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 membership with us or through your interaction with our website – www.swanstrust.co.uk.
This notice applies to you if you have registered to become or are a member of our Trust or use our website. 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.
References to we, our or us in this privacy notice are to the Swansea City Supporters’ Trust.
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 appointed Data Protection Compliance Manager, Dave Dalton, has overall responsibility for data protection compliance in our organisation. Our contact details are set out in the Contacting Us section of this notice.
1. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
Depending on the type of membership you register for with us or how you interact with our website, you may initially provide us with or we may obtain personal information about you, such as information regarding your:
- personal contact details that allows us to contact you directly such as name, title, postal and email addresses and telephone numbers;
- date of birth;
- membership start and end date;
- records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
- details of the financial transactions with you, including any details you have provided as part of any standing order arrangement;
- use of and movements through any online portal we may provide, passwords, personal identification numbers, IP addresses, user names and other IT system identifying information;
- records of your attendance at any events hosted by us;
- images in video and/or photographic form and voice recordings of events;
- your marketing preferences so that we know whether and how we should contact you;
- any disciplinary and grievance information;
2. WHERE WE COLLECT YOUR INFORMATION
We typically collect personal information about our members when you apply to become a member of the Swansea City Supporters’ Trust, in person or online via www.swanstrust.co.uk. It may also be collected from members and non-members alike when you purchase any services or products we offer; when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.
When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.
These pieces of information are used to improve services for you through, for example:
- enabling a service to recognise your device so you don’t have to give the same information several times during one task;
- recognising that you may already have given a username and password so you don’t need to do it for every web page requested;
- measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast;
You can read about how to manage these small files yourself through information on the Information Commissioner’s Office (ICO) website.
The cookies used on our website have been categorised based on the categories found in the ICC UK Cookie guide.
A list of all the cookies used on our website by category is set out below.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. The data is aggregated and anonymised, which means we cannot identify you as an individual.
Google Analytics – _ga, _gid
To opt-out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). These Cookies will remain on your device until you choose to clear it. If you choose to do this, you will need to enter your details each time you visit the site.
Google – NID
These Cookies will collect information about your browsing habits and allow us to show you advertisements while you are browsing our site and other sites on the internet. These are tailored by Google to reflect your interests. They help improve the relevance of the adverts that you see.
Cookies set by Third Party sites
On some pages of our website, other organisations, such as Facebook or Twitter, may also set their own anonymous cookies. They do this to track the success of their application, or to customise the application for you. Because of how cookies work, our website cannot access these cookies, nor can the other organisation access the data in cookies we use on our website.
For example, when you share an article using a social-media sharing button (for example, Facebook) on our website, the social network that has created the button will record that you have done this.
We do not control the dissemination of these cookies. You should check the relevant third party website for more information about these.
Some emails we track at an individual level to understand whether the user has opened and clicked on the email. We use this information to understand open and click rates on our emails to try and improve them. If you want to be sure that none of your email activity is tracked then you should opt out of the Swansea City Supporters’ Trust emails by clicking the unsubscribe link at the bottom of one of these emails.
Links to other websites
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|
|To administer any membership you have with us and managing our relationship with 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 membership contract with us.|
|To send you information about the Trust and Club and any relevant updates of general interest||Contact and membership details and marketing preferences.||This is necessary to enable us to properly manage and administer your membership contract with us.|
|To send you other information we think you might find useful or which you have requested from us, including our newsletters and information about membership||Contact details and marketing preferences.||This is necessary to ensure you get the full benefit of your Trust membership.|
|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 or you approach us with an enquiry.|
|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 run our Trust and in some cases we may have legal or regulatory obligations to retain records.|
|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.||Records of your attendance at any events or competitions hosted by us.||We have a legitimate interest in doing so to ensure that our membership is targeted and relevant.|
|To gather evidence for possible grievance or disciplinary hearings||All the personal information we collect.||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.|
|For the purposes of promoting the Trust, our events and membership packages.||(i) Images in video and/or photographic form from Trust events.
(ii) Member Names.
|(i) Images will normally be without personal information, name etc. unless you have given us your explicit consent to do so.
(ii) Occasionally we may mention Trust members when joining the Trust, but they will be by first name only.
|To administer your attendance at any courses or programmes you sign up to. (possible future purpose)||All contact and membership details, transaction and payment data.||This is necessary to enable us to register you on to and properly manage and administer your attendance on the course and/or programme.|
|To arrange for any trip or transportation to and from an event (possible future purpose).||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 an event.|
|For the purposes of equal opportunities monitoring if considered necessary at some future point.||Name, title, date of birth, gender, information about your race or ethnicity and health and medical information||We have a legitimate interest to promote an environment that is inclusive, fair and accessible.|
For some of your personal information you may 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 membership. 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 of this notice.
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
We do not include information about products and services from third parties etc. in the information we send you without your consent.
6. DISCLOSURE OF YOUR PERSONAL INFORMATION
We share personal information with the following parties:
- Any party approved by you.
- Other service providers: for example, our payment processors and suppliers of our IT services (including database and website);
- The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
- Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY
The personal information we collect is not transferred to and stored in countries outside of the UK and the European Union.
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 two years after your last contact with us or end of your membership to allow us to provide reminder information in relation to your membership. Exceptions to this rule are:
- Information that may be relevant to personal injury 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 the event.
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(s) or email address. We are looking at the option of your being able to update some of the personal information we hold about you through a membership portal in the future. In the meantime you can contact us by using the details set out in the Contacting Us section of this notice.
9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal information:
- the right to be informed about how your personal information is being used;
- the right to access the personal information we hold about you;
- the right to request the correction of inaccurate personal information we hold about you;
- the right to request the erasure of your personal information in certain limited circumstances;
- the right to restrict processing of your personal information where certain requirements are met;
- the right to object to the processing of your personal information;
- the right to request that we transfer elements of your data either to you or another service provider; and
- 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 of this notice.
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 firstname.lastname@example.org or write to us at Swans Trust, Dynevor House, 5-6 De La Beche Street, Swansea, SA1 3HA.
Last Revised: 13 January 2021