Welcome to our privacy notice.
1. About us
The Greater Manchester Trust for Recreation operating as Boys and Girls Clubs of Greater Manchester (“BGCGM”) is a registered charity in England and Wales number 521234. We are a charitable trust.
Our mission statement is:
“Our aim is to deliver a year-round programme of recreational and educational opportunities to young people, volunteers and leaders within our affiliated clubs that encourages them to reach their full potential.”
BGCGM respects your privacy and is committed to protecting your personal data. This privacy notice lets you know how BGCGM collects and processes your personal data as part of its activities and tells you about your privacy rights and how the law protects you. It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using your data.
2. Contact Details
BGCGM is the controller and responsible for your personal data, except where we state otherwise. If you have any questions about this privacy notice or wish to exercise Your Rights (see Section 10) please contact our data privacy manager at:
Boys and Girls Clubs of Greater Manchester
Stockport Business & Innovation Centre
Office 317 Broadstone Mill
Stockport SK5 7DL
T: 0161 660 4091
3. Personal Information we may collect about You
Personal data or personal information is any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer the following information about you, whether you are an adult or a child:
- personal contact details such as your name, title, home address, email addresses and phone numbers
- date of birth/age
- your club or organisation address, email address, web site and phone number
- club or organisation membership information including your role
- coaching and any other qualifications
- details of any next of kin, family members and emergency contacts
- records of our contact with you or your contact with us such as telephone conversations, emails and other correspondence and of your instructions to us
- payment card details, bank account information and details of transactions with you
- details of your entry into and attendance at events and competitions including results, records and rankings relating to you
- for boxing competitions, your medical record card
- donation information
- images of children and individuals in video and/or photographic form
- your story for a case study
- your marketing preferences so that we know whether and how we should contact you
- technical data such as your IP address and other IT system identifying information
- identification documentation such as passports and driving licences
- details of your social media accounts
- usage data including information on how you use our web site, products and services.
- any other information you may provide to us or which is provided about you
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 data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate information about your use of our web site to calculate the percentage of users accessing a particular web site feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Category personal information: We may also collect, store and use the following more sensitive types of personal information:
- Information about your race, ethnicity and religion
- Information about your health and medical information
We may also collect, store and use information about criminal convictions and offences.
We don’t usually collect this type of information and will only do so when there is a clear and valid reason and when data protection laws allow it. Please see section 6 below.
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes for example if you change your email or phone number.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION: 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 (for example to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
4. How do we collect your personal information?
We collect information from:
You directly. For example when you fill out a form to attend one of our events or to enter a competition, receive training, make a donation, volunteer for us (including acting as a trustee) or by e-mail or phone.
Third Parties which might include:
- the club or organisation of which you are a member, for example when a club affiliation form or a form to hire one of our playing grounds is completed by someone else or when they provide competition or event participant information to us
- clubs that are affiliated to us
- the National Association of Boys and Girls Clubs (NABGC) and organisations affiliated to the NABGC
- those acting on your behalf such as your parent or guardian
- those providing technical, payment or delivery services to us; those providing fraud prevention services and criminal record checks such as DBS to us; analytics providers; advertising networks; search engine providers; and our charity partners
Where you give personal information to a third party you should check their privacy notice.
Publicly Available Sources such as the web sites of our affiliated clubs and those who use our facilities, Companies House and the Charity Commission web sites in order for us to better understand our affiliated clubs/organisations and those clubs/organisations that use our products/services.
Social Media The information we receive will depend on the privacy settings which you have set on social media such as Facebook and Twitter.
5. How we use your personal information
We use your personal data to:
- administer, manage and deal with your club’s affiliation and provide your club with the benefits of affiliation
- provide you with the services, products or information you ask for
- establish, manage and carry out a contract between us and you for example when you hire our football pitches
- administer, manage, run and enable your participation in our events, competitions, tournaments, training, coaching, recreational and educational opportunities
- administer, manage, run and enable your participation in NABGC competitions
- promote BGCGM and its activities
- deliver awards such as the Young Volunteer Awards
- maintain our records
- carry out research and analysis to understand how we can improve our products or services including seeking your views or comments
- notify you of changes to our services
- process your donation
- comply with grant and funding requirements
- verify your identity
- investigate and handle any complaints or queries received from you or others
- investigate and handle legal, compliance and regulatory issues.
