This Policy is for Participants, Parents/Guardians and Volunteers
Excel Camps Ltd is the data controller and is committed to complying with our legal responsibilities under data protection law. We take your privacy seriously and will ensure your personal information is kept secure.
When we collect, use, share, retain or do anything else with your personal information (known collectively as ‘processing’) we are regulated under the General Data Protection Regulation (GDPR) and are responsible as ‘controller’ of your information.
This notice applies to you if you are:
• An existing or prospective participant of an Excel camp
• A person with parental responsibility for a participant
• An existing or prospective Excel Team volunteer or official
• A previous participant with a legitimate interest in the future services provided by Excel
We have a separate notice which provides privacy information relating to employees.
It is important that you read this carefully as it contains key information about how we use your personal data and your associated rights.
Information we collect about you
The categories of personal information we process includes:
• Contact details* (Participant, parent/guardian and emergency contacts)
• Date of birth* (Participant DOB is required by Excel, however the DOB of the account holder, usually the parent/guardian, is a requirement by the software management company Active. For information on why this is required you can contact Active via their website at www.activenetwork.com)
• Gymnast gender*
• Any relevant medical conditions and/or disabilities and additional support related information*
• Any individual risk assessments (participants and others if applicable)
• Details of any reasonable adjustments or steps taken to support your individual needs
• Participants attendance and achievement records
• Any communications from, to or relating to you
• Details relating to standards of conduct
• Any accident or incident reports including details of injuries*
• IP address, browser identifier and the time of access (if you use our website)
• Credit Card/Debit Card details (These details are encrypted and held securely)*
• Experience, qualifications, training and confirmation that you have completed a criminal record check (prospective or existing volunteers).
The information marked with an * above is essential for your child to be able to attend a holiday camp with Excel. It is your choice whether you provide all the information we have requested, however failure to provide the required information may affect our ability to meet you or your child’s needs and to protect their wellbeing.
Our purposes for processing information about you
We use the information we hold about you for a variety of purposes which are outlined below. Data protection law requires us to tell you what our legal reason is for each purpose.
When you ask us to provide you a service, such as a holiday camp, or you purchase a product from us, we usually need to use information about you to provide this product or service, for example:
• To contact you to confirm arrangements
• To notify you about changes to terms and conditions
• To process payments or send you receipts required
• To provide you with the benefits and services to which you have subscribed
We do so because it is necessary for the performance of a contract.
We have a duty of care to ensure it is safe for your child to take part in our holiday camps and to keep them safe while participating. Some individuals may be at risk of harm from participating in sporting activities as a result of a pre-existing condition. It is vital that you let us know if there is any reason why taking part in certain sports may be unsafe prior to participation. With your agreement, we will review any information you provide and undertake risk assessments in consultation with yourself and any appropriate trained professionals e.g. medical consultants. When we ask participants to provide relevant health information such as details of medical conditions, medication needs, allergies or injuries, this is because we have a legal obligation.
If you are selected for a role at Excel, we will usually obtain a reference from any appropriate organisation or individual you have nominated.
When you tell us about any special needs such as disabilities or other support information we may use relevant information to comply with our legal obligations under the Equality Act 2010. We will review any information you have provided to help us identify any actions we can take to support inclusion. We may need to ask you for more information to help us to best meet your child’s needs. We will keep a record of any steps we take to support inclusion.
If you are wishing to volunteer or work for us, depending on your role, we may need to ask you to complete a criminal record check (DBS) as we have a legal obligation to do so.
When we retain information about you, even after your child has participated in the camp, this is often because we are required to do so by law such as records we are required to keep for business and accounting purposes. Sometimes we are also legally obliged to share information about you with third parties. More information it provided below.
We rely on legitimate interests for the following purposes:
• Responding to communications, concerns or complaints and seeking feedback from you about our services
We will use the information you provide to respond to any comments or questions you raise and where appropriate to undertake investigations into any complaints or concerns. On occasion, we may contact you to seek your views on the services we provide.
• Holding emergency contact information
When you register for a camp we collect contact details. We also ask you to provide an emergency contact which we will only use in exceptional circumstances if we are unable to contact your primary contact e.g. a parent/guardian.
• Maintaining attendance registers and achievement records
For health and safety purposes and company records, we need to maintain a register of those in attendance at our holiday camps. On some of our Sport Specific Camps we may hold progress records, which enables us to provide an effective and progressive training program for each individual child.
• Collecting additional information to support a participant attending an off-site activity
Occasionally we may organise off-site activities to form part of the holiday camp day. If this was the case you would be made aware of this at the point of booking. In the event of off-site activities, we will need to collect additional information, that may vary dependent on the specific activities and whether they involve meals and travel.
• To monitor that you have completed any required safeguarding training and criminal record checks
If you undertake a role where a criminal record check (DBS) and safeguarding training are required, we will receive confirmation from the provider if your check is approved and that you have completed the required safeguarding training
• Filming for coaching purposes
On occasion, we may film participants e.g. during a camp for coaching purposes to help provide feedback to the participant. Videos taken at training sessions for individual coaching purposes will not be used for any other purpose without prior consent. Such videos would only be taken on Sport Specific Camps to help participants view their technique and understand where corrections need to be made
• Photography and filming during camps to promote Excel
We may take photos or videos on occasions to help promote Excel on our website, official social media pages and in communications. Any images of children will be published in line with our safeguarding policy
• Running and monitoring our club website and social media
We do not use any tracking or analytics on our website. Your IP address will be logged by our webserver but we would not be able to identify you from this information alone.
