PRIVACY POLICY & General Data Protection Regulation (GDPR)

Kegworth Shooting Ground Ltd (“we” or “our” or “us”) want to make sure all the personal information we have collected about you, is safe and secure whether we collect it through our website at https://www.kegworth.co.uk (“Site”) or from other sources. This Policy set outs our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation. If you have any questions about this Policy or what we do with your personal information, email john@kegworth.co.uk for details
Privacy NOTICES
Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us or in providing services to our customers or just managing our relationship with you.
When we hold or use your personal information as a data controller (see below for a description of what this is) we will provide you with a privacy notice which sets out in detail what information we hold about you (such as your contact details, address, etc.), how your personal information may be used and the reasons for these uses, together with details of your rights .
Where we collect personal  information from you directly, we will provide this privacy notice at the time we collect the personal information from you.
We will only provide this privacy notice to you once, generally at the start of our relationship with you. However if the applicable privacy notice is updated substantially, then we may provide you with details of the updated version. You are encouraged to check back regularly for updates.
Copies of our current privacy notices can be found below:
Data Privacy Notice
Kegworth Shooting Ground Limited
PRIVACY NOTICE
We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your contact with us. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.

This notice applies to you if you are either:

1. an individual shooter/participant of Clay Pigeon Shooting who has registered his/her interest in participating in the sport competitively and/or whose details we have collected from the CPSA or other third-party referral;
2. a coach, technical official or referee who has registered for membership to find out more about the training courses and accreditation services we offer; or
3. a fan, participant or supporter of the Clay Pigeon Shooting who has contacted us to purchase any of our online merchandise and/or signed up to receive updates about upcoming events, offers and ways to get involved further with clay pigeon shooting.

References to we, our or us in this privacy notice are Kegworth Shooting Ground Ltd.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation.

Contact details are set out in the "Contacting us" section at the end of this privacy notice.

1. Personal Information we may collect from you

When you contact or visit us, you may provide us with or we may obtain personal information about you, such as information regarding your:

o personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers;
o date of birth;
o gender;
o membership details including start and end date;
o records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
o any credit/debit card and other payment details you provide so that we can receive payments from you and details of the financial transactions with you;
o use of and movements through our web site, user names and other IT system identifying information;
o CCTV footage and other information obtained through electronic means such as swipe card and key fob records;
o records of your attendance at any events or competitions hosted by us.
o images in video and/or photographic form and voice recordings; and
o your marketing preferences so that we know whether and how we should contact you.

Shooters/Participants
If you are a shooter/participant who has registered his/her interest in participating in the sport competitively, you may also provide us with or we may obtain the following additional personal information from you:
o identification documents such as membership cards;
o details of any club and/or county membership;
o details of family members and coaches;
o records and assessment of any shooter rankings, gradings or ratings, competition results, details regarding [events/matches/games] attended and performance o any disciplinary and grievance information;

Coaches and officials
If you have registered with us to receive more information about working for us, you may also provide us with or we may obtain the following additional personal information from you:
o any coaching code or official number;
o your current affiliated club or other organisation (if applicable);
o coaching/teaching qualification and/or officiating history and any shooter rating (if any);
o accreditation/qualification start and end date;
o identification documents such as passport, utility bills, identity cards, etc.; and

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:
o information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
We may not collect all of the above types of special category personal information about you. In relation to the special category personal data that we do process we do so on the basis that
o the processing is necessary for reasons of substantial public interest, on a lawful basis;
o it is necessary for the establishment, exercise or defence of legal claims;
o it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
o based on your explicit consent.
In the table below, we refer to these as the “special category reasons for processing of your personal data”.
We may also collect criminal records information from you. For criminal records history, we process it on the basis of legal obligations or based on your explicit consent.

3. WHERE WE COLLECT YOUR INFORMATION
We typically collect personal information about our members when you visit our web site or contact us in person or by phone / text or email. when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.
If you are a shooter/participant of clay pigeon shooting we also may collect personal information about you from The CPSA or other governing body or other organization you are affiliated with or from other referrals such as from coaches or talent scouts.
If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

4. Uses made of the information
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.
Purpose Personal information used Lawful basis
All Members
To administer any membership account(s) you have with us and managing our relationship with you, [including arranging for any insurance] and dealing with payments and any support, service or product enquiries made by you All contact and membership details, transaction and payment information, records of your interactions with us, and marketing preferences.
This is necessary to enable us to properly manage and administer your purchase contract with us.


To arrange and manage any contracts for the provision of any merchandise, products and/or services. All contact and membership details.
Transaction and payment information. This is necessary to enable us to properly administer and perform any contract for the provision of [merchandise/products/services].

To send you information which is included within your membership benefits package, including details about advanced ticket information, [your insurance], competitions and events, partner offers and discounts and any updates on clay pigeon shooting. All contact and membership details
This is necessary to enable us to properly manage and administer your membership contract with us.

To send you other marketing information we think you might find useful or which you have requested from us, including our newsletters, information about Membership, events, participation products and information about our commercial partners All contact and membership details and marketing preferences Where you have given us your explicit consent to do so.
To answer your queries or complaints Contact details and records of your interactions with us
We have a legitimate interest to provide complaint handling services to you in case there are any issues with your membership.

