How and why we process your personal data
Our processing of personal data is proportionate and necessary for the provision of our services to members, to the procurement of goods and services from our suppliers, to the storage of business correspondence and technical information in relation to enquiries, and to the administration of membership accounts. We process only the minimum amount of personal data necessary in each case. We process no essentially sensitive private information.
We process personal data under three lawful bases:
- Contract
Membership applications, administration and renewals
We will use the information that you provide to us to process your membership application and renew your application if appropriate. We will email you information about events, courses, our services and other items of interest, as part of your membership. You can opt out or unsubscribe from receiving this information if you wish. Our legal basis for using your personal information in this way is for the performance of a contract.
SWRC has certain obligations relating to the membership of the club, which requires us to process membership-related personal data and to transfer that data to British Riding Clubs (BRC) to enable the BRC Insurance to be in place for members. Our legal basis for sharing your personal information in this way is for the performance of a contract.
Events – Competitions and Clinics
If you register for one of our competitions or clinics, we will use your information provided to us to process your registration and enable you to attend the competition or clinic. This will include sharing some of your information with our volunteers that run the event or camps. It may also include collecting and sharing medical information with them if you choose to provide that to us. Our legal basis for using your personal information in this way is for the performance of a contract.
If you choose to provide us with your dietary requirements we may share them with third parties that we use to provide catering at our events.
Our legal basis for using your personal information in this way is for the performance of a contract.
- Legitimate Interests
We process your personal data under the lawful basis of our legitimate business interests in ways that would be reasonably expected by individuals who contact us in the interests of joining our riding club, entering our riding club events, or who are interested in offering their own goods and/or services to us.
Specifically, we hold a record of your name, address, telephone number and email as a minimum, and a note of your general area or areas of interest. These records are held in our databases (My Show Secretary, Membership Database).
- Consent
For individuals who choose to sign up to receive our email newsletter, we process your personal data under the lawful basis of consent.
The minimum information collected for the newsletter is your name and email (provided by you). Your consent for us to send you our newsletter can be withdrawn by you at any time by unsubscribing.
If you provide personal data to us on your own initiative, we will not use, process or forward these data beyond the extent that is admissible by law or to which you have given your consent. Beyond this, we shall pass on your data only if we are obligated to do so by official directives or court orders.
Any modification of our privacy policy shall be published on this website, you can at any time obtain information on what data we store and how we collect and use them.
How we obtain your personal data
Information provided by you
You provide us with personal data directly through contact with us by joining as a member or by booking into one of our events. This information includes name, address, email address, telephone number and emergency contacts, but the set of information collected varies with the circumstances.
We may also keep information contained in any correspondence you may have with us via email (including attached documents) or received from you by fax, post or other delivery mechanisms. We do not record telephone conversations, but may make a written note of the substantive points.
Sensitive Personal Information
We do not seek to collect sensitive personal information (i.e. information relating to race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual orientation or criminal records). We ask that you do not provide such information to us. We ask that you make the event organiser or trainer aware of any medical conditions you may have prior to taking part and ensure your emergency contact details are carried on your person.
How We Use Your Personal Data
We use your data to allow us to conduct a membership relationship with you. We protect your personal data according to BRC policies in a manner that is consistent with the requirements of the General Data Protection Regulation concerning data protection. The emphasis of these policies is to ensure that your data remains secure against loss or unauthorised access to the fullest reasonable extent possible within our organisation. Our use of your personal data is proportionate and has a minimal impact on your privacy.
Sharing Information
We do not sell or buy mailing lists. We keep information about you confidential and will disclose your information to third parties only:
- for delivery of goods and services (for example, providing your name and address to a courier company);
- where we are required by legal or crime prevention agencies, regulatory authorities or fraud prevention agencies for the purposes of fraud prevention and to comply with legal and regulatory issues and disclosures.
- Medical emergencies
How long do we keep information about you?
We keep information until you request its removal or we have had no contact with you for a period that we redefine from time to time but which may be up to 3 years. This takes into account our need to meet any legal, statutory and regulatory obligations. These reasons can vary depending on the type of information. Information which is no longer required will be disposed of.
Data Subject rights
Subject access requests
The General Data Protection Regulation grants you the right to access particular personal data that we hold about you via a subject access request. We shall respond within one month of receiving the request and will provide you with details of the personal data we hold about you, including the following:
- the source of the information;
- the purposes for processing the information;
- third parties with whom we are sharing the information.
Right to rectification
You have the right to obtain from us, without undue delay, the rectification of inaccurate personal data we hold concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure
You have the right to obtain from us the erasure of personal data concerning you without undue delay, except where your data has been processed under the lawful basis of "legal obligation" (this basis applies to employees only).
Right to restriction of processing
Subject to exemptions, you have the right to obtain from us restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by you and is restricted until the accuracy of the data has been verified;
- the processing is unlawful and you oppose the erasure of the personal data and instead request the restriction in its use;
- we no longer need the personal data for the purposes of processing, but it is required by you for the establishment, exercise or defence of legal claims;
- you have objected to processing of your personal data pending the verification of whether there are legitimate grounds for us to override these objections.
Notification obligation regarding rectification or erasure of personal data or restriction of processing
We shall communicate any rectification or erasure of personal data or restriction of processing as described above to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. We shall provide you with information about those recipients it you request it.
Right to object
Except where data is processed under the lawful basis of "legal obligation" or "consent", you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you unless this relates to processing that is necessary for the performance of a task carried out in the public interest or an exercise of official authority vested in us. We shall no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. If you object on the grounds of direct marketing, this overrides our legitimate interests and we shall stop processing as soon as your objection on these grounds is received.
Invoking your rights
If you would like to invoke any of the above data subject rights or have a complaint regarding the way in which SWRC is processing your date, please contact SWRC Chairman by email. If any complaint is not resolved to your satisfaction you are able to make a formal complaint to the Information Commissioner's Office (ICO), you can make contact using the details at ico.org.uk