The GDPR sets out seven key principles:
Lawfulness, fairness and transparency
Integrity and confidentiality (security)
These principles lie at the heart of our approach to processing personal data. The General Data Protection Regulation (GDPR) and Data Protection Act 2018 (DPA 2018) regulate the “processing” of personal data in whatever format including students’ identifiable information. Processing refers to anything done with the information including its collection, use, disclosure and destruction. The DPA obliges organisations to inform the Information Commissioner that personal information is being processed and to provide data subjects with access to their personal information. The Act requires organisations to detail the purposes for which personal information is used (by data users), and use of data beyond that specified in the registration is unlawful. These notifications must be regularly reviewed and any changes made within 28 days of the date on which the entry became inaccurate or incomplete.
This notice explains why we ask for your personal information, how that information will be used and how we share your information. Information may be collected via a Membership form, by telephone, email, or Social Media. Information may be written (manual records), or held on a computer (electronic records). Please read the following carefully to understand how we will treat your personal information, as by using our services you are accepting and consenting to the practices described in this policy.
Why do we collect information from you
We need to collect and hold information about you, in order to:
● deliver Morpeth & Blyth Karate Clubs services
● contact you by post, email, telephone or otherwise
● understand your needs to provide the services that you request
● update our records
● ensure that we meet our legal obligations
We may not be able to provide you with a service unless we have enough information about you, or your permission to use that information.
What information can we collect from you
We may collect and process the following information about you.
Information you give us. You may give us information about yourself by filling in Membership forms or by corresponding with us by phone, email, social media or otherwise. This includes information you provide when you subscribe to and use our services etc.
We process information which may include:
● Personal details such as name, date of birth, address
● Contact details, including details of parents/guardian if applicable
● Visual images
● Incident and accident details
● Opinions of the data controller with regard to the data subject, for example grading results and feedback
The first principle requires we process all personal data lawfully, fairly and in a transparent manner. Processing is only lawful if we have a lawful basis under Article 6 for this type of data.
Our lawful basis for processing your personal data is that we have a legitimate interest and a contractual obligation to you as a member to provide the services you are registering for.
We also process sensitive classes of information that may include:
● Physical or mental health details
To process this special category data, we need to identify both a lawful basis for processing, Article 6, and a special category condition for processing in compliance with Article 9.
Any special category health data we hold on you is only processed for the purpose of passing health data to Instructors to allow the safe running of training sessions. Our lawful basis for processing your personal data is that we have a legitimate interest and a contractual obligation to provide you and other members of our organisation with a safe environment in which to participate in sport. We comply with Article 9(2a) of the GDPR in that we ask for explicit consent for the processing of this special category data on our application form.
In some circumstances we also process personal data that includes information relating to criminal convictions and offences. This also requires a higher level of protection.
To process data about criminal convictions, criminal offences or related security measures, we need both a lawful basis for processing, Article 6, and a separate condition for processing this data in compliance with Article 10.
For criminal records history, we process it on the basis of legal obligations and a legitimate interest, as teaching children is a regulated activity. We comply with Article 10 which says: “Processing of personal data relating to criminal convictions and offences or related security measures based on Article 6(1) shall be carried out only under the control of official authority or when the processing is authorised by Union or Member State law providing for appropriate safeguards for the rights and freedoms of data subjects.” This processing is necessary for the purposes of performing or exercising obligations or rights of the controller.
More information regarding criminal convictions can be found in the following document: Academy of Shotokan Karate Criminal Records and Disclosure & Barring Policy, Procedures and Practices
We also work closely with others and may receive information about you from them. These partners will include, but are not limited to, our Association, the Academy of Shotokan Karate.
How we use your information
By using our services you consent to our using your personal information (which may sometimes include sensitive personal information, i.e. medical information etc or criminal conviction information) that we collect from you, or from a third party, in accordance with this notice.
