Tamesis Club Limited (Tamesis Club) Data Privacy Policy

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Tamesis Club Limited (Tamesis Club, the Club) Data Privacy Policy

January 2024

Introduction

• 1.Tamesis Club is committed to managing personal data in compliance with UK data legislation. The principal aims are that data will be:

processed lawfully, confidentially, fairly and transparently

collected for specified, explicit and legitimate purposes

relevant and limited to what is necessary for processing

accurate and kept up to date

retained only for as long as necessary

processed in an appropriate manner to maintain security.

• 2.We ask all members and officers of the Club to agree to the policy contained in this document. This document explains how Tamesis Club collects information, how it is held and how it is used. The document explains your rights with regard to that information.

• 3.Tamesis Club's Data Controller leads in implementing this policy.

Contact

• 4.Please contact Tamesis Club's Honorary Assistant Treasurer, who acts as the Data Controller, using membership@tamesisclub.co.uk for any matters relating to data privacy.

Purpose

• 5.Tamesis Club operates as a member-run club that arranges sailing, paddleboarding, other on-water activities, training, boat and craft storage, social and other activities for its members and for external parties. Tamesis Club arranges participation and duties for members and other individuals. On occasion, Tamesis Club makes its facilities and services available to third parties. Tamesis Club engages in, but is not limited to, understanding the interests of members and potential members, encouraging additional membership, promoting all forms of sailing and related activities, organising appropriate sailing, on-water and social events and maintaining a historical record of the Club's activities.

Principle

• 6.Tamesis Club processes data lawfully, fairly and in a transparent manner in relation to individuals.

Policy

• 7.Members and other authorised users of the Tamesis Club's data are required to adhere to this data privacy policy.

Bases for processing data Contract, Legitimate Interest and Consent

• 8.Tamesis Club has a tiered approach to the legal bases for processing personal data. In any situation, more than one legal basis may apply. The rights of individuals vary depending on the basis that applies in accordance with the legislation.

• 9.Contract and Legitimate Interest: members of Tamesis Club, those participating in training and those organising or attending events, enter into a contractual relationship with the Club and personal data is processed in order to fulfil that relationship. Equivalent relationships, for data processing purposes, exist in the case of those applying to become members, signing up for courses or events, and former members.

• 10.Processing under the bases of Contract and Legitimate Interest includes processing of application forms and membership questionnaires. Club officials have access to personal data and may use this, for example, to contact members about their subscriptions, to promote sailing in accordance with the Club's purpose, to provide newsletters or to provide notification of events.

• 11.Tamesis Club uses a number of email distribution lists to contact members. Emails are sent in compliance with the Club's purpose.

• 12.Consent: Tamesis Club offers a number of services for which individuals provide specific additional consent. These include, but are not restricted to, an online member directory (accessible by members) and member to member messaging.

• 13.Where "Consent" is the basis for processing, Tamesis Club asks individuals for consent at the time of first requesting the service. Individuals have the right to withdraw consent.

• 14.Historically, consents for additional services have been considered by the management committee of Tamesis Club to be part of the membership contract. For new requests, Tamesis Club will ask members to provide consent when requesting or accessing these services for the first time in compliance with legislation current at the time.

• 15.Legitimate Interest: Tamesis Club processes personal data in which it has legitimate interest in a number of further circumstances. Tamesis Club holds personal data in relation to the organisation of events and may share this with other organisations where necessary for the running of those events. Tamesis Club holds personal data of individuals whom it considers may be prospective members. Tamesis Club collects information on members' sailing interests and other preferences.

• 16.Tamesis Club holds such personal data where necessary to further the objects of the Club.

• 17.Vital interest: On occasion, Tamesis Club holds personal data, such as in relation to allergies or medical conditions, in order to allow safe organisation of events.

Sensitive Personal Data

• 18.Sensitive Personal Data which relates to an individual and includes protected attributes such as: race, ethnic, political, religious, trade union, physical or mental health, sexual orientation, criminal proceedings or convictions. Where Tamesis Club holds Sensitive Personal Data, Tamesis Club will use reasonable further endeavours to protect such information.

Rights of individuals

• 19.Current legislation provides rights for individuals covering:
  • The right to be informed
  • The right of access
  • The right of rectification
  • The right of erasure
  • The right to portability
  • The right to object; and
  • Rights in relation to automated decision-making and profiling.

• 20.If you have any concerns about the data Tamesis Club holds or processes, please contact the Data Controller.

• 21.Users may manage certain consents online through a members' portal on Sailing Club Manager.
• 22.Tamesis Club may require further proof of identity from any individuals requesting access to data.
• 23.Individuals have the right to register a complaint with the Information Commissioner's Office or successor organisations.

Photography and Videos

• 24.Gathering photographs or video of events is in the legitimate interests of the Club and/or part of the membership contract. The Club may publish photographs or videos of events or individuals. The Club will endeavour to remove any photographic material on request.

Data retention

• 25.Tamesis Club retains personal data only for as long as is necessary for contractual purposes, for carrying out the purpose of the Club, for event organisation, for legal requirements and for historical record keeping purposes. The retention period in appropriate circumstances may be indefinite.

Minors

• 26.In situations where Tamesis Club holds the personal data of minors, Tamesis Club applies this data privacy policy.

• 27.Consent for under 18 year olds. Junior members are not entitled to be members without a parent or other legal guardian who is already a member. Parents or legal guardians must grant consent to use data on behalf of all dependent junior members.

Location of data processing

• 28.Sailing Club Manager, the "Data Processor", carries out data processing under contract. The terms and conditions relating to Sailing Club Manager's data processing may be found on their website:
  • Terms of Service
  • Privacy Policy
  • Cookie Policy
  • GDPR Compliance
  • Subprocessors

• 29.All data processing is carried out within the United Kingdom, the United States or the European Union.

Sharing of information

• 30.Tamesis Club does not routinely disclose members' personal data to third party organisations nor does it undertake direct marketing on behalf of any such organisation.

• 31.Tamesis Club shares the information necessary for the organisation of events with other relevant parties. Tamesis Club occasionally shares data with the RYA and other relevant sailing organisations.

• 32.In the event of there being a legal requirement to share data with the Police or other authorities, personal data may be provided without the need to obtain consent from the individual(s) concerned.

Social media platforms

• 33.Members from time to time may make use of social media platforms such as Facebook, WhatsApp, Instagram or X. Users sign up individually and separately to such sites. This Privacy Policy does not cover use of such social media platforms.
• 34.Members should, however, exercise care when using such platforms not to share personal information inappropriately.

Printed media

• 35.Tamesis Club processes personal data in accordance with this policy at the time of going to press and endeavours to minimise the incidence of inaccuracies. Once printed, it may not always be possible to control circulation or to rectify errors if data subsequently prove to be inaccurate.

Updates

• 36.Tamesis Club reviews and, if appropriate, updates its privacy policy every two years or more frequently as required.

Last updated 18:38 on 25 April 2024