Privacy Notice – The Access to Sports Project
You have a legal right to be informed about how The Access to Sports Project uses any personal information that we hold about you. To comply with this, we provide a ‘privacy notice’ to inform you where we are processing your personal information. This privacy notice explains how we collect, store and use your personal information and what kind of information we hold.
We, The Access to Sports Project, (Registered Office: 8 Blackstock Mews, N4 2AW) are the ‘data controller’ for the purposes of data protection law. Our Data Protection Compliance Manager is John Mackinnon. Contact information is available below.
2 Who we are
The Access to Sports Project is a sports development charity operating in the London boroughs of Islington, Haringey and Hackney delivering progressive and sustainable sports projects for children, young people and adults. We aim to increase and sustain participation in sport and physical activity, especially for disadvantaged people or communities by providing:
• a range of accessible and affordable sports activities for local people in local venues.
• Accredited training for local people enabling them to gain qualifications as sports coaches/leaders
• Providing support and assistance to local sports organisations and voluntary groups interested in sports (eg. sports groups or community/voluntary organisations).
The Access to Sports Project is a registered company in England and Wales (4402633) and is also a registered charity (1122243)
References to “we”, “us” and “our” in this policy are references to The Access to Sports Project.
3 Statement of Intent
We need to collect and use certain types of information about our service users to operate our services. As a result you will be required from time to time to submit information about yourself to receive or use services.
The Access to Sports Project are fully committed to the correct storing and treatment of personal information. We take your privacy seriously and ensure that your information is handled safely and securely and in line with current data protection regulations. Whenever you provide such information, we will treat that information in accordance with this policy and fully endorse and adhere to the Data Protection Act. We will act in accordance with current legislation and aims to meet best practice.
4 Information we collect and how we use it.
The information we collect and the way in which is used includes:
• Ensure we know how you prefer to be contacted and act upon those preferences
• Process bookings and membership registrations for courses and events.
• Provide you with the services, products or information you have asked for
• Keep a record of your relationship with us
• Contact a parent, carer or emergency contact in an emergency
• Check to see if there are any medical conditions or allergies in an emergency
• Send you information by letter, e-mail or to contact you by telephone with information about the services you have registered for.
• Understand our impact and to assess the effectiveness of our work against our charitable aims
• Understand how we can improve our services or information
• In certain instances, to inform funding bodies about the young people whom our projects reach
Participants on our Sports and Physical Activity programmes
We collect your contact details and some statistical information to ensure we are fulfilling our charitable purpose, e.g. gender and ethnic background. Your safety is of paramount importance to us and therefore we collect details of any medical condition and emergency contacts. For more details, please see section 5.
In instances data related to Young People’s participation in our projects will be shared with our key funders and partners (Youth and leisure departments in Islington and Hackney) and other funders for reporting purposes. These partners are equally required to comply with the data protection regulations (see Section 7 for more information)
Finsbury Park Tennis
Finsbury Park Tennis is managed by the Access to Sports Project: We collect your contact details when you create an account with us (via the OpenPlay online system), allowing you to book classes and sessions online. We collect statistical information to ensure we are fulfilling our charitable purpose, e.g. gender, ethnic background, activity levels. We monitor your activity and usage of the facilities and use your contact details for marketing purposes to help improve our facilities, and offer classes appropriate to you. Your safety is of paramount importance to us and therefore we collect details of any medical condition and emergency contacts. For further details, please see section 5.
Coach Education & Training
In addition to the contact and medical information outlined above we may collect additional information this may include educational background, sporting qualifications previously completed, identity documentation and in some instances evidence of employment status, eligibility for public funds, residency and any learner support needs.
Our Staff, volunteers, trustees and job applicants
We have separate privacy notices which are provided to our staff, volunteers, trustees and Job Applicants
We collect and process personal data about our suppliers (including sub-contractors and individuals associated with our suppliers and subcontractors) in order to receive goods or services for the benefit of our participants and staff and to complete our contractual duties, e.g. make payments.
When we collect payment via PayPal or Stripe we do not keep any bank or card details or security codes supplied to make the transaction. We do retain a record of payments, payment amounts and customer contact details so that in the event of a cancellation, refunds can be processed.
• To enhance your experience of the website by storing various configurable settings used to personalise the web site. You do not have to reset them each time you visit the site. The settings stored are Filtering, Display Options and Centre Quick Links.
