Privacy Policy

Welsh Karate Union Privacy Policy

Amended 20/06/2018

 

1.           Introduction

1.1.       We are committed to safeguarding the privacy of our coaches, athletes and website visitors and will only use your personal information to provide services as requested from us, in accordance with contractual or legal obligations, or where legitimate interests apply.

1.2.       In this policy, “we”, “us” and “our” refers to the Welsh Karate Union (WKU) and the clubs that fall under its jurisdiction.

1.3.       This policy applies where we are acting as a data controller and where officials and/or coaches’ duties constitute that of a data processor.

1.4.       In accordance with Article 4 of the General Data Protection Regulation (GDPR) the following definitions are applicable:

1.4.1.1.          ‘personal data’ means any information relating to an identified or identifiable person who can be identified through this information;

1.4.1.2.          ‘special category data’ means any information considered more sensitive than general personal data and is subject to an additional condition for lawful processing;

1.4.1.3.          ‘processing’ means any action or set of actions which is performed on personal data, including, but not limited to, collection, recording, organising, structuring and storing of data;

1.4.1.4.          ‘data controller’ refers to the person or persons who, alone or jointly, determines the means and purposes of the processing of personal data;

1.4.1.5.          ‘data processor’ refers to the person or persons who process personal data on behalf of the controller.

 

2.           Information We Collect

 

2.1.       Information we collect is provided voluntarily when a coach. athlete or organisation enters a relationship with us. The information we collect may include, but not be limited to, name, address, date of birth, gender, contact details (e.g. phone number and/or email address) and medical information.

2.2.       Some data is collected automatically during the execution of ICT services (website; office network) such as IP address, cookies, device ID and activities within these systems. This data may be stored in databases owned and maintained by service providers. The services providers may use such information to track, for example, the total number of visitors to our website or social media pages.

2.3.       Special category data in the form of medical requirements and fitness/health data is collected through consent.

 

 

3.           How We Use Your Information

 

3.1.       We use the information you provide to administer membership, and provide the membership services you are signing up to when you register with a club. We have a contractual obligation to provide services our coaches and athletes have registered for. Reasons we will need to process your data include:

 

3.2.       Training and Competition Entry:

3.2.1.   Sharing personal data with the club coaches or officials to safely administer training sessions;

3.2.2.   Sharing personal data with club/WKU team managers to enter events;

3.2.3.   Sharing personal data (which may include special category data) with competition organisers for entry into events

 

3.3.       Funding and Reporting:

3.3.1.   We may share anonymised data with a funding body as a condition of grant funding e.g. Local Authorities;

3.3.2.   Analysing data to monitor club trends to facilitate development of the WKU and clubs, our practices, and policies;

3.3.3.   We are occasionally asked to conduct official surveys by sporting bodies, NGOs and government organisations. In these circumstances we are only requested to provide anonymised data.

 

3.4.       Membership and Club Management:

3.4.1.   Data will be collected through membership and insurance forms to allow processing of payment;

3.4.2.   Data may be shared with WKU officials and club instructors to provide information about club activities, membership renewals or invitations to social events.

3.4.3.   Information you provide may be passed on to third party affiliates where there is a legitimate or legal reason for doing so; such as insurance providers, our affiliated NGB, or competition organisers.

 

3.5.       Marketing, Communications and Social Media:

3.5.1.   Official correspondence from the Welsh Karate Union are typically to be communicated to officials and club instructors whereupon they will disseminate this information to their club members. However, we may occasionally require direct contact with our members where face-to-face communication has not been possible, for example, in the case of a prolonged absence from training. This will be conducted through phone, email or letter.

3.5.2.   While we do not currently send any marketing communications, any future marketing communication will contain an easy “unsubscribe” option to opt-out of receiving future marketing communications. Additionally, if at any time you wish not to receive any future marketing communications or wish to be deleted from our mailing lists, please contact us as detailed below.

3.5.3.   Photography and video of our members may be used for the promotion of karate and the WKU through leaflets, brochures, website and social media articles amongst others. These will only be used with the informed consent of members sought during application to the WKU.

3.5.4.   The WKU and individual clubs operate social media pages including, but not limited to, Facebook, Instagram, WhatsApp and Twitter. All members are free to join these pages; however, they must be made aware that the provider of these social media platforms have their own privacy policies and that the WKU does not accept any responsibility or liability for these policies. Members should check these policies before submitting any personal data on our official social media pages.

