International Budo
Federation/British CombatSombo Association/British Grappling Association
PRIVACY NOTICE FOR OUR MEMBERS
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 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.
This notice applies to
you if you are either:
1. [an individual player/participant of Combat
Disciplines who has
registered his/her interest in participating in the sport competitively and/or
whose details we have collected from one of our affiliated clubs, schools,
universities or other third-party referral];
2. [a coach, technical official or [referee/umpire] who
has registered for membership to find out more about the training courses and
accreditation services we offer]; or
3. [a fan, participant or supporter of the
[insert details of sport] who has [contacted us to purchase any of our online
merchandise and/or] signed up to receive updates about upcoming events, offers
and ways to get involved further with [insert details of the sport].
References to we, our or us in this
privacy notice are to the International Budo Federation 118 East Street
Sittingbourne Kent ME10 4RX
We have appointed a Data Protection Officer to oversee our
compliance with data protection laws [as we are not required to do so], but our
Data Protection Compliance Manager has overall responsibility for data
protection compliance in our organisation.
Contact details are set out in the "Contacting us" section at the end of this privacy notice.
When you sign up for membership with us, you may provide us
with or we may obtain personal
information about you, such as information regarding your Address
Combat Discipline
o
personal contact details that allows us to
contact you directly such as name, title, email addresses and telephone numbers;
o
date of birth;
o
gender;
o
membership details including start and end date;
o
records of your interactions with us such as
telephone conversations, emails and other correspondence and your instructions
to us;
o
records of your attendance at any events or
competitions hosted by us;
o
images in video and/or photographic form and
voice recordings; and
o
your marketing preferences so that we know
whether and how we should contact you.
Players/Participants
If you are a player/participant who has registered his/her interest in participating
in the sport competitively, you may also provide us with or we may
obtain the following additional personal
information from you identification documents such as passport and identity
cards;
o
details of any club and/or county membership;
o
details of next of kin, family members, coaches
and emergency contacts;
o
records and assessment of any player rankings,
gradings or ratings, competition results, details regarding
[events/matches/games] attended and performance (including that generated
through player pathway programme);
o
any disciplinary and grievance information;
o
any details required for the purposes of
awarding scholarship funding or grants (including any means testing;
Coaches and officials
If you have registered with us to receive more information
about [our coaching/teaching accreditation/qualification scheme and/or any of
our education and teaching programmes] you may also provide us with or
we may obtain the following additional personal
information from you:
o
any coaching code or official number;
o
your current affiliated club or other
organisation (if applicable);
o
coaching/teaching qualification and/or
officiating history and any player rating (if any);
o
accreditation/qualification start and end date;
o
identification documents such as passport,
utility bills, identity cards, etc.; and
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 condition, health and sickness records,
medical records and health professional information;
We may not collect all of the above types of 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
o
the processing is necessary for reasons of substantial
public interest, on a lawful basis;
o
it is necessary for the establishment, exercise
or defence of legal claims;
o
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
o
based on your explicit consent.
In the table below, we refer to these as the “special
category reasons for processing of your personal data”.
We may also collect criminal records information from 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 become a member of International
Budo Federation to purchase any services or products we offer online [e.g. where you are selling any merchandise],
when you make a query and/or complaint or when you correspond with us by phone,
e-mail or in some other way.
If you are a player/participant of Combat Disciplines we
also may collect personal information about you from any club, school or other
organisation you are affiliated with or from other referrals such as from
coaches or talent scouts.
If you are providing us with details of referees, next of
kin, beneficiaries, family members and emergency contacts they have a right to
know and to be aware of how what personal information we hold about them, how
we collect it and how we use and may share that information. Please share this privacy notice with those
of them 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 we
process 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
|
All Members
|
To administer any membership account(s)
you have with us and managing our relationship with you, [including arranging
for any insurance] and dealing with payments and any support, service or
product enquiries made by you
|
All contact and membership details, transaction
and payment information, records of your interactions with us, and marketing
preferences.
|
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 merchandise, products and/or services.
|
All contact and membership details.
