Twirl Ireland Federation Privacy Policy
Who we are?
Twirl Ireland Federation (TIF), also known as Baton Twirling Sport Association of Ireland (BTSAI), is the National Governing Body for Baton Twirling in Ireland. Twirl Ireland Federation are committed to protecting and respecting your privacy rights and complying with our obligations under the General Data Protection Regulation.
Information that we collect
An indicative list of categories of data subjects and categories of personal data we collect is included below. The level and type of information is dependent on your engagement with Twirl Ireland Federation.
Description of the categories of data subjects;
· Designated staff of funding bodies
· Designated staff of affiliated organisations
· Coach education contacts
· Twirl Ireland Federation appointed officials
· Twirl Ireland Federation registered club directors
· Twirl Ireland Federation registered judges
· Prospective volunteers through a job application process
· Designated contacts for the National Trials Register
· Coaches and prospective coaches participating in Coach Education programmes through Sport Ireland Coaching or Twirl Ireland Federation
· General Public through
o General enquiries
· Freedom of Information requests
· Subject access requests
· Media queries
· Information provided when visiting our website
Europe is now covered by the world's strongest data protection rules. The mutually agreed General Data Protection Regulation (GDPR) came into force on 25th May 2018 and was designed to modernise laws that protect the personal information of individuals. This is a requirement for businesses and organisations to obtain consent to process data in some situations. When an organisation is relying on consent to lawfully use a person's information, they have to clearly explain that consent is being given. This information is required to fully identify and register athletes, coaches, club directors, judges & clerks, and volunteers. The association to use the information for the purposes of competition registration and membership application.
TIF receives and stores your information, including address, phone and email address as part of membership registration and competition entry when due, on a PC and on the cloud-based service Dropbox. We are of course committed to protecting all your information.
This information is stored digitally through password protection, with access only to individuals who require it for the essential running of the association and events. It is not shared with any third party or with other members without express consent. The only time these details may be shared would be in the case of an emergency during a TIF event, and your details need to be provided to associated services, or if Sport Ireland need to contact you with other sport/twirling related concerns. In the case that TIF is contacted for your club details, we will pass their details on to you instead to make contact.
As part of publicising the sport and TIF, images and information (not including contact details) is maintained by TIF, all athletes/participants/volunteers complete a media release form. You have the right to ask us to remove any information or images shared in PR or social media, which we will action within 24 hours of contact. Signage is also displayed around the venues to inform occupants of the use of video and photo on site.
We process categories of data relevant to the above reasons/purposes which may include:
Categories of personal data:
· Full Name
· Date of birth
· Address
· Phone number
· Class of membership
· Identifying photographs
· Name, address, email address and phone number of parent/guardian of member under 18
· Copy of passport for athletes, coaches, officials, volunteers travelling to international competitions.
Twirl Ireland Federation also process Special Category Data of personal data in the case below:
· Declaration to compete.
This information will not be provided to any third parties, however in the instance where the member decides to represent the association at an international event/competition, with the members consent the above information will be shared with the bodies listed below:
· International Baton Twirling Bodies
o NBTA
o WFNBTA
o WBTF
o IBTF
TIF will retain membership details for the duration of the individual’s membership. Should an individual’s membership lapse for 5 years, TIF will delete all membership records relating to that individual, including any levels and qualifications held by the individual. In relation to details required for international competition, this information will be deleted once processing is completed. TIF will retain all competition results for historical purposes. Results will be archived from the website after 10 years.
It is the right of our members at any stage to request access to the data we retain on them. Specifically the existence of the following:
· Right of access
· Right to rectification
· Right to erasure
· Right to restrict processing
· Right to data portability
· Right to object
A request for access to the data retained can be made via email to operations@twirlireland.com using the following subject and template
Subject: Data Access Request
Email Body:
Dear...
I wish to make an access request under Article 15 of the General Data Protection Regulation (GDPR) for a copy of any information you keep about me, on computer or in manual form in relation to...
As part of publicising the sport and TIF, images and information (not including contact details) is maintained by TIF, all athletes/participants/volunteers complete a media release form. Each individual has the right to ask TIF to remove any information or images shared in PR or social media, TIF will action the removal within 24 hours of contact. Signage is also displayed around the venues to inform occupants of the use of video and photo on site.