- equal opportunities monitoring
- carry out background and DBS checks for safeguarding purposes
- send you communications which you have requested and may be of interest to you
- prevent and detect fraud or error
We will only use your personal information when the law allows us to. We will collect and use your personal information for one or more of the following reasons:
Consent Where you (or your parent/guardian) have provided specific consent to us to use your personal information in a certain way, such as to send you email or text direct marketing or to use your image.
Performance of a contract Where we are entering into a contract with you or performing our obligations under it, for example when you hire a football pitch from us or those under a contract with an affiliated club.
Legal obligation Where it is necessary so that we can comply with a legal obligation that we are subject to for example regarding people working with children to comply with our safeguarding requirements or where collection of the personal information is required or authorised by law.
Vital Interests Where it is necessary to protect life or health of you or another person for example to share your information with the emergency services if you become ill at one of our events
Legitimate Interests Where it is necessary to achieve ours or a third party’s legitimate interests. We consider our legitimate interests to be the running of BGCGM as a charity in pursuit of its charitable aims, for example:
- to administer and manage our relationship with you or your club or organisation
- to provide member services, including advice and guidance
- to administer and manage events and competitions
- responding to solicited enquiries
- charity governance including delivery of our charitable objectives, audit and reporting requirements
- sending direct marketing by post or phone
- to recruit volunteers and record and administer any volunteering arrangement
- to carry out research and analysis to improve our products/services/events/competitions
- to manage access to our premises and for security purposes
- to invite you to participate in surveys including seeking your views or comments on our products, services, events and activities
- to protect the security of our communications and other systems
- fraud prevention and the prevention or detection of crime
- for insurance purposes
- to process any donation
- record keeping and dealing with complaints
- to apply for, administer and manage grants and funding
- maintain communication suppression lists
- to process financial transactions and maintain financial controls and records
- to fulfil legal, regulatory and risk management obligations
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Special Category personal information: When we use sensitive personal information, such as information about your health, race, ethnicity or religion we require an additional legal basis to do so under data protection laws. We do so on the basis that the processing is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law in connection with employment, social security or social protection; reasons of substantial public interest, such as for equal opportunities monitoring or safeguarding of children and adults at risk; or based on your explicit consent. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else's vital interests) and you are not capable of giving your consent, or where you have already made the information public.
For volunteers (including prospective trustees) we may also collect information about criminal convictions and offences, in which case this is processed on the basis that it is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law or based on your consent.
Withdrawal of Consent: Where you have given us consent to use your personal information in a certain way you have the right to withdraw that consent at any time. If you withdraw your consent we may not be able to provide certain products or services to you. We will tell you if that is the case. For more information on your rights see the Your Rights section below.
Marketing: We may send you marketing communications by email, telephone and by post where we are permitted to do so by law. You can ask us to stop sending you marketing communications or update your choices on how you receive marketing information at any time by contacting us.
7. Disclosure of your Personal Information
We may share your personal data with third parties for the purposes set out in this notice, but we do not sell or rent your information to third parties. The third parties include:
- Our staff and volunteers, including our trustees
- Our affiliated clubs, for example when we run a competition or tournament
- NABGC and its affiliated organisations in connection with the running of NABGC competitions
- Third parties involved in hosting, organising or running competitions and events or delivering training
- Catering and venue providers to ensure dietary requirements are met and/or arranging accommodation
- Our suppliers, sub-contractors and service providers for example IT service providers and payment processors
- Our professional advisors including lawyers, bankers, accountants and insurers who provide us with their professional services
- government authorities and regulators (such as HMRC, the Charity Commission, police, Information Commissioner)
- Third parties who provide us with funding
- Third parties to whom we may choose to sell, transfer or merge parts of the Charity or its assets. Alternatively, we may seek to merge with another entity. If a change happens to BGCGM then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and permit them to process your personal information for specified purposes and in accordance with our instructions.
8. International Transfers
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.
- 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.
- 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.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. How long do we keep your personal information for?
We keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may keep your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data; see Your Rights below for further information.
Under certain circumstances, by law, you have the right to:
- Request access to your personal information. 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.
- 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 exercised your right to object to processing (see below).
- 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing 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 data 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.
In some cases these rights may not apply or be limited. Further information on these rights can be obtained from the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Please contact us if you wish to exercise any of these rights.
You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
You also have a right to make a complaint at any time to the ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
11. Data 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 data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12. Third Party Links
Our web site may include links to third party web sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party web sites and are not responsible for their privacy statements. We encourage you to read the privacy notices of every web site that you visit.
13. Changes to this Privacy Notice
This Privacy Notice may be updated from time to time. The date of the most recent version appears on the bottom of the page.
dated 26 June 2019