Information which you provide us with will be kept securely and will only be used for the purposes stated when the information is collected. For example:
● to progress the service you requested
● to allow us to be able to communicate and provide services appropriate
to your needs
● to ensure that we meet our legal obligations
● where necessary, to protect individuals from harm or injury
In order to provide you with a good service or investigate complaints, we may use and pass on the information we hold about you to other people and organisations that provide that service, for example we may communicate with the Academy of Shotokan Karate regarding your licence application/renewal or we may need to involve external organisations such as Insurance Companies regarding incidents. Information will only be shared with them if they have genuine need for it. These external professional organisations are obliged to keep your details secure, and use them only to fulfil your request or deliver our service. We are the controller of the information collected by us and we will only provide personal information to an external organisation or individual for the purposes set out above or in order to help prevent risk of harm to an individual, crime, including fraud, or if required to do so by law. The only exception to this would be in cases where there is a legal obligation to disclose, or where disclosing the information is necessary or in the public interest.
At no time will your information be passed to organisations or individuals external to us for marketing or sales purposes or for any commercial use without your prior express consent.
Information you give us during telephone calls may be processed. If this occurs, it would be to enable us to act upon your wishes or to investigate incidents or complaints.
If you email us we may keep a record of your contact, your email address and the content of the email for our record keeping and to enable us to act upon your wishes or to investigate incidents or complaints. However, this information will not be kept longer than necessary and in line with our data retention policies.
Facebook/Twitter – Direct Marketing
Morpeth & Blyth Karate Clubs do not engage in Direct Marketing and if they do, explicit consent will be sought. We have a Facebook page and a Twitter account. We advertise events such as courses and gradings on our Facebook and Twitter pages and on some occasions on our website. We also publish other information of interest to students such as grading and competition results. All members are free to join these pages. If you join one of the social media pages, please note that the provider of the social media platform(s) have their own privacy policies and that the clubs do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data on the club social media pages.
Our website morpethandblythkarateclubs.co.uk does not store or capture personal information when you access it as a visitor.
Our systems will only capture and record personal information if you:
● subscribe to or apply for services that require personal information
● contact us and leave your details for us to respond.
Our website uses cookie technology for analytical purposes, and to personalise the user experience of the site. A cookie is a string of information that is sent by a website and stored on your hard drive or temporarily in your device’s memory. This helps us to provide you with a good service when you browse our website and also allows us to improve our site. No personal information is collected this way. Please note that this notice only covers the Morpeth & Blyth Karate Clubs website maintained by us, and does not cover other websites linked from our site.
You can use your web browser to:
delete all cookies;
block all cookies;
allow all cookies;
block third-party cookies;
clear all cookies when you close the browser;
open a 'private browsing' / 'incognito' session, which allows you to browse the internet without storing local data; and
install add-ons and plug-ins to extend browser functionality.
Our website is hosted by Wix and the following link gives a detailed explanation about cookies and Wix websites.
Visual images of students are taken and used by Morpeth & Blyth Karate Clubs for various purposes, including but not limited to, marketing, advertising and sharing information about students’ achievements and grading results. Some of these may be posted to our Facebook page and/or Twitter account and/or website. They are deleted from personal devices used to take the image as soon as this occurs. All students can decline having their image taken or posted and students under 18 must have explicit parental/guardian signed consent for photo’s to be taken and published. Any requests for this data to be removed will be acted upon immediately. This does not include visual images posted on our social media platforms by students or others as this is entirely the individual’s choice and outside of Morpeth & Blyth Karate Clubs’ control.
How we will protect your information
Our aim is not to be intrusive, and we won't ask irrelevant or unnecessary questions. The information you provide will be subject to rigorous measures and procedures to make sure it can't be seen, accessed or disclosed to anyone who shouldn't see it.
