THE ISLAND TRUST LTD and ISLAND (CUTTER) LTD (the Company)
How we use your / your child’s information
When you / your child take part in a residential or day sail voyage, the Company needs to keep and process information about you / your child for normal procedural and health and safety purposes. The information we hold and process will be used for our management and administrative use only. The information we hold will have been provided by you. We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately. This includes using information to enable us to comply with the voyage contract, to comply with any legal requirements and regulations, pursue the legitimate interests of the Company and protect our legal position in the event of legal proceedings. If you do not provide this data, we may be unable in some circumstances to comply with our obligations and we will tell you about the implications of that decision.
The information that we collect, process, hold
The sort of information we hold includes correspondence with you, your contact details, and other information needed for participation in the voyage and delivering RYA training, if applicable.
The type of information that we collect to enable us to process the booking, include:
- personal information, such as
- name of parent/guardian, address, email address, phone number;
- name of participant, address if different to parent/guardian, email address, date of birth, gender
- emergency contact details
- photo permission
- relevant health and safety information, such as medical information, fitness, swimming ability or dietary requirements
- RYA course, if applicable
- bursary awarded, if applicable
- processing funding applications, if applicable
The lawful basis on which we collect and process this information
We collect and process personal information in order to fulfil contractual obligations and to comply with the law and regulations.
Storing this information
We take appropriate technical and organisational steps to safeguard your information. We will hold Personal Data in accordance with the minimum retention periods required by law or regulation. We will only keep personal information after this period if there is a legitimate and provable business reason to do so.
Your information may be held at our offices or on secure systems, with each asset, eg computer or other electronic device, being password protected.
It is our normal practice to destroy printed paper copies containing Personal Data soon after the fulfilment of a voyage. However, we retain copies in digital format for as long as is necessary to comply with legal requirements and regulations. Once the retention period has elapsed, the documents are reviewed, archived if applicable, or confidentially destroyed or deleted from our systems depending on their purpose, classification and action type.
Providing Information to us electronically
No data transmission over the internet can be guaranteed as 100% secure. When sending Personal Data to us via email, you do so at your own risk if your email provider does not use TLS (Transport Layer Security) by default. Where possible, we recommend encrypting/password protecting electronic attachments. If in doubt, you may prefer to return forms to us by post.
Who we share information with
We share information for the purpose for which it is required. We routinely share data with:
- The Royal Yachting Association (RYA), pertaining to certificates or qualifications gained
- Association of Sail Training Organisations (ASTO), of which we are a member, pertaining to funding
- Funding bodies, if applicable
On very rare occasions, you / your child may be offered a transfer to another sail training operator, for instance, if we needed to withdraw from participation in an event and there was sufficient time to find you / your child an alternative, meaning we would need to share your / your child’s personal information with them. In such instances, we would have a written data sharing contract in place, setting out the responsibilities of each party for that data. We do not share information about you with anyone without consent unless the law and our policies allow us to do so.
We may share your / your child’s Personal Data where we are under legal obligation to do so, for example where we are required to share information under statute, to prevent fraud and other criminal offences or because of a Court Order for example the police.
Fitness to take part and health declaration
As part of the booking process you are required to complete an ‘individual details and consent form’. You are advised to seek medical advice if you are in any doubt of your / your child’s ability to participate. On this form you have the opportunity to inform us of any special requirements you / your child may have. For example, this may be the need for reasonable adjustments due to a disability. Information you provide on this form will be used to comply with our health and safety and operating obligations. By providing this information you consent to us holding and processing the information.
Royal Yachting Association (RYA) courses:
Where RYA training leads to a certificate that must be registered online
On successful completion of a RYA Day Skipper course, and upwards, your / your child’s name, contact details, date of birth, certificate number and date of issue will be shared with the RYA through a secure web portal on www.rya.org.uk. The data will be stored on the RYA’s central database. This information allows the RYA to record the qualification, to update any records they may hold for you / your child, and to verify or replace a certificate if required.
Where an RYA certificate is issued which is not required to be registered online
On successful completion of your / your child’s RYA Start Yachting certificate / RYA Competent Crew certificate, achievement of the certificate will be recorded and stored by us. This information allows us to verify or replace a certificate if required.
Fulfilment of Duke of Edinburgh’s Award Gold Residential
Successful completion of a DofE Gold Residential activity is signed off by the Assessor (us) at the end of the voyage. Should your / your child’s DofE booklet not be available, with your permission we are able to enter the information online through your / your child’s eDofE portal. To do that, we will need your/ your child’s DofE ID number, which will only be used for this purpose.
We gather feedback at the end of a voyage whereby participants are asked to complete a short form. Feedback is voluntary and can be anonymous. This feedback may be used in reports to funding bodies who have contributed financially to the voyage or to an individual, or in our own published material, including Annual Reports and newsletters, website and social media. We do not use last names, but on occasion may use a first name. Feedback will be stored as per guidelines outlined in this Notice.
Photographs and videos
Imagery is only taken with express permission from the parent/guardian or participant if aged 18 or over. Images may be used in reports to funding bodies who have contributed financially to the voyage or to an individual, or in our own published material, including Annual Reports and newsletters, website and social media. We do not use last names, but on occasion may use a first name. Images will be stored as per guidelines outlined in this Notice.
Where you have consented to our processing of your /your child’s personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent. However, the withdrawal of consent does not affect the lawfulness of earlier processing. If you withdraw your consent, we may not be able to continue to provide services to you. Even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis.
The Company aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
If you would like to discuss this policy in more detail, please contact us on 01752 823007, by email to firstname.lastname@example.org , or in writing to The Island Trust, 10 Manston Terrace, Exeter EX2 4NP.
Last reviewed September 2019