Privacy Statement

Privacy notice - Sport Pembrokeshire

This privacy notice covers how Pembrokeshire County Council (as a Data Controller) will collect, use and share your personal data for the purposes of Sport Pembrokeshire (Sports Development Service). We collect and use your personal information so that we can administer and provide you with effective and efficient Sports Development services.

Why we need your information (purpose of processing)

We collect and use your personal information so that we can:

• Successfully and efficiently provide you with experiences in a variety of venues and circumstances including in school, live-streamed sessions, extracurricular activities and events.
• To meet requirements of contracts linked to the purchase of equipment / resources from us.
• Utilise relevant material for marketing and or digital communication purposes.
• We may take photos and videos of you at our events and share these on our social media platforms such as Facebook, Twitter and Instagram to showcase the positive work we do in schools and community to support the well-being of people in Pembrokeshire. Some of these photos and videos may also be added to our promotional DVD, the footage of which will be shown to attendees at the annual Sport Pembrokeshire awards.

The information that you provide will be processed according to the the UK General Data Protection Regulations (UK GDPR), the Data Protection Act 2018, The Education Act 2002 and European Regulations 1303/2013 and 1304/2013.

We will also make any disclosures required by law and we may also share this information with other bodies responsible for detecting/preventing fraud/crime or auditing/administering public funds to ensure money is targeted and spent in the most appropriate and cost effective way. In order to achieve this, information will be shared with our Audit Service within Pembrokeshire County Council and with The Auditor General for Wales Audit Wales Privacy and Cookie Policy (opens in a new tab).

We will not make any disclosures to third parties for marketing purposes.

Your data will be secure and confidential at all times and we will only collect the personal information that is required to provide you with our service.

What personal data are being collected?

The categories of personal data being collected are:

• Contact Details (i.e. pupil names, parent / guardian details, addresses, phone numbers, email addresses)
• Pupil details (i.e. age, date of birth, school attended)
• Health or medical information
• Eligibility for Free School Meals
• Photo/Video of you taken at Sport Events
• During Live Streamed sessions your image may be recorded for safeguarding purposes

What is our legal basis for processing your personal data?

The UK General Data Protection Regulations (UK GDPR) requires specific conditions to be met to ensure that the processing of your personal data is lawful. These relevant conditions are below:

• Article 6 (1)(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose. This is in relation to any marketing and digital communications you receive from us.

• Article 6 (1)(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

• Article 6 (1)(e) Public task: the processing is necessary for you to perform a task in the public  interest or for your official functions, and the task or function has a clear basis in law. This is in relation to Cynydd Referrals.

• Article 6 (1)(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. This is in relation to photos and videos taken at events and the contact details held for Community Clubs.

Some types of personal data are more sensitive than others, and need more protection. This is classed as ‘special category data’ and could include information about your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and the processing of genetic or biometric data, health and sex life and sexual orientation.

We process this type of special category data as it is necessary for reasons of: 

• Article 9 (2)(g) Substantial public interest.

(The relevant Data Protection Act 2018 condition is – Schedule 1 Part 2: Equality of opportunity or treatment and Statutory and government purposes)

Who will we share your information with?

We may need to share your personal data with internal departments, other organisations and third parties, this will include:

• Bodies responsible for detecting/preventing fraud or auditing/administering public funds to ensure money is targeted and spent in the most appropriate and cost effective way.
• We will not make any disclosures to third parties for marketing purposes, unless you have consented otherwise.
• External tutor who delivers the Safeguarding course.  Deliverer shares the participant information with 'UK Coaching' (National Governing Body).

We use data processors (third parties) who provide services to us in terms of IT provision and disaster recovery. We have contracts in place with these data processors, and they cannot do anything with your personal information unless we have instructed them to do it. They will hold your data securely and your personal information will only be shared in accordance with UK GDPR. When it is necessary for your personal information to be transferred outside of the UK as part of these contracts, this will only be done in accordance with the UK GDPR.

Pembrokeshire County Council has a duty to protect the public fund it manages. Therefore, the information that you have provided to us may be used for the prevention and detection of fraud and for auditing purposes both internally and externally.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting CIFAS (opens in a new tab).

How long do we keep hold of your information?

Pembrokeshire County Council will only keep your information for as long as is necessary, we will retain the information provided to us for the duration of the individual's time at school.

• Named contact details for the Community Club are updated as and when changes occur.
• Details of the Community Club Representative on Safeguarding Courses are securely disposed of immediately after the course concludes.
• Cynydd referral records will be retained until we are advised by Welsh European Funding Office (WEFO) (or its successor body) that they can be securely destroyed. While the exact retention period cannot be confirmed, the WEFO Project Closure Guidance states that records must be kept until at least 2026.
• Work Experience records are held for length of placement.
• Sport Pembrokeshire awards details are retained for 10 years.
• Photographic and Video Footage from Events, Festivals, Training, and Awards are kept for 10 years.
• Contact and marketing data will be retained until consent is withdrawn or for a maximum of 10 years of inactivity, whichever occurs first.
• Photos and videos are kept for 7 years and then are deleted from our servers, but we may still use them in our publications / DVD’s after this time.

Your information will be securely disposed of once it is no longer required.

Your Rights

Under the General Data Protection Regulation 2016 and Data Protection Act 2018, you have rights as an individual including:

• The right to Rectification – you have the right to ask to have your information corrected.
• The right to Restrict processing may apply – you may request that we stop processing your personal data however, this may delay or prevent us delivering a service to you. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
• The right to Object – this is not an absolute right and will depend on the reason for processing your personal information.
• The right to Erasure - you may request that we erase your personal data however, this may delay or prevent us delivering a service, or continuing to deliver a service. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
• The right to Data portability – you have the right to request transfer of your information without determent.
• The right to not be subject to Automated decision making and profiling.
• The right of Access – you have the right to ask us for copies of your personal data. To make a request, please contact:

Access to Records

Pembrokeshire County Council

County Hall

Haverfordwest

SA61 1TP

Email: accesstorecords@pembrokeshire.gov.uk Telephone: 01437 775798

Complaints or queries

Pembrokeshire County Council endeavours to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this seriously. We encourage people to bring to our attention if they believe that our collection or use of information is unfair, misleading or inappropriate. 

This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below:

Data Protection Officer

Pembrokeshire County Council

County Hall

Haverfordwest

SA61 1TP

Email: dataprotection@pembrokeshire.gov.uk

Telephone: 01437 764551

If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office as the statutory body which oversees data protection law:

Information Commissioner’s Office – Wales

2nd Floor, Churchill House

Churchill Way

Cardiff

CF10 2HH

Email: wales@ico.org.uk

Telephone No: 0303 123 1113

Our contact details as Data Controller are:

Pembrokeshire County Council, County Hall, Haverfordwest, Pembrokeshire, SA61 1TP.

Telephone number: 01437 764551 or enquiries@pembrokeshire.gov.uk

Our Data Protection Officer’s information is detailed above in the complaints and queries section.

Changes to this privacy notice:

We keep our privacy notice under regular review.