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Privacy Policy

WSA – PRIVACY POLICY

OUR COMMITMENT

At Welsh Sports Association (WSA) we take protection of your personal information very seriously.   It is important to us that we are transparent to our members, prospective members, visitors to our website, our partners, suppliers and professional connections, regarding our collection and use of personal information.

In this privacy policy we tell you what information we collect, how we use this information and what your rights are in respect of your personal information whether you are a visitor to our website, contact us to enquire about membership or any training or other events we offer, become a member or partner organisation, provide services to us or whether you are a business connection.

WSA is a data controller and responsible for your personal data.  In this policy we may be referred to as “WSA”, “we”, “us” or “our”.

We have a trading subsidiary, Vibrant Nation Ltd with whom we may share your personal information from time to time in accordance with this policy.

When we talk about personal data or personal information we are only referring to information from which an individual person can be identified.  We are not referring to data where the identity has been anonymised.

Please read this policy carefully.  If you have any queries regarding its contents or any personal information we may hold relating to you then please do not hesitate to contact our appointed data protection manager [name] in one of the following ways:-

  • Email address:
  • Registered office:
  • Telephone number:

You have the right to make a complaint at any time to the Information Commissioner Office (ICO).  We would however like the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THIS POLICY

We keep our policy under regular review.

It is important that the personal information we hold about you is accurate and current.   If the personal information changes during our relationship with you or your organisation, please contact us so we may update the personal information.

 

INFORMATION WE COLLECT

We may collect, use, store and transfer different kinds of personal information  about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, passport number, national insurance number, employment position, qualifications.
  • Contact Data includes correspondence address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you, training and events you have attended or provided on WSA’s behalf.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

Our website and services are not intended for children and we do not knowingly collect information regarding children.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, attendance at a training course). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

 

HOW WE COLLECT YOUR INFORMATION

We may collect personal information in the following ways:

OUR WEBSITE

Our website enables you to contact us with an initial enquiry.  Where you use our ‘contact us’ facility we will ask you for your name, email address and a brief summary of your enquiry.

As you interact with our website, we may automatically collect Technical Data. We collect this personal information by using cookies and other similar technologies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

DIRECT CONTACT

You may give us Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:-

  • use the “contact us” facility on our website;
  • enquire about membership or the membership benefits and services offered by WSA;
  • apply for membership of WSA;
  • use any of the membership benefits and services;
  • contact us via our helpline;
  • if you attend a training or other event offered by WSA;
  • engage with us as a partner offering support/services to our members;
  • are engaged by WSA as a sub-contractor to deliver certain services, training or events offered by WSA from time to time;
  • provide feedback on the membership benefits and services we offer;
  • request marketing to be sent to you.
THIRD PARTIES

We may receive information about you from third parties e.g. from Sports Wales or other sporting organisations who are members of WSA.

We may obtain Technical Data from analytics providers such as Google based outside the EU.

We may further collect personal information about you from publicly available sources such as Companies House, the Electoral Role based inside the EU, or from web based search engines.

SOCIAL MEDIA

We may collect your personal information when you engage with us on social media.

 

HOW WE USE YOUR PERSONAL INFORMATION

We will use the personal information we collect for the following purposes:-

  • to reply to any general enquiry you make and to provide you with information regarding memberships, training or events offered or opportunities to work with WSA.
  • to provide the services and support offered by WSA.
  • to make a payment to you for services you have delivered on our behalf.
  • to manage our relationship with you.
  • to comply with our legal and regulatory obligations.
  • to introduce you to or engage the services of third party service providers.
  • to deal with any feedback or complaint you may make.
  • to administer, develop and improve our business.
  • to protect our business e.g. should it be necessary to commence debt recovery actions or defend any legal claim.
  • to make suggestions and recommendations to you about the services we, and other members of our group, offer which may be of interest to you.
  • to invite you to any training or events we may hold or of which we may be a party which may be of interest to you.
  • to facilitate an introduction to a business connection where you or your organisation requires the services of the relevant business connection.
  • to engage with you as a partner organisation.

We must have a lawful reason for processing your personal information. Most commonly, we will use your personal information in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you.
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • where we need to comply with a legal or regulatory obligation.
  • where you have given your consent to process your personal information.

Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
When you contact us with an enquiry regarding membership or any of the services/support we offer (a) Identity

(b) Contact

(a) Necessary for our legitimate interests
To register your organisation as a member (a) Identity

(b) Contact

(a) Performance of a contract
To process your membership , provide membership benefits, services and support including:

(a) Updating your organisation details

(b) Manage payments, fees and charges

(c) Collect and recover money owed to us

(d) to send you our newsletter which will keep you up to date regarding issues and matters affecting your sector.

(a) Identity

(b) Contact

(c) Financial

(d)Transaction

(e) Marketing and Communications

(a) Performance of a contract

(b) Necessary for our legitimate interests (to recover debts due to us)

If you are a non-member to process your order to attend a training or other event (a) Identity

(b) Contact

(c) Financial

(d)Transaction

(e) Marketing and Communications

(a) Performance of a contract (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how members use their membership and the support and services offered as part of the membership)

To engage you as a sub-contractor (a) Identity

(b) Contact

(c) Financial

 

(a) Performance of a contract (b) Necessary for our legitimate interests
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how members use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, member relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests
To make suggestions and recommendations to you about membership benefits and services offered by WSA and its group companies that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)
Engage with you as a partner organisation (a)           Identity

(b)           Contact

(a)  Performance of a contract (b) Necessary for our legitimate interests

 

CHANGE OF PURPOSE

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

MARKETING

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.  We will get your express opt-in consent before we contact you for marketing purposes.

You can ask us to stop sending you marketing messages at any time by contacting us by one of the contact methods stated above or by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of the provision of services, your service experience or the historic supply of services.

 

SHARING YOUR PERSONAL INFORMATION

We will share your personal information with our trading arm, Vibrant Nation Ltd to help Vibrant Nation determine whether it can provide you with certain services or to facilitate the delivery of such services to you.   Vibrant Nation Ltd has its own privacy policy at [insert link].

We may also need to share your personal information with:-

  • third party service providers who deliver certain services offered as part of our membership benefits
  • to those third party suppliers who provide administrative and support services to us e.g. Sports Wales,.
  • our professional advisers including lawyers, insurers, and accountants.
  • HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as is set out in this policy.

We require all external third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our external third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

 

INTERNATIONAL TRANSFERS

Certain of our third party suppliers e.g. Google are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

INFORMATION SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

INFORMATION RETENTION

How long will you use my personal information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We are required to retain certain information for a period of 7 years to ensure we can comply with evidential and regulatory requirements or for tax purposes.

If you contact us to enquire into membership or any training or other event we can provide but choose not to proceed we will delete your personal information within 6 months of your enquiry.

In some circumstances you can ask us to delete your information: see Request erasure below for further information.

In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal information (commonly known as a “information subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

if you wish to exercise any of the rights set out above, please contact us using the contact details stated above.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.