Venturers Privacy Notice (last updated July 2018)
1. Who are we?
This Privacy Notice is provided to you by Venturers Norfolk Broads Cruise (VNBC or Venturers) which is the data controller for your data if you have any connection with the VNBC. A description of what data is processed and for what purpose is set out in this Privacy Notice.
2. What data do VNBC process?
VNBC will process some or all of the following where necessary to perform our operations as a provider of a Christian-based activity holiday:
· Names, titles, gender, age and dates of birth;
· Contact details such as telephone numbers, addresses, and email addresses. These are either of the individual participant or their parent/guardian.
· Where you make donations or pay for activities, financial identifiers such as the amount, your name and the purpose of the donation will be recorded and kept secure. Bank account numbers may be seen on cheques and/or electronic payments but will not be held by VNBC.
· Medical information provided by yourselves on a health declaration form to understand the health needs of participants.
3. How do we process your personal data?
VNBC will comply with the legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We will use your personal data for some or all of the following purposes:
· To enable us to meet all legal and statutory obligations;
· To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with good safeguarding practice from time to time with the aim of ensuring that all participants are provided with safe environments;
· To maintain our own accounts and records;
· For the safe running of Venturers operations.
· For general communication about forth coming Venturers activities;
4. What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests as a provider and organiser of a Christian-based water-based activity holiday, or the legitimate interests of a third party (such as the Examiner of our accounts or the Boatyards from which VNBC hire their vessels). Some of our processing is necessary for compliance with a legal obligation.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use. This could be, for example, the use of photographs in our marketing material.
5. Sharing your personal data
Your personal data will be treated as strictly confidential. It will not be shared with third parties other than those identified above without your consent unless there is a legal imperative to do so.
6. How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
7. Your rights and your personal data
You have the following rights with respect to your personal data:-
1. The right to access information we hold on you
· At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
2. The right to correct and update the information we hold on you
· If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
3. The right to have your information erased
· If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
· When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
4. The right to object to processing of your data
· You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
5. The right to data portability
· You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
6. The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
· You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
7. The right to object to the processing of personal data where applicable.
8. The right to lodge a complaint with the Information Commissioner’s Office.
8. Further processing
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
9. Contact Details
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at: