In May 2018, the regulations surrounding how companies and organisations can hold your personal data changed. This Notice tells you how we handle your Personal Data and the rights you have, when we hold it. This Notice is intended to comply with the provisions of the General Data Protection Regulation EU 2016/679 (GDPR) which governs how Personal Data is processed within the European Economic Area (EEA).
We are always happy to explain anything which this Notice does not make clear to you.
Who are we?
We are Trans Can Sport, community project providing sports and fitness activities to a trans and non-binary people.
You will find our contact details at the end of this Notice.
We are the “data controller” for the purposes of GDPR. This means that we decide how your Personal Data is processed and for what purposes.
Your personal data – what is it?
Personal Data is data that relates to a living individual who can be identified from that data. An example of personal data in the context of Trans Can Sport could be your name, address or health information (where provided). We might be able to identify you from the data itself or by linking that data to other information we have access to. GDPR tells us how we must process your Personal Data.
How do we process your Personal Data?
We comply with our obligations under GDPR in the following ways:
We use your Personal Data for the following purposes:
What is the legal basis for processing your personal data?
Under the GDPR there are a number of permitted legal reasons that we can use (or ‘process’) your Personal Data. One of the legal reasons is called ‘legitimate interests’. Broadly speaking this means that we can process your personal information as long as it is solely for the successful operation of Trans Can Sport. Before doing this, we will consider and balance any potential impact on you and your rights.
For health data we rely on your express consent to process this.
Security of Data
Within Trans Can Sport, your Personal Data is stored on a membership system called myClubhouse. This system can only be accessed by a limited number of individuals who carry out specific roles within the club. Instructors also have limited access to your health data as they are responsible for your wellbeing during the activity. These individuals have signed a declaration that they will treat any Personal Data they see with confidentiality.
Sharing your personal data
Your Personal Data will be treated as strictly confidential. Personal Data will be shared only with organisations whose services are required in order to help us provide the services we offer our members. We use other companies to help us process your Personal Data so that we can offer you the best possible service. At Trans Can Sport the main third party we share your data with is MyClubhouse (the Trans Can Sport membership system provider).
We will only share your Personal Data with other third parties with your consent. These third parties, in turn, may rely on data processors to provide services that help them help us.
Some third parties we use may operate outside the EEA (Extended Economic Area). In these cases, we will make sure that we have robust contracts in place with those third parties and that adequate safeguards exist to protect and secure your Personal Data.
When you give your consent to our holding of your Personal data you agree to us sharing your Personal Data (including special categories of Personal Data – where we have your explicit consent) with third party processors and sub-processors located both inside and outside the EEA.
How long do we keep your Personal Data?
We keep your Personal Data for as long as you are a member of our organisation. We will keep your information for no longer than we reasonably need. We retain your information for up to seven years after you give it to us, unless you expressly request for us to remove it. This is so that we can support any legal/insurance claims or complaints, and to facilitate easy membership renewal.
Your rights and your Personal Data.
Unless we have an exemption under GDPR, you have the following rights with respect to your Personal Data:
Further processing
If we wish to use your Personal Data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use. We will do this before we start processing for the new use. We will set out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Contact Details
If you have a problem, complaint or, if there is something you don’t understand, please contact us first using the following email:
transcansport@gmail.com
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/cont... or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
All emails sent by the system contain a tracking pixel. This is used to track whether each email has been opened by the recipient, and when. This information can be viewed by those users of the system with permission to view email delivery reports. We do not display any information regarding the location of the recipient. Note that the tracking pixel is only activated if the recipient chooses to download images into their email client.
We, Trans Can Sport, make use of the myClubhouse software supplied by Simmetrics Ltd to process personal data we include on our myClubhouse website in accordance with our privacy policy set out above. Simmetrics Ltd processes your personal data on our behalf and they can only do so in accordance with our written instructions. You can find the details of our data processor’s privacy policy here: http://www.myclubhouse.co.uk/Home/PrivacyPolicy.