Data Protection
This policy describes how we collect and use your personal data during your use of the Koushinkan Aikido Oxford website (www.aikidooxford.co.uk) (the ‘website’) in accordance with the General Data Protection Regulation (GDPR) and related UK data protection legislation.
A) Who is using your personal data?
The Koushinkan Aikido Oxford is the “data controller” for the information that we collect when you visit the website. This means that we decide how to use it and are responsible for looking after it in accordance with the GDPR.
Access to your personal data within Koushinkan Aikido Oxford will be provided to those staff who need to view it as part of their work in connection with the operation of the website. It will also be shared with the third parties described in Section E.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We may update this policy at any time.
B) Glossary
Where we refer in this policy to your ‘personal data’, we mean any recorded information that is about you and from which you can be identified. It does not include data where your identity has been removed (anonymous data).
Where we refer to the ‘processing’ of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure, deletion or retention.
C) Types of data we collect about you
We will automatically collect, store, and use the following categories of data when you browse and search our site, if you have consented to our use of cookies:
– technical information, for example, the type of device (and its unique device identifier) you use to access our site, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform; and
– information about your visit to our site including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
D) How we use your data
We process your data for purposes arising from your use of the website, for example, to ensure that we understand who uses our site and how our site is used and to improve our site and ensure it is secure. This processing occurs because it is necessary to meet our legitimate interests in operating and improving the website, analysing its use, and ensuring its security.
We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.
E) Sharing your data with third parties
We may share your data with third parties who provide services on our behalf, such as those who help us to operate the website. All our third-party service providers are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.
We may also share your personal data with third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our site terms of use or to protect the rights, property or safety of our site, our users, and others.
Where your data is shared with third parties, we will seek to share the minimum amount necessary.
F) Where we store or use your data
We may store data collected by the website manually or electronically. The data is stored on our secure servers and/or in our premises within the UK.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to the website and any transmission is at your own risk.
G) Third party websites
Our site contains links to and from various third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
H) Retaining your data
We will only retain your data for as long as we need it to fulfil our purposes, including any relating to legal, accounting, or reporting requirements.
I) Your rights
Under certain circumstances, by law you have the right to:
– Request access to your data (commonly known as a “subject access request”). This enables you to receive a copy of your data and to check that we are lawfully processing it.
– Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
– Request erasure of your data. This enables you to ask us to delete or remove your data under certain circumstances, for example, if you consider that there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing (see below).
– Object to processing of your data where we are relying on our legitimate interests (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.
– Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
– Request the transfer of your data to another party.
Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. Further information on your rights is available from the Information Commissioner’s Office (ICO).
If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, you should contact the club at fo@aikidooxford.co.uk. The same email address may be used to contact the club. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
If you remain dissatisfied, you have the right to lodge a complaint with the ICO at https://ico.org.uk/concerns/.
J) Cookies
Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.
K) Changes to this policy
Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.
L) Contact
If you wish to raise any queries or concerns about this privacy policy please contact info@aikidooxford.co.uk.
GDPR Compliance Statement
Introduction
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Our Commitment
Koushinkan Aikido Oxford (‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR, the UK’s Data Protection Bill and English DP law.
Koushinkan Aikido Oxford are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Preparing for the GDPR
Koushinkan Aikido Oxford already have a consistent level of data protection and security across our organisation, however it is our aim to be as fully compliant with the GDPR by 25th May 2018 as possible. Our preparation includes: –
- Information Audit – carrying out a club-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
- Policies & Procedures – implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
- Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy – we are revising our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent – we are revising our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information of an individual’s right to access any personal information that Koushinkan Aikido Oxford about them and to request information about: –
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
Koushinkan Aikido Oxford takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction.
GDPR Roles and Employees
Koushinkan Aikido Oxford have designated Richard Watts as our Appointed Person and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Koushinkan Aikido Oxford understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact Richard Watts, info@aikidooxford.co.uk.