over social media, it will usually be as a registered user of that social media platform. The use of personal data on social media is governed by your agreement with that platform’s own privacy policy or terms and conditions. Ramsbottom Running Club’s official social media pages are administered by Ramsbottom Running Club as a data controller of these pages. These social media platforms may process user personal data to deliver anonymised user statistics to the local administrator of that page or event. We do not use the personal data you have made available on social media outside of that platform, unless you have given us your consent to do so.

     

    4.6. Club Photography and Filming

    Photography or filming is likely to take place at our club sessions, events and races, is common practice, and helps us to inspire other people to engage with the club. It also provides a means for historical recording of club activities over time. Furthermore, our use of images helps to demonstrate the diverse range of people who are involved in the club.

     

    We ensure compliance with safeguarding laws and are supported both in-house through our designated Club Welfare Officers and externally with the support of other experts in the field of safeguarding.

     

    In line with the lawful basis of Legitimate Interest individuals have the right to object to this method of data processing by asking the person taking the photograph directly, or via Ramsbottom Running Club (when images are displayed on the Clubs owned platforms), and requesting deletion of relevant imagery.


     

    5. What Data We Share

     

    5.1. England Athletics Affiliation

    When you become a member of or renew your membership with Ramsbottom Running Club you will automatically be registered as a member of England Athletics. We will provide England Athletics with your personal data which they will use to enable access to an online portal (called myAthletics). England Athletics will contact you to invite you to sign into and update your MyAthletics portal which, amongst other things, allows you to set and amend your privacy settings. I

    f you have any questions about the continuing privacy of you personal data when it is shared with England Athletics, please contact dataprotection@englandathletics.org

     

    5.2. Anonymised Participant Data

    Under the lawful basis of Legitimate Interest, we may pass anonymised membership data to external funders of club activities, including gender, ethnicity, physical activity levels and disability. This will be used solely for monitoring purposes and to identify where future interventions and funding might be best invested to increase levels of engagement amongst underrepresented groups.


     

    6. How We Contact You

     

    The large majority of our outgoing communication is via the closed ‘Ramsbottom Running Club - Members’ Facebook group. Communicating with you in this way is a form of data processing, and as such may only be carried out under a specific lawful basis.

     

    6.1. Under the Lawful Basis of Fulfilling a Contract

    In order to fulfil our obligation to you as a member of Ramsbottom Running Club to ensure our sessions, races and events are delivered in a safe and appropriate manner, to ensure the club is managed appropriately, and to ensure that all members are given equitable access to membership benefits there are some communications we send to all members via email.

     

    The following communications fall into this category:

     

    - Confirmation of your club membership / membership renewal

    - Updates to key documents, such as this privacy policy

    - Essential announcements in relation to your membership of the club

    - Details of the Annual General Meeting

     

    6.2. Under the Lawful Basis of Legitimate Interest

    There are some occasions where we may contact you as part of our ongoing club development activities. For example, where we write to members with the aim of understanding how we might be able to make the club as welcoming and supportive as possible for everyone.

     

    The following types of communications fall into this category:

     

    - Questionnaires aimed at developing our understanding of the effectiveness of Ramsbottom Running Club in relation to the objectives of the club

    - Questionnaires for research aimed at understanding the effect that Ramsbottom Running has on your individual health and wellbeing

     

    You have a right to object to receiving these emails, to do that please contact us directly via members@ramsbottomrunningclub.co.uk


     

    7. How We Protect Your Information

     

    We work extremely hard to apply appropriate security measures in order to protect your data from being accessed or disclosed without your permission, or lost. We have a small volunteer committee who oversee the management and governance of Ramsbottom Running Club, who are regularly updated on good practice in data handling, all personal data is password protected and only available to those with a specific need for access.

     

    In the event of a data breach we will notify you and any applicable regulator, where legally required to do so.


     

    8. Retention Periods

    In order to present our data retention periods as simply as possible we have chosen to do so using our definitions of categories of data defined in section 3 above.

     

    8.1. Identity Data –

    Date of birth and medical/health information will be deleted upon the non-renewal of membership annually.

     

    8.2. Contact Data –

    Postal address and telephone number will be deleted upon the non-renewal of membership annually.

     

    We will however retain the first name, surname, gender and email address of members in perpetuity for the purposes of historic records of club membership.

     

    We will also retain your emergency contact name and emergency contact number in perpetuity in case you return to weekly club sessions on an occasional basis in future.

     

    8.3. Incident Data – In perpetuity

    We retain this data in order to keep a historical record of our incident profile, from which we are able to continually review our operating policies in order to enable the safe and appropriate delivery of our club sessions.

     

    8.4. Survey Data – In perpetuity

    This data is used for the purposes of understanding our club members in greater detail. Changes over time are of particular interest where comparison of current versus historical data allows us to assess the impact of actions taken to improve club activities.

     

    8.5. Club Imagery – In perpetuity

    Club imagery is predominantly processed under the lawful basis of Legitimate Interest, and may be stored securely in perpetuity as it represents a historical record of club sessions, races, events and activities. Although extremely rare, there can be occasions where we are required to process information conveyed in photographs under another of the lawful bases, such as Consent, Legal Obligation, Vital Interest, Public Task.


     

    9. Your Rights

     

    You have the right to:

     

    9.1. Be informed if your personal data is being used

    Where appropriate we endeavour to inform you of this at the point where your data is being collected, however for circumstances where that is not practical or possible please refer to this Privacy Policy.

     

    9.2. Get copies of your data

    You are also free, at any time, to request a downloadable copy of all the data we hold on you. To do this please contact us via: members@ramsbottomrunningclub.co.uk

     

    9.3. Have your data corrected

    If at any time you feel the data we hold on you is incorrect, please contact us via: members@ramsbottomrunningclub.co.uk

     

    9.4. Have your data deleted

    Should you wish, at any time, for us to delete your data then please contact us via: members@ramsbottomrunningclub.co.uk and we can enable this process.

     

    9.5. Limit how we use your data

    If you are concerned about the accuracy of the data or how it is being used please contact us. Where you have previously provided us with consent to use your personal data in a specific way, you can remove your consent at any time (or opt-out) by emailing us.

     

    9.6. Object to the use of your data

    Where we are processing your data under the lawful basis of Legitimate Interest you have the right to raise an objection to that processing. This is not an absolute right to object and we will carry out a balancing test where we assess the reasons for your objection in the context of our legitimate interests.

     

    9.7. Raise a concern

    If, at any time, you have a concern as to how we are handling your information then please contact us. If you feel that we have not addressed your concerns appropriately you have the right to raise them directly with the ICO (read more).