Transaction and payment information.
|
This
is necessary to enable us to properly administer and perform any contract for
the provision of [merchandise/products/services].
|
To send you information which is
included within your membership benefits package, including details about advanced
ticket information, [your insurance],
competitions and events, partner offers and discounts and any updates on
Combat
Disciplines
|
All contact and membership details
|
This
is necessary to enable us to properly manage and administer your membership
contract with us.
|
To send you other marketing
information we think you might find useful or which you have requested from
us, including our newsletters, information about Membership, events,
participation products and information about our commercial partners
|
All contact and membership 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.
|
Retention of records
|
All the personal information we
collect
|
We
have a legitimate interest in retaining records whilst they may be required
in relation to complaints or claims. We need to retain records in order to
properly administer and manage your membership 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 processing of
your personal data” referred to in section 2 above.
For
criminal records history we process it on the basis of legal obligations or
based on your explicit consent.
|
The security of our IT systems
|
Your usage of our IT systems and
online portals.
|
We
have a legitimate interest to ensure that our IT systems are secure.
|
To conduct data analytics studies to
better understand event attendance and trends within the sport
|
Records of your attendance at any
events or competitions hosted by us.
|
We
have a legitimate interest in doing so to ensure that our membership is
targeted and relevant.
|
For the purposes of promoting the
sport, 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
|
We
have a legal obligation and a legitimate interest to provide you and other
members of our organisation with a safe environment in which to participate
in sport.
|
Players/participants
|
To conduct performance reviews,
manage performance and determine performance requirements and administer your
development and training requirements on any player pathway programme
|
All performance and attendance data
and information about your health and medical condition.
Details of any affiliated club and/or
county membership.
|
This
is necessary to enable us to properly manage and administer your development
through the performance programme.
We
process special category personal data on the basis of the “special category reasons for processing of
your personal data” referred to in section 2 above
|
To make decisions about your
progression and development through any player pathway programme and to
assist with the delivery of rankings and ratings
|
All performance and attendance data
and information about your health.
Details of any affiliated club and/or
county membership.
|
This
is necessary to enable us to properly manage and administer your development
through the performance programme.
We
process special category personal data on the basis of the “special category reasons for processing of
your personal data” referred to in section 2 above.
|
To administer and monitor your attendance
at events and competitions
|
All non-medical performance and
attendance data.
Details of any affiliated club and/or
county membership.
|
This
is necessary to enable us to register you on to and properly manage and
administer your development through the performance programme.
|
To arrange for any trip or
transportation to and 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 the event.
We
process special category personal data on the basis of the “special category reasons for processing of
your personal data” referred to in section 2 above
|
To administer any drug and alcohol
testing
|
Health and medical information
|
We
process special category personal data on the basis of the “special category reasons for processing of
your personal data” referred to in section 2 above
|
To use information about your
physical or mental health (including any injuries) or disability status, to
ensure your health and safety and to assess your fitness to participate, to
provide appropriate adjustments to our sports facilities and to monitor and
manage sickness absence
|
Health and medical information
|
We
process special category personal data on the basis of the “special category reasons for processing of
your personal data” referred to in section 2 above
|
To gather evidence for
possible grievance or disciplinary hearings
|
All the personal information we
collect including any disciplinary and grievance information.
|
We
have a legitimate interest in doing so to provide a safe and fair environment
for all members and to ensure the effective management of any disciplinary
hearings, appeals and adjudications.
We
process special category personal data on the basis of the “special category reasons for processing of
your personal data” referred to in section 2 above
For
criminal records history we process it on the basis of legal obligations or
based on your explicit consent.
|
To assess your eligibility
for and to provide any scholarship funding and/or grants
|
All details required for the purposes
of awarding scholarship funding or grants (including any means testing)
|
This
is necessary to enable us to properly administer and perform any contract for
the provision of funding.
|
For the purposes of equal
opportunities monitoring
|
Name, title, date of birth, gender, information
about your race or ethnicity, health and medical information and
performance data
|
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 processing of
your personal data” referred to in section 2 above
|
Coaches and officials
|
To administer your attendance at any
courses or programmes you sign up to
|
All contact and membership details, transaction
and payment data.