• To support the use of Google Analytics within the site. This analytical tool collects standard internet log information and visitor behaviour information in an anonymous form. The information collected is about your use of the website (including your IP address) and is transmitted to Google. This information is then used to evaluate the use of the website and to compile statistical reports on website activity. The Access to Sports Project will not use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our site. We will not associate any data gathered from this site with any personally identifying information from any source as part of our use of the Google statistical analytics tool. Google will not associate your IP address with any other data held by Google. Neither Access to Sports nor Google will link, or seek to link, an IP address with the identity of a computer user.
You have the option to accept or decline cookies by modifying the settings on your browser.
For more information on cookies please visit http://www.allaboutcookies.org/.
Links to third Parties
Our website may, from time to time, contain links to and from the websites of our organisations including partners, local authorities, sports organisation and clubs. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.
In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
5 Special Categories of personal Information (Sensitive Information)
Under current data protection regulation certain categories of personal information are considered more sensitive than others. Sensitive personal information we collect includes ethnicity, date of birth, health and medical conditions and information regarding children and young people. We collect sensitive data to:
• To maintain a safe and secure environment for participants including children and young people whilst attending our programmes.
• Enable us to understand who we are working with and ensure we are meeting our charitable aims through our work.
If you provide us with any sensitive personal information we will treat that information with extra care and confidentiality and always in accordance with this Privacy Notice.
6 How do we protect your information.
We are committed to ensuring that your information is secure. To prevent unauthorised access and improper use we have put in place suitable physical, electronic and managerial procedures to safeguard and secure all data we hold.
7 Disclosure of your personal information
Primarily we will use the information you have given us for the purposes of delivering our projects and programmes in line with our charitable objectives and will maintain your information on a strictly confidential basis and we will not sell or rent your information to third parties; and we will not share your information with third parties for marketing purposes.
There are however instances where the delivery of our charitable programmes requires that we share elements of personal data and these are outlined below.
• We share anonymised data about facility usage and participant demographics with our funders and partner sponsors. The data does not contain any personal information that can identify you or your address.
• Any party approved by you;
• governing bodies or awarding bodies for coach education and sports leadership for the learner certification and accreditation purposes;
• for the affiliation of players to national governing bodies of sport (NGBs) or NGB-affiliated leagues and events for the purpose of participation in Sporting competitions and events.
• Other service providers and advisors: we take bookings for our courses and activities via OpenPlay booking system. This system is bound by the same GDPR and has appropriate systems and security in place.
• External funding providers: We are required by funding agreements to share data (name, age, date of birth gender, post code, ethnicity) of participants of activities. This data is used for reporting purposes only and will not be used by the third parties to contact you with marketing communications. All our funders are equally required to comply with data protection laws. (See local authority section below).
• The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
• If you are taking part in an activity, or you have registered on someone else’s behalf (i.e as a parent or carer) we will store medical conditions and emergency contact details provided and will use these in the case of an incident.
Local Authorities: Islington and Hackney Council
In addition, if a child or young person accesses a project funded by Islington or Hackney Council details will be shared with Islington or Hackney Council and input into the Integrated Youth Services Database. Local authorities have a duty under the Children’s Act to work with partners to provide and improve services to children and young people in the area. Therefore Islington or Hackney Council may also use this information for other legitimate purposes and may share this information where necessary with other organisations responsible for administering services to children and young people.
8 Transferring your personal information internationally
The personal information we collect is not transferred to and stored in countries outside of the UK and the European Union.
9 How long do we keep your 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, information that we need to retain for legal or contractual purposes will normally be retained in accordance with usual practice and regulatory requirements. Information that may be relevant to personal injury or discrimination claims may be retained until the limitation period for those types of claims has expired.
Generally, where there is no legal or contractual 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:
10 Our legal basis for using your information
In some cases, we will only use your personal information where we have your explicit consent.
Legal Obligation may require us to process your information.
There are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for us to process your information to help us to deliver our programmes in line with our charitable objectives.
Whenever we process your personal information under the ‘legitimate interest’ basis we balance our identified legitimate interest and the need to process personal data against the interests, rights and freedom of the individual. We will not process personal information if we feel that there is an imbalance or that the interests of the individual override the identified legitimate interest.
11 Your rights in relation to personal information.
You have the following rights in relation to your personal information:
• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict processing of your personal information where certain requirements are met;
• the right to object to the processing of your personal information;
• the right to request that we transfer elements of your data either to you or another service provider; and
• the right to object to certain automated decision-making processes using your personal information.
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 can contact us by using the details set out in the “Contacting us” section below.
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.
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, or complaints 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.
12 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.
13 Contacting us
In the event of any query or complaint in connection with the information we hold about you, please email firstname.lastname@example.org or write to us at The Access to Sports Project (Mailing Address: Sobell Leisure Centre, Hornsey Road London N7 7NY)
Last updated 10 May 2018