DEWSBURY AMATEUR SWIMMING CLUB CLG
PRIVACY NOTICE FOR OUR MEMBERS

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We are committed to respecting your privacy.

This notice is to explain how we may use personal information we collect before, during and after your membership with us. This notice applies to you if you have registered to become or are currently a member of our club. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.
References to WE, OUR or US in this privacy notice are to Dewsbury Amateur Swimming Club CLG also known as Dewsbury Dolphins.

We have not appointed a named Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but Gillian Johnson on behalf of a Data Protection Compliance Manager has overall responsibility for data protection compliance in our club/organisation. Contact details are set out in the ‘Contacting us’ section at the end of this Privacy Notice.

1. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
Depending on the type of membership you register for with us, you may initially provide us with or we may obtain personal information about you, such as information regarding your:
• Personal contact details that allows us to contact you directly such as name, title,
email addresses and telephone numbers;
• Date of birth;
• Gender;
• Membership start and end date;
• References of your interactions with us such as telephone conversations, email and
other correspondence and your instructions to us;
• Records of your attendance at regular training sessions and any events hosted by us
or other sports clubs when representing us;
• Images in video and/or photographic form and voice recordings;
• Identification documents such as passport etc.;
• Details of next of kin, family members and emergency contacts;
• Records and assessment of any swimmer ranking, grading or rating, competition
results, details regarding (events) attended and performance;
• Any disciplinary and grievance information.

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following ‘Special Categories’ of more sensitive personal information regarding you:
• Information about your health, including any medical conditions, health and sickness records, medical records and health professional information.
We may not collect all of the above Special Category personal information about you. In relation to the special category personal data that we do process we do so on the basis that:
• The processing is necessary for reasons of substantial public interest, on a lawful basis;
• It is necessary for the establishment, exercise or defence of legal claims;
• It is necessary for the purposes of carrying out the obligations and exercising our or
your rights in the field of employment and social security and social protection law;
or;
• Based on your explicit consent.
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In the table following we refer to these as ‘special category reasons for the processing of
your personal data’.
We may also collect criminal records information about you. For criminal records history we
process it on the basis of legal obligations or based on your explicit consent.

3. WHERE WE COLLECT YOUR INFORMATION
We typically collect personal information about our members when you apply to become a
member of the club, you register your details when you complete a membership form and
make payment for your annual and/or weekly membership fees. We also collect
information when you make a query and/or complaint or when you correspond with us by
telephone, email or in some other way i.e. through a social media messenger page.
We may also collect personal information about you from any third party references you
provide as part of the application process for membership.
If you are providing us with these details of referees, next of kin, family members and
emergency contacts, they have a right to know what personal information we hold on them
and how we collect or may share it. Please ensure your share this Privacy Notice with those
of whom you feel are sufficiently mature to understand it. They also have the same rights as
set out in the ‘Your rights in relation to personal information’ section below.