Details of your current affiliated
club or other, coaching/teaching qualifications and/or officiating history.
|
This
is necessary to enable us to register you on to and properly manage and
administer your development through the course and/or programme.
|
To conduct performance reviews,
managing performance and determining performance requirements
|
All performance and attendance data
and information about your health.
Details of your current affiliated
club or other, coaching/teaching qualifications and/or officiating history.
Qualification start & end dates.
|
This
is necessary to enable us to properly manage and administer your development
through the course and/or programme.
We
process special category personal data on the basis of the “special category reasons for processing of
your personal data” referred to in section 2 above
|
To make decisions about your
progression and accreditation status
|
As above.
|
As
above.
|
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.
|
To administer any drug and alcohol
testing
|
Health information
|
We
have a legal obligation and a legitimate interest to provide you &other
members of our 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 processing of
your personal data” referred to in section 2 above.
|
To arrange for any trip or
transportation to and 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 the event.
We
process special category personal data on the basis of the “special category reasons for processing of
your personal data” referred to in section 2 above
|
|
|
|
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 position as
a member. For other personal information
you may not be under an obligation to provide it to us, but if you do not
provide it then we may not be able to properly perform our contract with you.
Where you have given us your consent to use your personal
information in a particular manner, you have the right to withdraw this consent
at any time, which you may do by contacting us as described in the "Contacting
us" section below.
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 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 provide certain member benefits to you.
5.
DIRECT MARKETING
Email, post and SMS
marketing: from time to time, we may contact you by email, post or SMS with
information about products and services we believe you may be interested in.
We will only send marketing messages to you in accordance
with the marketing preferences you set. You can then let us know at any time
that you do not wish to receive marketing messages by [completing this form You
can also unsubscribe from our marketing by clicking on the unsubscribe link in
the marketing messages we send to you.
We share personal information with the following parties:
o
Any party
approved by you.
o
To any
governing bodies or regional bodies for the sports covered by our club: to
allow them to properly administer the sports on a local, regional and national
level.
o
The
Government or our regulators: where we are required to do so by law or to
assist with their investigations or initiatives.
o
Police,
law enforcement and security services: to assist with the investigation and
prevention of crime and the protection of national security.
We do not disclose personal information to anyone else
except as set out above.
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.]
[The
personal information we collect may be transferred to and stored in countries
outside of the UK and the European Union. Some of these jurisdictions require
different levels of protection in respect of personal information and, in
certain instances, the laws in those countries may be less protective than the
jurisdiction you are typically resident in. We will take all reasonable steps
to ensure that your personal information is only used in accordance with this
privacy notice and applicable 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 safeguards as required under data protection laws. For further details please contact us by
using the details set out in the "Contacting us" section below.]
8.
HOW LONG DO WE
KEEP PERSONAL INFORMATION FOR?
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 practice and regulatory requirements. Generally, where there is no legal
requirement we retain all physical and electronic records for a period of 6
years after your last contact with us.
Exceptions to this rule are:
o
CCTV records which are held for no more than 30 days unless we need to preserve the records
for the purpose of prevention and detection of crime;
o
Information that may be relevant to personal injury
claims, or discrimination claims may be retained until the limitation period
for those types of 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
you have worked for us.
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 may be able to update some of the personal information
we hold about you you can contact us using by using the details
set out in the "Contacting us"
section below.
9.
YOUR RIGHTS IN
RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal
information:
o
the right to be informed about how your personal
information is being used;
o
the right to access the personal information we
hold about you;
o
the right to request the correction of
inaccurate personal information we hold about you;
o
the right to request the erasure of your
personal information in certain limited circumstances;
o
the right to restrict processing of your
personal information where certain requirements are met;
o
the right to object to the processing of your
personal information;
o
the right to request that we transfer elements
of your data either to you or another service provider; and
o
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 of law. More information about your legal rights can be found on the
Information Commissioner’s website at
https://ico.org.uk/for-the-public/.
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 below.
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 complaint first.
10.
CHANGES TO THIS
NOTICE
We may update this privacy notice from time to time. When we
change this notice in a material way, 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.
In the event of any query or complaint in connection with
the information we hold about you, please email ibfbcsa@gmail.com or write to
us at 118 East street Sittingbourne ME10 4RX
May 2018