We have carried out a legitimate interest assessment (LIA) to ensure that the above processing is necessary and is carried out in a way that ensures a balance between the organisation’s interests and your individual interests, rights and freedoms with appropriate safeguards, especially to protect the interest of data subjects who are children. We can provide details of these assessments on request.
You have a right to object to the use of your information for any purposes we undertake based on legitimate interests. Further information is provided in the section below on individual rights.
We rely on consent in the following circumstances:
• To use your email or telephone numbers for marketing purposes
• To take photographs and videos for publication
When you have given us your consent for your personal information to be used for a particular purpose, you have the right to withdraw this consent at any time, which you may do by contacting us using the contact details below. Your withdrawal of consent will not affect any use of the data that was made before you withdrew your consent.
Special categories of personal data
Special categories of personal data are a category of information that is more sensitive and requires greater protection. Some of the information we process falls into this category (e.g. health/medical data or any information you provide to us about a disability or your religion, race or gender identity). It is unlawful for organisations to process this type of information unless an additional legal condition applies. We will only process this type of information if one of the following applies:
• You have given your explicit consent or have made this information public
• We are required to do so to establish, exercise or defend a legal claim
• We are required to do so to comply with employment or social security or social protection law
• There is a substantial public interest in doing so; or
• It is in your vital interests and you are unable to provide consent e.g. if you are unconscious or do not have sufficient mental capacity
With your consent, we will send you our newsletter and other information about our activities, services and products that we think might be of interest to you based on your age, interests and experience. You will receive this information by email. You can change your mind at any time, therefore if you no longer wish to receive information and deals relating to our products and service, simply click on the unsubscribe button on one of the emails, alternatively you can notify us by email: firstname.lastname@example.org and request that you wish to be removed from the mailing list.
Why we share information about you
We may be required to share your personal information in the following reasons:
• Complying with legal and/or regulatory responsibilities We may be required to share information with bodies such as Her Majesty’s Revenue & Customs (HMRC), Health & Safety Executive (HSE), Police and Information Commissioner’s Office (ICO). We may also share information with other organisations to safeguard children. Any information that is shared will be strictly limited to what is required to ensure children are protected from harm and will be carried out in accordance with the law and relevant government guidance
• Obtaining legal or professional advice
• Obtaining a service from a third party
All service providers are contractually required to ensure your information is secure and cannot use this information for their own purposes. Where we are required to share information with them to provide the service, we only disclose information that is strictly necessary to deliver the service.
Except for the above, will only share your information with any other third parties with your prior agreement.
Transfers of data out of the EEA
We may transfer your personal information to countries which are located outside the European Economic Area (EEA) for the follow purposes:
• To the United States in order to provide secure online storage. This service is provided by the Microsoft One Drive Cloud who are certified as adhering to the EUUS Privacy Shield. To view the Microsoft Privacy Statement Click Here
We will not transfer your information to any other country or organisation outside the EEA unless there is a European Commission adequacy decision for the specific country to which the data is transferred or where we can be certain that there are adequate safeguards provided for your information and individual rights standards that meet the GDPR requirements.
Please contact us using the contact details in this notice if you would like further information about why transfers to the above countries are permitted under GDPR.
You have important rights under data protection law. In summary these include:
• To be informed about how your information is processed (set out above)
• To access any personal data held about you
You have the right to access the personal information we hold about you. You can also request a copy of any information we hold by writing to us using the contact details below.
• To have your data rectified if it is inaccurate
If you think that any of the information we hold is inaccurate, you can ask that corrections are made. We will either make the requested amendments or provide an explanation as to why we are not making changes
• To have your data deleted (except if there is a valid lawful reason to retain it)
After you have attended a holiday camp with Excel, if you do not attend another camp within a 3 year period, we will delete any information you provided except for any financial/accounting records which need to be retained for six years in line with UK tax law. Additional information that has been provided solely for the purpose of participating in a specific activity will be deleted after the event
Video footage that has only been taken for coaching purposes will be retained only for as long as it is required for that purpose and in most cases, will be deleted within one month.
Photographs and other video footage captured for promotional purposes will be retained for up to 4 years old. After this time, they will be deleted unless we consider them to be of public interest and should consequently be archived for historical purposes. Where images have been published on social media, these platform providers may continue to process your data after the retention period has lapsed.
You have a right to request the deletion of your information in advance of the above retention periods. We will delete this information unless there is a lawful reason for the information to be retained
• To have your information restricted or blocked from processing
If you object to processing, we will restrict the processing of your information for the purpose to which you are objecting whilst we review your objection
• To object to:
– Any processing based on legitimate interests
The right to object is specific to the data subject’s particular situation. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing, which override your individual interests, rights and freedoms or we need to continue to process your information in connection with a legal claim. All objections must be made in writing by way of an email to email@example.com
– Your personal information being used for direct marketing activities
You can object to our direct marketing activities by unsubscribing from the relevant communication as described above in the marketing section of this notice.
To exercise any of your rights or if you have any questions about our privacy notice please contact Head Office.
Head Office Email: firstname.lastname@example.org
Head Office Phone: 01428 748615
While we hope to be able to resolve any concerns you have about the way that we are processing your personal data, you have the right to lodge a complaint with the Information Commissioners Office (ICO) if you believe your data has been processed in a way that does not comply with the GDPR or have any wider concerns about our compliance with data protection law. You can do so by calling the ICO helpline on 0303 123 1113 or via their website.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine reason to need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will inform you and the ICO of any personal data breaches in line with our legal obligations.
Cookies we collect:
Type of cookie
First or Third party
Can be blocked
Session or Persistent
APISID, CONSENT, GPS, LOGIN_INFO, PREF, SID, SSID, VISITOR_INFO1_LIVE, YSC
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