4. USES MADE OF THE INFORMATION
The table below describes the main purposes for which your personal information, the
categories of your information involved and our lawful basis for being able to do this.
Purpose Personal Information Used Lawful Basis
To administer any membership you
have with us and managing our
relationship with you, including dealing
with payments and any support or
service enquiries made by you
All contact and membership
details, transaction and
payment information and
records of your interactions
with us.
This is necessary to enable us to properly
manage and administer your
membership contract with us.
To arrange and manage any contracts
for the provision of any services or
products
Contact details, transaction
and payment information.
Records of your interactions
with us.
This is necessary to enable us to properly
administer and perform any services and
products you have purchased from us.
To send you information which is
included within your membership
including details about competitions,
galas and any updates on swimming.
Contact and membership
details.
This is necessary to enable us to properly
manage and administer your
membership contract with us.
To send you marketing information
relating to our club including any
newsletters, information about
memberships, events and products
Contact details and marketing
preferences.
Where you have given us your explicit
consent to do so.
To answer your queries or complaints Contact details and records of
your interactions with us.
We have a legitimate interest to provide
complaint handling services to you in
case there are any issues with your
membership – this may include involving
a third party such as a governing body
who will provide guidance and support
to the club however this is on a
confidential basis.
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Retention of records All the personal information
we collect.
We have legitimate interest in retaining
records whilst they may be required in
relation to complaints. We need to
retain records in order to properly
administer and manage your
membership and run our club and in
some cases we may have legal or
regulatory obligations to retain records.
We process special category personal
data on the basis of the ‘special category
reasons for the processing of your
personal data’ referred to in section 2.
For criminal records history we process it
on the basis of legal obligations or based
on your explicit consent.
For the purposes of promoting the club,
our events and membership packages.
Images in video and/or
photographic form.
Where you have given us your explicit
consent to do so.
To comply with health and safety
requirements
Records of attendance,
medical information about
your health.
We have a legal obligation and a
legitimate interest to provide you and
other members of our club/organisation
with a safe environment in which to
participate in sport.
We process special category personal
data on the basis of the ‘special category
reasons for the processing of your
personal data’ referred to in section 2.
To administer your attendance to
weekly training sessions and any
programmes/courses or
competitions/galas you sign up to
All contact and membership
details, transactions and
payment data.
This is necessary to enable us to register
you on to and properly manage and
administer your attendance at weekly
training sessions and any programmes/
courses or competitions/galas.
To arrange for any trip or
transportation to or from an event
Identification documents,
details of next of kin, family
members and emergency
contacts, transaction and
payment information, health
and medical information.
This is necessary to enable us to make
the necessary arrangements for the trip
and/or transportation to an event.
We process special category personal
data on the basis of the ‘special category
reasons for the processing of your
personal data’ referred to in section 2.
To use information about your physical
or mental health (including injuries) or
disability status, to ensure your health
and safety and to assess your fitness to
participate in any events or activities
we host.
Health and medical
information
We process special category personal
data on the basis of the ‘special category
reasons for the processing of your
personal data’ referred to in section 2.
To gather evidence for possible
grievance or disciplinary hearings
All the personal information
we collect
We have a legitimate interest in doing so
to provide a safe and fair environment
for all members and to ensure the
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effective management of any disciplinary
hearings, appeals and adjudications.
We process special category personal
data on the basis of the ‘special category
reasons for the processing of your
personal data’ referred to in section 2.
For criminal records history we process it
on the basis of legal obligations or based
on your explicit consent.
For the purposes of equal opportunities
monitoring
Name, title, date of birth,
gender, information about
your race or ethnicity and
health and medical
information
We have a legitimate interest to
promote a sports environment that is
inclusive, fair and accessible.
We process special category personal
data on the basis of the ‘special category
reasons for the processing of your
personal data’ referred to in section 2.
To comply with legal obligations, for
example, regarding people working
with children or vulnerable adults to
comply with our safeguarding
requirements
Information about your
criminal convictions and
offences
For criminal records history we process it
on the basis of legal obligations or based
on your explicit consent.
For some of your personal information you will have a legal, contractual or other requirement or
obligation for you to provide us with your personal information. If you do not provide us with the
requested personal information we may not be able to admit you as a member or we may not be
able to properly perform our contract with you or comply with legal obligations and we may have to
terminate your membership. For other personal information you may not be under an obligation to
provide it to us, but if you do not provide it them we may not be able to properly perform our
contract with you.
Where you have given us your consent to use personal information in a particular manner, you have
the right to withdraw this consent at any time, which you may do so by contacting us as described in
the ‘Contacting us’ section.
Please note however that the withdrawal of your consent will not affect any use of the data made
before you withdrew your consent and we may still be entitled to hold and process the relevant
personal information to the extent that we are entitled to do so on the bases other than your
consent. Withdrawing consent may also have the same effects as not providing the information in
the first place, for example we may no longer be able to offer you a membership.
5. DIRECT MARKETING
Email, phone, post and SMS marketing: We will not contact you through by post, telephone
or SMS for marketing purposes. All events and product promotion will be done through the
members facebook page, on our club website or by email to you providing you have given
consent to do so. If a member does not attend training sessions for a period of 4 weeks a
committee member will contact the member by phone or email to discuss if there is a
problem the club need to be aware about or to confirm the member no longer wishes to be
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a member of the club. If the club are unable to contact you following 3 months of none
attendance the member will have their membership cancelled without further notice.
6. DISCLOSURE OF YOUR PERSONAL INFORMATION
We share personal information with the following parties
• Any party approved by you
• To any governing bodies or regional bodies for the sports covered by our club
(swimming) to allow them to administer the sports on a local, regional and national
level.
• 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.
7. 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.
We will take all reasonable steps to ensure that your personal information is only used in
accordance with this Privacy Notice and application data protection laws and is respected
and kept secure and where a third part processes your data on our behalf we will put in
place appropriate safe guards as required under data protection laws. For further details
please contact us by using the details set out in the ‘Contacting us’ section.
8. HOW LONG DO WE KEEP PERSONAL INFORMATION?
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, personal
information that we need to retain for legal purposes will normally be retained in
accordance with usual commercial practise and regulatory requirements. Generally, where
these is no legal requirement we retain all physical and electronic records for a period of 6
years after your last contact with us or the end of your membership. Exceptions to this rule
are:
• Details regarding unsuccessful membership applicants where we hold records for a
period of not more than 12 months;
• Information that may be relevant to personal injury or discrimination claims may be
retained until the limitation period for those type pf claims has expired. For
personal injury or discrimination claims this can be an extended period as the
limitation period might not start to run until a long time after the event.
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 using the details set
out in the ‘Contact us’ section.
9. 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;
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• 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.
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.
Whilst this Privacy Notice sets out a general summary of your legal rights in respect of
personal information, this is a very complex area or law. More information about your legal
rights can be found on the Information Commissioners website at http://ico.org.uk/for-thepublic/.
To exercise any of the above rights, or if you have any questions relating to your rights,
please contact us by using the details set out in the ‘Contacting us’ section.
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 complain
first.
10. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a
material, we will update the version date at the bottom of this page. For significant changes
to this notice we will try to give you reasonable notice unless we are prevented from doing
so. Where required by law we will seek your consent to changes in the way we use your
personal information.
11. CONTACTING US
In the event of any query or complaint in connection with the information we hold about
you, please email info@dolphins-asc.co.uk or write to us at
Registered office: Dewsbury Amateur Swimming Club CLG c/o Harrison
Blakeley Accountancy Limited, 21 Church Street, Horbury, WF4 6LT