DATA PRIVACY NOTICE
Sport Newcastle Charity is a ‘Data Controller’ which means that we are responsible for determining the purposes and means whereby we process personal data in relation to you. We are a registered charity which offers funding and support to men, women and children in the North East of England to assist them in achieving their sporting objectives. We seek to promote success through sport. We do this in a variety of ways including providing financial backing to individual athletes and sports people, clubs and coaches (also referred to in this document as ‘Applicants’).
Sport Newcastle is committed to full compliance with the requirements of the General Data Protection Regulation (‘GDPR’). We need to collect and use information about people with whom we engage in order to operate and carry out our core functions. We regard the lawful and appropriate treatment of personal information as being integral to our operations and to maintaining the confidence of all those with whom we engage. We will endeavour to deal appropriately and in accordance with the principles of GDPR with all personal information we use however it is recorded and collected and whether it is on paper, in electronic records or any other format.
The purpose of this document is to set out the policies and processes we will adopt to ensure that all of us who have access to any personal data held be us as data users are cognisant with and will abide by the obligations imposed by GDPR.
The GDPR Principles
In summary, to comply with the six basic principles of GDPR the way we process personal data must be:
1. Fair, lawful and transparent;
2. For a legitimate purpose;
3. Adequate, relevant and limited;
4. Accurate and up to date;
5. Such as to ensure that data is kept only as long as is necessary; and
6. Such as to ensure that it is kept secure.
What does this policy cover?
In carrying out our core functions we must engage with a number of third parties. In particular, we engage with the following:
The individual’s who apply to us for financial grants or rewards or others such as parents who make such applications on their behalf.
Representatives of clubs/organisations who apply to us for financial grants or rewards.
Our Friends and Supporters, both individual and corporate, on whose backing we are dependent to raise the funding required to enable us to offer financial support to individuals and clubs.
We will make use of the data we handle in relation to our Charity Office Holders and Committee members, Applicants, Friends and Sponsors, Project Partners, Suppliers and anyone else with whom we engage in carrying out our core functions.
This policy also describes your data protection rights, including your right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the ‘What rights do you have?’ section below.
What information do we collect?
We collect and process personal data from you or your parent when you apply to us for financial support or we engage with you in fulfilling our core functions. This may include:
your date of birth,
your contact details including your home or business address, email address and phone number;
[in the case of Applicants] your sporting background to include your sporting achievements, your membership of or involvement in particular teams, or any key role you may have played in support of an individual sportsperson or organisation.
your payment and/or bank account details, where you provide these when seeking or providing financial support or to enable us to fulfil other contractual obligations to you;
your marketing preferences, including any consents you have given us;
your medical conditions or disability information, where you provide this to us with your consent (or your parent’s consent) to ensure we are aware of any support we may need to provide to you.
Some information about you may be generated as part of your involvement with us, in particular data about your performance or your involvement in particular sporting matches or events.
Where you are an Applicant the information we hold in relation to you will ordinarily be collected from written or electronically transmitted forms.
What information do we receive from third parties?
Sometimes, we receive information about you from third parties. For example, where we seek references or testimonials to support an application for funding. If you are a child, we may be given information about you by your parents.
How do we use this information, and what is the legal basis for its use?
We process this personal data for the following purposes:
1. As required by the us to fulfil our core function and pursue our legitimate interests, in particular:
we will use your information to manage and administer applications for funding or awards;
we will also use data to maintain records of your sporting performances and history, including match or competitions outcomes and/or;
we may choose to send you promotional materials and offers by post or by phone, or by email where we want to send you offers relating to similar products and services that you have previously sought. Before doing so we will expressly seek your consent.
2. To fulfil a contract, or take steps linked to a contract: this is relevant where you we agree to provide financial support or you agree to provide us with financial support to fund our core functions. This may include:
communicating with you;
providing and arranging the delivery or other provision of products, prizes or services;
3. Where you give us consent:
we may send you direct marketing or promotional material by email;
we may handle medical or disability information you or your parent provide to us, to ensure we support you appropriately;
on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
4. For the purposes of fulfilling any legal obligations to which we are subject:
we may maintain records such as health and safety records and accounting records in order to meet specific legal requirements;
we may need to ensure, where you will work with children, that you have undergone an appropriate DBS check – this is also carried out with your consent.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent you will always be able to withdraw that consent unless we have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing material without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or any profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below in the ‘How do I get in touch with you?’ section below.
Who will we share this data with, where and when?
We may share your data with third parties where to do so would be consistent with the GDPR principles.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data may also be shared with third party service providers who will process it on our behalf for the purposes identified above. Such third parties might include the Charity Commission and any third party providers of data processing services we may use.
What rights do you have?
We are committed to ensuring that any data we process is accurate and up to date. We will be dependent on you to make us aware of any changes to your personal information. In certain circumstances you have the following rights in relation to your personal data:
the right to be informed of how we use your data – that is the purpose of this document.
the right to request access to your data – to do so you should make a ‘subject access request to us.
the right to request correction of your data – if any data we hold about you is incomplete or inaccurate you are entitled to require us to correct it.
the right to request erasure of your data – if you would like us to stop processing your data you have the right to ask us to delete it where you believe that there is no proper basis for us to continue processing it.
the right to object to the inclusion of information – where we are relying on a legitimate interest (or that of a third party) for processing your data you have the right to object to the way in which we are using it.
the right to request the restriction of processing of your data – you have the right to ask us to stop processing your data.
the right to portability of your data – you have the right to transfer the data we hold in respect of you for your own purposes.
the right to request the transfer of your data – you have the right to request the transfer of the personal information we hold in respect of you to another party.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with us using the details set out below. If you have any unresolved concerns, you have the right to complain to the Information Commissioner’s Office.
Some of the information listed above must be provided on a mandatory basis so that we can make the appropriate legal checks or as required by the Charity Commission. We will inform you which information is mandatory when it is collected. Some information is optional, particularly information such as your medical information. If this is not provided, we may not be able to provide you with appropriate assistance, services or support.
For the avoidance of doubt, where we have required you to consent to our use of your data you also have the right to withdraw your consent at any time. We must comply with this request unless we have a legitimate reason for continuing to hold your data or we are under a legal obligation to do so.
How do you get in touch with us?
We hope that we can satisfy any queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch with us at email@example.com or by writing to Christopher Potts, Data Officer, Sport Newcastle, PGS Law, Law Court Chambers, 20 – 22 Waterloo Street, South Shields, NE33 1AW.
How long will we retain your data?
Where we process personal data for marketing purposes or with your consent, we process the data for 3 years unless you ask us to stop when we will only process the data for a short period after this to comply with your requests. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your wishes in future.
Where we process personal data in connection with performing a contract or fulfilling some other legal obligation, we keep the data for 6 years from your last interaction with us.
We will retain information held to maintain statutory records in line with appropriate statutory requirements or guidance.
Where we process personal data obtained in connection with an application for financial support we will keep this data for six years from the date of the most recent application we have received on your behalf. We do so to enable us to fulfil a legitimate interest in monitoring the total financial support that has been requested by an individual person or organisation and to enable us to measure sporting achievements against stated objectives. As stated above, you have the right to object to us retaining this data if you do not believe that there is a legitimate interest justifying its retention.