Introduction
The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.
The Shropshire Chess Association is a data controller within the meaning of the GDPR and we process personal data. The association has opted not to appoint a data protection officer, however any concerns about your data and any subject access requests should be addressed to the general secretary.
We may amend this privacy notice from time to time. If so, we will supply you with and/or otherwise make available to you a copy of the amended privacy notice.
This privacy notice should be read in conjunction with the privacy notice of our parent body, Shropshire Chess Association Privacy Notice.
The purposes for which we intend to process personal data
We intend to process personal data for the following purposes
- To keep you informed of all upcoming events.
- To be able to contact yourselves in emergency circumstances.
- To fulfil our legal obligations to safeguard children in our care.
The legal bases for our intended processing of personal data
Our intended processing of your or your child’s personal data has the following legal bases:
- You have given written consent to ourselves processing your personal data for the purposes listed above
- The processing is necessary for the running of the clubs activities.
- The processing is necessary for compliance with legal obligations to which we are subject.
It is a requirement of being a member of the club that you provide us with the personal data that we request.
Persons/organizations to whom we may give personal data
If the law allows or requires us to do so, we may share your or your child’s personal data with:
- the police and law enforcement agencies
- Child Protection Agencies
- the Information Commissioner’s Office (“ICO”)
We may need to share your personal data with the third parties identified above in order to comply with our legal obligations.
Transfers of personal data outside the UK
All personal data will be processed in the UK only.
Retention of your/your child’s personal data
When acting as a data controller we will retain data relating to you or your child as follows:
- If no concerns are raised then your information will be retained for 1 year after last contact with you or your child.
- Where child welfare concerns are referred to children’s social care or the police then records will be retained for 6 years after last contact with you or your child.
At the end of the retention period all records will be destroyed.
Retention of personal data about our volunteers
- Any records of concerns about our volunteers will be retained until they reach pension age or for 10 years, whichever is longer. If the allegation is proven to be malicious the record will be destroyed immediately.
- Criminal records check certificates will not be retained unless there is a dispute about the results of the check. Instead only the reference number of the certificate and the decision made about whether the person may act as a volunteer will be retained.
How we store your data
- All data will be stored electronically and will be password protected
- This password will be known only to the Lead Child Protection Officer and the General Secretary
- Only the Lead Child Protection Officer will have direct access to the data
- All data will be securely backed up on an external hard drive.
- Any data stored in relation to child protection concerns and referrals will be kept separate from any general records held and a separate child protection file will be created for each child.
Requesting personal data we hold about you (subject access requests)
You have a right to request access to personal data that we hold about you or your child. Such requests are known as ‘subject access requests’ (“SARs”).
Please provide all SARs in writing.
To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information.
DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request).
You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply.
Putting things right (the right to rectification)
You have a right to obtain the rectification of any inaccurate personal data concerning you or your child that we hold. You also have a right to have any incomplete personal data that we hold about you or your child completed. Should you become aware that any personal data that we hold about you or your child is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.
Deleting your records (the right to erasure)
In certain circumstances you have a right to have the personal data that we hold about you or your child erased. Further information is available on the ICO website (www.ico.org.uk). If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.
The right to restrict processing and the right to object
In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website (www.ico.org.uk). Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.
Withdrawal of consent
Where you have consented to us processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.
Please note:
- the withdrawal of consent does not affect the lawfulness of earlier processing
- if you withdraw your consent, your child’s club membership will be terminated
- even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data)
Automated decision-making
We do not intend to use automated decision-making in relation to your personal data.
Policy Review
We will regularly review our record keeping policies to ensure they are effective and comply with current legislation.
Complaints
If you have requested details of the information we hold about you and you are not happy with our response, or you think we have not complied with the GDPR or DPA 2018 in some other way, you have a right to lodge a complaint with the ICO (www.ico.org.uk).