SAMA KARATE SOUTHWEST DATA PROTECTION POLICY

This policy sets out Sama Karate Southwest’s commitment to protecting personal data and how we implement that commitment with regards to the collection and use of personal data to meet our data protection standards and comply with the EU’s General Data Protection Regulation (GDPR) May 2018.

This policy applies to all Instructors, assistants and volunteers of Sama Karate Southwest.

It applies to all data that Sama Karate Southwest holds relating to identifiable individuals. This can include:

  • Names of individuals
  • Postal addresses
  • Email Addresses
  • Telephone number
  • Medical information

As responsible instructors we are committed to comply with the eight data protection principles as listed below in order to meet our legal obligations as laid down by the GDPR:

Ensuring that data is collected, processed and used fairly and lawfully.
Processing personal data only in order to meet our operational needs or fulfil legal requirements.
Ensuring that personal data collected is adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
Taking steps to ensure that personal data is up to date and accurate.
Establishing appropriate retention periods for personal data.
Ensuring that data subjects’ rights can be appropriately exercised.
Providing adequate security measures to protect personal data and taking organisational measures against unauthorised and unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
Ensuring personal data is not transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
In addition to the above Sama Karate Southwest ensures: the nominated officer responsible for data protection compliance provides a point of contact for all data protection issues.
All Instructors are made aware of good practice in data protection.

  • Provides adequate Instructor training for all staff responsible for personal data collection.
  • All instructors handling personal data know where to find further guidance if needed.
  • All queries about data protection, internal and external to the club, are dealt with effectively and promptly.
  • Regularly reviews data protection procedures and guidelines within the club.

This policy helps to protect Sama Karate Southwest from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the club uses data relating to them.
  • Reputational damage. For instance, the club could suffer if hackers successfully gained access to sensitive data.

Responsibilities:

Everyone who works with Sama Karate Southwest has responsibility for ensuring data is collected, sorted and handled appropriately.
Each Instructor/Assistant/Volunteer that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

Instructor guidelines:

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, Instructors can request it from the Database operator (Sensei D Drain).
  • Sama Karate Southwest will provide training, as and when required, to all Instructors to help them understand their responsibilities when handling data.
  • Instructors should keep all data secure, by taking sensible precautions and following the guidelines within this policy.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorised people, either within the club or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of appropriately.
  • Instructors should request help from the Data Protection Officer (Sensei D Drain) if they are unsure about any aspect of data protection.

Data Storage:

Paper – it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out. Data printouts should be shredded and disposed of securely when no longer required.
Electronically – it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
  • Data should be backed up frequently.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and firewall.

Data Use:

Personal data is of no value to Sama Karate Southwest or its Instructors unless the club can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, Instructors should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally.
  • Data must be encrypted before being transferred electronically.
  • Personal data should never be transferred outside the EEA.
  • Instructors should not save copies of personal data to their own computers. Only the central copy of data can be accessed.

Data Accuracy:

AThe law requires Sama Karate Southwest to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Sama Karate Southwest should put into ensuring its accuracy.
It is the responsibility of all Instructors who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Instructors should not create or store any unnecessary additional data sets.
  • Instructors should take every opportunity to ensure data is updated. For instance, their registers must contain up to date emergency contact numbers and medical details.
  • Sama Karate Southwest will make it easy for data subjects to update the information Sama Karate Southwest holds about them. For instance, via the membership and registration forms.
  • Data must be updated as inaccuracies are discovered. For instance, if a student can no longer be reached on their stored telephone number, it should be removed from the database.

Subject access requests:

All individuals who are the subject of personal data held by Sama Karate Southwest are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at info@sama-southwest.com . The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controller will aim to identify the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons:

In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Sama Karate Southwest will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from legal advisers where necessary.

Providing Information:

Sama Karate Southwest aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How data is being used.
  • How to exercise their rights.

To these ends, the club has a privacy statement, setting out how data relating to individuals is used by the club. This is available upon request.

Sama Karate Southwest Declaration:

All information provided to Sama Karate Southwest at the time of registering is held on a database and is used to communicate club information and register with F.E.K.O. (Federation of English Karate Organisations). By registering a membership with Sama Karate Southwest, these terms are agreed to. Sama Karate Southwest takes privacy very seriously and holds this information in accordance with the GDPR. We do not make the information contained in our database available to any third party organisations.

This policy was adopted by: Sama Karate Southwest
Date: 7th August 2018
To be reviewed: 7th August 2020
Data Officer: Debbie Drain