Information Security and Transmission of Information
The following information gives further details regarding Information Governance, Data Protection, Information Security and Freedom of Information. These define our commitments and responsibilities to your privacy and cover a range of information and technology security areas. All Instructors who handle personal information must comply with this Policy at all times. We treat it as a disciplinary matter if they misuse or do not look after your personal information properly. We will not keep your information longer than it is needed or where the law states how long this should be kept. We will dispose of paper records and delete any electronic personal information in a secure way.
In order to ensure the confidentiality of identifiable information, systems and procedures are in place to control access to such information. Such controls are essential to ensure that only authorised persons have:
• physical access to computer hardware and equipment and access to computer system utilities capable of overriding system and access controls e.g. IT administrator rights.
• access to either electronic or paper records containing confidential information about individuals.
Personal information that Morpeth & Blyth Karate Clubs stores is generally provided in written format by students or family/guardians on the Application for Dojo Membership. As long as membership has not expired, these forms are taken to all karate sessions in case of emergencies. These, and all other paper-based confidential information, such as incident reports, are stored in locked premises when not in use and accessible only by authorised Instructors. All personal information must be stored securely and not left in view of others. No records are left unattended or in a manner where they may be seen by unauthorised persons.
A limited amount of the personal information that Morpeth & Blyth Karate Clubs have is stored on computer, mainly to maintain Membership Records. Computer systems are password protected and accessible only by authorised Instructors. The internet router has firewall protection and the computer systems have software, installed to protect against virus attacks and hacking into the computer. These systems are fully compliant with the General Data Protection Regulation 2018. No external device or equipment, including discs, USB drives and other data storage devices, are run on or connected to Morpeth & Blyth Karate Clubs’ systems without express permission of Morpeth & Blyth Karate Clubs. As we use cloud storage system on our computers, personal data information may be classed as being stored outside the European Economic Area. We use Knowhow Cloud storage system, which is fully GDPR compliant and appropriate measures are put in place to keep your Personal Data secure.
We will not keep your information longer than it is needed or where the law states how long this should be kept. We will keep your Personal Information for as long as we need it for the purposes set out above, so this period will vary depending on your interactions with us and the nature of the Personal Information. For example, we may keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim. Where we no longer have a need to keep your information, we delete or anonymise the relevant information. We will dispose of paper records and delete any electronic personal information in a secure way. Documents that are no longer required are shredded. Most information is deleted as soon as you are no longer a member of Morpeth and Blyth Karate Clubs.
Data Protection laws give you a number of rights, as follows:
1. To be informed why, where and how we use your information.
2. To ask for access to your information
3. To ask for information to be corrected if inaccurate or incomplete.
4. To ask for your information to be deleted or removed where there is no need for us to continue processing it.
5. To ask us to restrict the use of your information.
6. To ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information.
7. To object to how your information is used.
8. To challenge any decisions made without human intervention (automated decision making).
9. To lodge a complaint with the Information Commissioner’s Office whose contact details are below.
10. If our processing is based upon your consent, to withdraw your consent.
You have the right to ask us to stop using your personal data in relation to any of our services. However, this may cause delays or prevent us delivering a service to you. Where possible we will seek to comply with your request but we may be required to hold or process information to comply with a legal requirement. We aim to ensure that the information we hold about you is accurate and up to date. However, there may be situations where you find the information we hold is no longer accurate and you have the right to have this corrected. You also have the right to request a copy of the information that we hold about you (Subject Access Request).
If you would like to exercise the above rights or request a copy of some or all of your personal information, please contact:
Morpeth & Blyth Karate Clubs
Middle Newham Farm
TEL: 07950 627263
We will respond to a request promptly and in any event within 28 calendar days of receiving it. Please note that some types of personal data are exempt from the right of subject access and so cannot be obtained by making a subject access request. Please note that whilst the majority of requests will not incur a charge, a reasonable fee for administrative costs associated with the request may be charged if the request is ‘manifestly unfounded or excessive’.
You also have the right to complain to the Information Commissioner’s Office if you are unhappy with the way we process your data. Details can be found on the ICO website, or you may write to the ICO at the following address: Information Commissioner's Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number