Special Olympics Plymouth and District (SOPD) is committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that your provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulations (the GDPR).
Data Controller – A controller determines the purposes and means of processing personal data.
Data Processor – A processor is responsible for processing personal data on behalf of a controller.
Data Subject – A natural person.
Categories of Data: Personal data and special categories of data
Personal Data – The GDPR applies to ‘personal data’ meaning any information relating to natural persons who can be identified, or who are identifiable, directly from the information in question; or who can be indirectly identified from that information in combination with other information (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special Categories of Personal Data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third Party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who Are We?
SOPD is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: firstname.lastname@example.org
3. The Purpose of Processing Your Personal Data
We use your personal data for the following purpose:
To assess eligibility to participate in SOGB competitions and manage safely and effectively your participation in the Club’s activities.
4. The Categories of Personal Data Concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal Data Special Category Personal Data (health information)
We have obtained your personal data from:
Forms completed by you or on your behalf by your carers. Verbal confirmation of changes to your details given by you or your carers. Confirmation of registration details from Special Olympics GB.
In order to monitor overall traffic to the website we employ the use of web analytics services which record the IP address of website visitors.
In order to protect the website from malicious web traffic and attacks we employ the use of the Wordfence and Sucuri plugins which record the IP address of website visitors.
Our primary web analytics service is managed by Google and they, as a Data Processor, store the primary website traffic data.
Our website is hosted by Siteground, who also provide a web analytics service, and they, as a Data Processor, store the website’s files, database and website traffic data.
Our website is provided by Linedot Web Design and they, as a third party Data Controller, share access to all data processed on the website as well as the website traffic data.
We DO NOT use publicly accessible sources to obtain data about you.
5. What is our Legal Basis for Processing Your Personal Data?
a) Personal Data (article 6 of GDPR)
The processing of personal data in SOPD is deemed necessary for legitimate interest reasons of the data controller or a third party (YMCA Plymouth or Special Olympics GB). SOPD processes Members’ and Volunteers’ personal data in ways they would reasonably expect it to be processed where their membership or association with us is the compelling justification for the processing.
We process personal data generated on our website under the lawful basis of Legitimate Interests, including personal data generated by website analytics services, and website security plugins.
Consent of the Data Subject. SOPD understand that not everyone wants to have their photograph taken, or that there may be legal reasons why this cannot be done, so we ask your permission to take photographs or make videos which include your image.
We also ask permission to check your eligibility to become a registered Special Olympics GB (SOGB) Athlete. If you give your permission we give your name to our Eligibility Officer who performs the check and certifies whether or not you are eligible under SOGB rules, while maintaining NHS confidentiality rules.
These consents are built in to the basic information form that we ask all new joiners to compete when first attending the Club. You are under no obligation to give your consent, and you can change your mind at any time either to cancel the consent or to give the consent.
b) Special Category Personal Data (article 9 of GDPR)
The processing of special category personal data in SOPD is deemed necessary to protect the vital interests of the data subject and to assess eligibility of the data subject to participate in Special Olympics activities.
More information on lawful processing can be found on the ICO website
6. Sharing Your Personal Data
Your personal data will be treated as strictly confidential, and will be shared only with:
YMCA Plymouth (for safety we share a named attendance list with YMCA) Special Olympics GB
7. How Long do we Keep Your Data?
We keep your personal data for no longer than reasonably necessary, and only until you tell us you are leaving SOPD or until 2 years after you last attend the Wednesday Club, when we will assume you have left us. At this time your data will be carefully anonymised so you cannot be identified, but can be used by SOPD for statistical purposes when applying for funding and for historical purposes.
Any personal data generated by our primary web analytics service is deleted once it is 26 months old.
8. Providing us With Your Personal Data
We require your personal data as it is a requirement necessary to take part in the Club’s activities.
9. Your Rights and Your Personal Data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you; The right to request that we correct any personal data if it is found to be inaccurate or out of date; The right to request your personal data is erased where it is no longer necessary to retain such data; THE RIGHT TO WITHDRAW YOUR CONSENT TO THE PROCESSING AT ANY TIME, WHERE CONSENT WAS OUR LAWFUL BASIS FOR PROCESSING THE DATA; The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to portability) where applicable; The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that a restriction be placed on further processing; The right to object to the processing of personal data, where applicable.
For further information on your rights, see the ICO website
10. Transfer of Data Abroad
SOPD DOES NOT TRANSFER PERSONAL DATA OUTSIDE THE EEA
11. Automated Decision Making
SOPD DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING
12. Further Processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to Make a Complaint
To exercise all relevant rights, queries or complaints, please in the first instance contact our Data Representative, Lee Fergusson – email email@example.com
If we are unable to resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office:
by phone on 030 3123 1113
by email at https://ico.org.uk/global/contact-us/email/
or by post to:
The Information Commissioner’s Office
Cheshire SK9 5AF
Special Olympics GB Data Protection Policy
Special Olympics GB Privacy Statement