Data Protection Policy
1.0 Introduction
Purpose
RTK is committed to being transparent about how it collects and uses the personal data of its users, and to meeting its data protection obligations. This policy sets out RTK’s commitment to data protection, and individual rights and obligations in relation to personal data.
This policy applies to the personal data of our users.
Rachael Wolstencroft, is the person with responsibility for data protection compliance within the Company and can be contacted at info@redtigerkarateclub.co.uk with regards to questions about this policy, or requests for further information.
2.0 Definitions
"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.
3.0 Data protection principles
RTK processes personal data in accordance with the following data protection principles:
processes personal data lawfully, fairly and in a transparent manner.
collects personal data only for specified, explicit and legitimate purposes.
processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
keeps personal data only for the period necessary for processing.
adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
RTK tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.
Where RTK processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.
RTK will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.
RTK keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
4.0 Individual rights
As a data subject, individuals have a number of rights in relation to their personal data.
5.0 Subject access requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, RTK will tell him/her:
whether or not their data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
to whom their data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
for how long their personal data is stored (or how that period is decided);
their rights to rectification or erasure of data, or to restrict or object to processing;
their right to complain to the Information Commissioner if they think RTK has failed to comply with their data protection rights; and
whether or not RTK carries out automated decision-making and the logic involved in any such decision-making.
RTK will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless they agree otherwise.
To make a subject access request, the individual should send the request to info@redtigerkarateclub.co.uk. In some cases, RTK may need to ask for proof of identification before the request can be processed. RTK will inform the individual if it needs to verify their identity and the documents it requires.
RTK will normally respond to a request within a period of one month from the date it is received.
If a subject access request is manifestly unfounded or excessive, RTK is not obliged to comply with it. Alternatively, RTK can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request.
6.0 Other rights
Individuals have a number of other rights in relation to their personal data. They can require RTK to:
rectify inaccurate data;
stop processing or erase data that is no longer necessary for the purposes of processing;
stop processing or erase data if the individual's interests override RTK’s legitimate grounds for processing data
stop processing or erase data if processing is unlawful; and
stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override RTK’s legitimate grounds for processing data.
To ask RTK to take any of these steps, the individual should send the request to info@redtigerkarateclub.co.uk
7.0 Data security
RTK takes the security of personal data seriously. RTK has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.
Where RTK engages with 3rd parties to process personal data on its behalf, such parties (The English Karate Federation, Dojo Expert and Towergate Insurance) do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
8.0 Data breaches
If RTK discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. RTK will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
9.0 Individual responsibilities
Individuals are responsible for helping RTK keep their personal data up to date. Individuals should let RTK know if data provided changes, for example if an individual moves to a new house or there are changes in medical information such as asthma diagnosis/broken bones etc.
Individuals who have access to personal data are required:
to access only data that they have authority to access and only for authorised purposes;
not to disclose data except to individuals (whether inside or outside RTK) who have appropriate authorisation;
to keep data secure (for example by complying with rules on access to the club APP including password protection, and secure file storage and destruction);
not to remove personal data, or devices containing or that can be used to access personal data, from RTK’s APP without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
not to store personal data on local drives or on personal devices that are used for work purposes.
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under RTK’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
10.0 Training
RTK will provide training to all individuals working on our behalf about their data protection responsibilities.
Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.