 

4.           Our Legal Basis for Processing Personal Data

 

4.1.       In accordance with Article 6 of the GDPR, we have audited our data and ensured each category of data complies with a lawful reason for processing. Our legal grounds are as follows:

4.1.1.   Contractual Requirements: Much of our processing of personal data is to meet our contractual obligation to coaches and athletes. For example, to conduct karate with best practice all our members are required to be insured before they may participate.

4.1.2.   Legitimate Interests: Under several circumstances we process personal data on the condition that is furthers our legitimate interests, or those of the individual in question, so long as they do not override the fundamental rights and freedoms of the affected individual. These include:

§  Providing a safe training environment;

§  Providing officials and coaches with resources to aid execution of their responsibilities; such as when teaching as a guest in another dojo;

§  Offering members and their families the opportunity to participate in social events;

§  Providing optional services to a member (e.g. courses and qualifications);

§  Marketing communications (on the condition that there is always a clear “unsubscribe” option within each communiqué);

§  Analysing and improving our professional practices;

§  Managing legal issues.

4.1.3.   Legal Obligation: We are required to collect, process and disclose personal data in certain ways to meet our legal obligations (e.g. pensions, planning applications).

4.1.4.   Protection of Vital Interests: We may collect or share personal data where it may be required to save someone’s life, such as in the case of a medical emergency.

4.1.5.   Consent: When required by law, and where no other legal basis applies, we will handle personal data only by consent of the individual. For example, we request consent from students (or parents/legal guardians) to permit the use of photography and videos that may be used to promote the WKU or karate.

4.2.       We will only collect and process special category data if an additional condition for processing is valid as per Article 9 of the GDPR. For more information on these conditions see Article 9(2) of the GDPR.

 

5.           Where Data is Stored and Processed

5.1.       As a United Kingdom based organisation we have ensured that our data storage is located within the United Kingdom or the European Union, or, where the service is provided by a third party such as our website host), that they are or will be compliant with GDPR on or before 25^th May 2018. 

 

6.           Security and Retention

6.1.       As detailed in Article 32 of the GDPR, we have taken appropriate and reasonable technical and organisational measures to ensure a level of security appropriate to the risk of personal data. These include such measures as:

6.1.1.   Restricted access to ICT systems;

6.1.2.   Physical records containing personal data are kept secure by club instructors and access is limited to only those requiring it for the safe delivery of karate or in the event of an emergency;

6.1.3.   Access to personal data is restricted to certain officials and club coaches by organisational structure (e.g. Club Instructors, Assistant Instructors, Treasurer, Licensing Officer etc.);

6.2.       Users who may be required to act as a data processor for confidential information (such as club instructors) are required to adhere to a Confidentiality Agreement.

6.3.       We will hold your personal data on file for as long as you are a member with us. Athlete data is updated every year on annual membership forms. Any personal data we hold on you will be securely destroyed after four years of inactivity on that member’s account. Your data is not processed for any further purposes other than those detailed in this policy.

 

7.           Your Rights

Chapter 3 of the GDPR provides the following rights for individuals:

·         The right to be informed;

·         The right of access;

·         The right to rectification;

·         The right to erasure;

·         The right to restrict processing;

·         The right to data portability;

·         The right to object;

·         Rights in relation to automated decision making and profiling.

 

7.1.       Please be aware that depending on the legal basis for the processing of the personal data, not all rights will apply. For example, if the legal basis is a legal obligation an individual will not have the right to erasure, the right to portability, nor the right to object. 

7.2.       As a data subject you are not obliged to share your personal data with the WKU. If you choose not to share your personal data with us we may not be able to register or administer your membership, ultimately preventing participation within our activities.

 

8.           Website Privacy Policy

 

8.1.       How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

9.           Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

 

10.        Contact Us

Please feel free to contact us if you any questions about this Privacy Policy or of the information practices of company. You can contact us at: This email address is being protected from spambots. You need JavaScript enabled to view it.

This policy has been endorsed by the Welsh Karate Union instructors and officers. The policy was approved on 20/06/2018, following a policy review consultation with senior committee members.

Overall responsibility for the effectiveness of the policy lies with Paul Watson (Chief Instructor).  For more information, please contact this person on t. 07786 933165