Retention of records All the personal information we collect We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your membership and in some cases, we may have legal or regulatory obligations to retain records.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
For criminal records history we process it on the basis of legal obligations or based on your explicit consent.
The security of our IT systems Your usage of our IT systems and online portals.
We have a legitimate interest to ensure that our IT systems are secure.
To conduct data analytics studies to better understand event attendance and trends within the sport Records of your attendance at any events or competitions hosted by us and member shooting grounds / clubs. We have a legitimate interest in doing so to ensure that our membership is targeted and relevant.
For the purposes of promoting the sport, our events and membership packages. Images in video and/or photographic form. Where you have given us your explicit consent to do so.
To comply with health and safety requirements Records of attendance We have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate in sport.
Shooters/participants
To conduct performance reviews, manage performance and determine performance requirements and administer your development and training requirements on any shooter pathway programme All performance and attendance data and information about your health and medical condition.

Details of any affiliated club and/or county membership.
This is necessary to enable us to properly manage and administer your development through the performance programme.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.

To administer and monitor your attendance at events and competitions All non-medical performance and attendance data.

Details of any affiliated club and/or county membership. This is necessary to enable us to register you on to and properly manage and administer your development through the performance programme.
To arrange for any trip or transportation to and from an event Identification documents, details of next of kin, family members and emergency contacts, transaction and payment information, health and medical information. This is necessary to enable us to make the necessary arrangements for the trip and/or transportation to the event.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To administer any drug and alcohol testing Health and medical information We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To use information about your physical or mental health (including any injuries) or disability status, to ensure your health and safety and to assess your fitness to participate, to provide appropriate adjustments to our sports facilities and to monitor and manage sickness absence Health and medical information We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To gather evidence for possible grievance or disciplinary hearings All the personal information we collect including any disciplinary and grievance information. We have a legitimate interest in doing so to provide a safe and fair environment for all members and to ensure the effective management of any disciplinary hearings, appeals and adjudications.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
For criminal records history we process it on the basis of legal obligations or based on your explicit consent.

For the purposes of equal opportunities monitoring Name, title, date of birth, gender, information about your race or ethnicity, health and medical information and
performance data We have a legitimate interest to promote a sports environment that is inclusive, fair and accessible.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
Coaches and officials
To administer your attendance at any courses or programmes you sign up to All contact and membership details, transaction and payment data.
Details of your current affiliated club or other, coaching/teaching qualifications and/or officiating history. This is necessary to enable us to register you on to and properly manage and administer your development through the course and/or programme.
To conduct performance reviews, managing performance and determining performance requirements All performance and attendance data and information about your health.

Details of your current affiliated club or other, coaching/teaching qualifications and/or officiating history.

Qualification start & end dates. This is necessary to enable us to properly manage and administer your development through the course and/or programme.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To make decisions about your progression and accreditation status As above. As above.
To comply with legal obligations, for example, regarding people working with children or vulnerable adults to comply with our safeguarding requirements Information about your criminal convictions and offences
For criminal records history we process it on the basis of legal obligations or based on your explicit consent.
To administer any drug and alcohol testing Health information We have a legal obligation and a legitimate interest to provide you &other members of our organisation with a safe environment in which to participate in sport.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To arrange for any trip or transportation to and from an event Identification documents, details of next of kin, family members and emergency contacts, transaction and payment information, health and medical information. This is necessary to enable us to make the necessary arrangements for the trip and/or transportation to the event.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to admit you as a member or we may not be able to properly perform our contract with you or comply with legal obligations and we may have to terminate your position as a member. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you.
Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contacting us" section below.
Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain member benefits to you.

5. DIRECT MARKETING
Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products and services we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages by visiting our membership portal or emailing us at john@kegworth.co.uk. You can also unsubscribe from our marketing by clicking on the unsubscribe link or STOP request in the marketing messages / text message we send to you.

6. Disclosure of your PERSONAL information
We share personal information with the following parties:
o Any party approved by you.
o To any governing bodies, regional / county bodies for the sports covered by our association: to allow them to properly administer the sport on a local, regional, national level and international level.
o Other service providers: for example, email marketing specialists, payment processors, data analysis, CCTV contractors, promotional advisors, contractors or suppliers and IT services (including support, development, CRM, website, video and teleconference services);
o Our supply chain partners & sub-contractors, such as couriers, import/export agents, shippers;
o Our Commercial Partners: for the purposes of providing you with information on any tickets, special offers, opportunities, products and services and other commercial benefits provided by our commercial partners where you have given your express for us to do so.
o The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
o Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
We do not disclose personal information to anyone else except as set out above.

7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY
The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws. For further details please contact us by using the details set out in the "Contacting us" section below.

8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?
The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 10 years after your last contact with us. Exceptions to this rule are:

o CCTV records which are held for no more than 31 days unless we need to preserve the records for the purpose of prevention and detection of crime;
o Information that may be relevant to personal injury claims, or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after you have worked for us.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address.

