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 relationship with us a volunteer. This notice applies to current and former volunteers and this notice is not a contract of employment or other contract to provide services. 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.

References to we, our or us in this privacy notice are to British Rowing Ltd (company number 1706271) and British Rowing Events Ltd (company number 79C283), registered address 6 Lower Mall, London W6 9DJ.

We have appointed a Data Protection Officer to oversee our compliance with data protection laws.

Contact details are set out in the “Contacting us” section at the end of this privacy notice.

1. Personal Information

When you sign up to become a volunteer with us, you may provide us with or we may obtain personal information about you, such as information regarding your:

• personal contact details such as name, title, addresses, telephone numbers, and personal email addresses and emergency contact details;
• date of birth;
• gender;
• details of family members and emergency contacts;
• bank account details for payment of any out of pocket expenses;
• records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
• records of your volunteering history;
• any identification documents;
• all information included as part of the volunteering application process;
• referee details and any references provided;
• performance including any feedback provided to us by yourself, members of staff or other third parties;
• the location in which you are volunteering;
• movements though CCTV footage and other information obtained through electronic means such as swipecard and key fob records;
• use of our information and communications systems, including the computers and fixed and mobile phones that we allow you to use, passwords, personal identification numbers, IP addresses, user names and other IT system identifying information;
• images in video and/or photographic form and voice recordings;
• your marketing preferences so that we know whether and how we should contact you;

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 race or ethnicity, religious beliefs and sexual orientation; and
• 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 information about you. In relation to the special category personal data that we do process we do so on the basis that:

• the processing is necessary for reasons of substantial public interest, on a lawful basis;
• it is necessary for the establishment, exercise or defence of legal claims;
• 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
• 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 volunteers through the application process directly from you. We may sometimes collect additional information from third parties including former clubs or other organisations you may have volunteered for or via background check agencies.  We will also collect additional personal information throughout the period of your volunteering for us and when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way

We also may collect personal information about you from any third party references you provide as part of the application process for becoming a volunteer or from any feedback provided to us about your performance as a volunteer.

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 your personal 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.

Non- ‘special categories’ of Personal Information

‘Special categories’ of Personal Information and Criminal Records

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 volunteer or we may not be able to properly perform our arrangements with you or comply with legal obligations and we may have to terminate your position as a volunteer.  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 arrangements with you as a volunteer.

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 benefits to you as a volunteer.

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 emailing us [email protected]. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.

6. Disclosure of your personal information

We share personal information with the following parties:

• Any party approved by you.
• Other service providers: for example, email marketing specialists, payment processors, data analysis, CCTV contractors and IT services (including CRM, website, video- and teleconference services);
• Our supply chain partners and sub-contractors, such as couriers, distributors, import/export agents, shippers;
• Our Commercial Partners: for the purposes of providing you with information on any tickets, special offers, opportunities, products and services and other commercial benefits provided by our commercial partners where you have given your express consent for us to do so;
• The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
• Providing references to future employers or organisations you may wish to volunteer for.
• Our affiliated clubs/competitions: for the purposes of providing you with information on any further volunteering opportunities where you have given your express consent to do so.

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 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 (if you are currently volunteering with us, this may be for 6 years after you last volunteered for us).  Exceptions to this rule are:

• CCTV records which are held for no more than 8 weeks unless we need to preserve the records for the purpose of prevention and detection of crime; and
• Information that may be relevant to personal injury claims may be retained until the limitation period for those types of claims has expired.  For personal injury claims this can be an extended period as the limitation period might not start to run until a long time after you have volunteered for us.

9. Your rights in relation to personal information

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict the processing of your personal information where certain requirements are met;
• the right to object to the processing of your personal information;
• the right to request that we transfer elements of your data either to you or another service provider; and
• 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.

11. Contacting us

In the event of any query or complaint in connection with the information we hold about you, please email the Company Secretary at [email protected] or write to us at The Chief Operating Officer, British Rowing, 6 Lower Mall, London W6 9DJ.

Version dated 16 May 2018