How we use your information
Twirl Ireland Federation process personal data in connection with our role as the National Governing Body tasked with the sustainable development of Baton Twirling in Ireland which includes:
· Organisational capability initiatives within the baton twirling sector
· Providing support to member clubs within the sector
· Providing support to high performance athletes
· Conducting and disseminating research on baton twirling in Ireland
· Delivery and effective administration of an Anti-Doping Testing Programme
· Promotion of good practice and awareness in the areas of ethics, anti-doping, outdoor recreation
· Supporting the development of Coaches in Ireland in conjunction with Sport Ireland
· Supporting sports participation initiatives
Sharing/Disclosing your Information
Where allowed by law, necessary, or required by law, illustrative examples of whom we share data with include:
· Twirl Ireland Federation
· Department of Transport, Tourism and Sport
· World Anti-Doping Agency
· International Baton Twirling Bodies
o NBTA
o WFNBTA
o WBTF
o IBTF
· Providers of goods and services
· Individuals providing support services within the sport
· Legal representatives
Twirl Ireland Federation notes that data sharing can bring large benefits in the efficient delivery of services, but it must be done in a way that respects the rights of individuals to have their personal data treated with care and not accessed or used without good reason. Data sharing must always be necessary, proportionate and have a clear purpose.
Twirl Ireland Federation is subject to the Freedom of Information Act and any correspondence with Twirl Ireland Federation may be released in response to a Freedom of Information request.
International Transfers
Your personal information is processed and stored within the EU. However, if we are required to transfer your data to a destination outside of the European Economic Area (EEA), including to a jurisdiction where the level of protection afforded to personal data is not as high as that in the European Union, we will do so in compliance with the GDPR. This may include, for example, transfers to partner agencies or IT service providers.
If we transfer personal data to such jurisdictions, we will ensure that appropriate measures are in place to allow us to comply with our obligations under applicable law in respect of such transfers. Such measures may include entering into ‘standard contractual clauses’ in the form approved by the European Commission, or in respect of transfers to the USA, ensuring that the transfer is covered by the EU-US Privacy Shield Framework. If you would like to receive further details or a copy of the measures that we have taken in this regard, please contact us at operations@twirlireland.ie
Safeguarding and Security Measures
Twirl Ireland Federation takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. Twirl Ireland Federation only collects the minimum amount of information with a cognisance of the necessity and proportionality of any processing activity.
We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including measures including but not limited to:
· Access Controls
· Encryption
· Multi-Factor Authentication
· Appointment of a Data Protection Officer
· Robust security updates including patching and anti-virus software
· Business continuity planning – including backups
· Data Protection Impact Assessments
· Contractual obligations re. Data Protection with Third Parties
· Local risk assessments
· Audits of the IT and data protection environment
· Physical Security
· Passwords
· Staff guidance
· Due diligence when selecting suppliers, contractors and in staff selection
How long we keep your data
All the personal data that we collect and hold is kept in accordance with our retention policy and retention schedule. This policy is guided by the legislative and regulatory frameworks we are subject to and helps us to ensure that we do not keep personal data for longer than is necessary for the purpose(s) it was collected for.
Cookies
A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly. For further information please refer to our Cookie Policy.
Data Subject Rights
You have several rights in relation to your personal data under applicable privacy and data protection law, which may be subject to certain limitations and restrictions. We will respond to any valid requests within one month, unless it is particularly complicated or you have made repeated requests in which case we will respond, at the latest, within three months. We will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. You will not be charged a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive, in which case we will charge a reasonable fee in the circumstances or refuse to act on the request.
If you wish to exercise any of these rights, please contact our Data Protection Officer. We may request proof of identification to verify your request.
Data Protection Officer
For further information about this privacy notice please contact our Data Protection Officer
Data Protection Officer
Twirl Ireland Federation
8 Broadfield View
Rathcoole
D24 EK59
Supervisory Authority
If you are not satisfied by our efforts to resolve your concerns, feel free to contact the Irish Data Protection Commission. Their contact details are:
Postal Address:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Offices:
Dublin Office
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland.
Portarlington Office
Canal House,
Station Road,
Portarlington,
R32 AP23
Co. Laois,
Ireland.
Telephone: +353 01 7650100
1800437 737
How to contact us | Data Protection Commissioner
https://www.dataprotection.ie/en/contact/how-contact-us
Engaging with the DPC
The most effective and efficient way to contact the DPC regarding queries or complaints is by means of the webforms.
If you have a query, concern or complaint regarding a data protection matter, you can engage with the Data Protection Commission in the following ways:
· By webform on their website;
· By post.