You will be able to update some of the personal information we hold about you through our membership portal. Alternatively, you can contact us using by using the details set out in the "Contacting us" section below.

9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal information:
o the right to be informed about how your personal information is being used;
o the right to access the personal information we hold about you;
o the right to request the correction of inaccurate personal information we hold about you;
o the right to request the erasure of your personal information in certain limited circumstances;
o the right to restrict processing of your personal information where certain requirements are met;
o the right to object to the processing of your personal information;
o the right to request that we transfer elements of your data either to you or another service provider; and
o the right to object to certain automated decision-making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below.
If you are unhappy with the way we are using your personal information, you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.


10. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.


11. CONTACTING US
In the event of any query or complaint in connection with the information we hold about you, please email info@cpsa.co.uk or write to us at Kegwoth Shooting Ground Ltd
by emailing John@kegworth.co.uk
Please note that it is possible for you to be covered by more than one privacy notice.

THE DIFFERENCE BETWEEN DATA CONTROLLERS/PROCESSORS
A data controller is a person who controls how personal information is processed and used. A data processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller.
This distinction is important. You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below to see what rights you have). These rights can generally only be exercised against a data controller of your information.
In most cases we will be a data controller of your personal information. In any case where we are not a data controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the data controller (i.e. the person who controls how we process the personal information). In these cases we will endeavour to inform you who is the data controller of your personal information so that you can direct any such requests to them.
Also it is only a data controller that will provide you with a privacy notice about your personal information, so where we process your personal information as a data controller we will provide you with a privacy notice. Where we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.

HOW DO WE USE YOUR PERSONAL information?
We will use your personal information as described in the privacy notice provided to you, but, for example, we may use your personal information to administer any account(s) you have with us or to send you information we think you might find useful, provided you have indicated that you are happy to be contacted for these purposes. To see how we use your personal information, please see our current privacy notices, which can be accessed below:
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Details of how we disclose your personal information are set out in the relevant privacy notice provided to you, but generally it is where we need to do so in order to run our organisation (e.g. where other people process information for us). In such circumstances, we will put in place arrangements to protect your personal information. Outside of that we do not disclose your personal information unless we are required to do so by law.
If we transfer personal information about you outside the European Economic Area (EEA), we will let you know and ensure that all reasonable security measures are taken and that any third party processers will be required to process the information in accordance with information protection laws and we will notify you in your privacy notice if we are the information controller.
We do not sell, trade or rent your personal information to others.
HOW LONG DO WE HOLD ON TO YOUR PERSONAL INFORMATION?
Further details of how long we hold onto your personal information for are set out in the relevant privacy notice provided to you, but we will only hold your information for as long as is necessary or where you ask us to delete records we may delete it earlier.
The duration for which we retain your personal information will differ depending on the type of information and the reason why it was collected. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.
what are Your rights?
Full details of your rights set out in the relevant privacy notice provided to you, but you are entitled by law to ask for a copy of your personal information at any time. You are also entitled to ask us to correct, delete or update your personal information, to send your personal information to you or another organisation and to object to automated decision making. Where you have given us your consent to use your personal information in a particular manner, you also have the right to withdraw this consent at any time.
To exercise any of your rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contact" section below. You can also unsubscribe from any direct marketing by clicking on the unsubscribe link in the marketing messages we send to you.
You should note that some of your rights may not apply as they have specific requirements and exemptions which apply to them and they may not also apply to personal information recorded and stored by us. However your right to withdraw consent or object to processing for direct marketing are absolute rights.
If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner’s Office or your local data protection regulator. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/. However, we are here to help and would encourage you to contact us to resolve your complaint first.
linking with third party sites
Our Site may, from time to time, contain links to and from the websites of our commercial partners, other regional bodies, advertisers and clubs. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.
In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
Security
We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information. We take information and system security very seriously indeed and we are Cyber Essentials certified.
Cookies
Certain parts of our Site use "cookies" to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store on your computer's hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited. The only personal information a cookie contains is information that you have personally supplied.
We use cookies on our Site to enable us to deliver content that is specific to your interests and gives us an idea of which parts of the Site you are visiting and to recognise you when you return to the Site. Reading cookies does not give us access to other information on your computer's hard-drive and our Site will not read cookies created by other websites that you have visited.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If, however, you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access the Site.
Please note providers of third party content may also use cookies over which we have no control.
Log Files
In common with most websites, our Site logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.
We may use this information to analyse trends, administer the Site, track your movement around the Site and gather broad demographic information.
Changes to this policy
Any changes we may make to this Policy in the future will be posted on our Site and, where appropriate, notified to you by e-mail. When we change this Policy in a material way, we will update the version date at the bottom of this page. Please check back frequently to see any updates or changes to this Policy and should you object to any alteration, please contact us as set out in the "Contact" section below.
Contact
In the event of any query or complaint in connection with the information we hold about you, please email john@kegworth.co.uk
Our Data Protection Compliance Manager is John Wroughton
Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

 

Kegworth Shooting Ground Ltd 2018