Luton Diving Club

Approved – December 2021
Next Review – First committee meeting after the AGM (2022)

Table of Contents

  1. Data Protection Principles
  2. General Provisions
  3. Lawful, Fair & Transparent Processing
  4. Lawful Purposes
  5. Data Minimisation
  6. Accuracy
  7. Archiving / Removal
  8. Security
  9. Breach


The Club – means Luton Diving Club (LDC), a Community Amateur Sports Club.
GDPR – means the General Data Protection Regulation.
Responsible Person – The Club Chairman shall be responsible for data protection within the Club.
Register of Systems – means a register of all systems or contexts in which personal data is processed by the Club.

1. Data Protection Principles

The Club is committed to processing data in accordance with its responsibilities under the GDPR. The Club needs to gather and use certain information about individuals. These may include members, waiting list, business contacts, volunteers and other people the Club has a relationship with or may need to contact. This policy describes how this personal data should be collected, handled and stored.

Article 5 of the GDPR requires that personal data shall be:

a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. General Provisions

a. This policy applies to all personal data processed by the Club.
b. This policy applies to: Members of the Luton Diving Club Committee and volunteers of the club; and all contractors, suppliers and other people working on behalf of the Club.
c. The Responsible Person shall take responsibility for the Club’s ongoing compliance with this policy.
d. This policy shall be reviewed at least every two years.
e. The Club shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, Fair & Transparent Processing

a. To ensure its processing of data is lawful, fair and transparent, the Club shall maintain a Register of Systems.
b. Individuals have the right to access their personal data and any such requests made to the Club shall be dealt with in a timely manner.

4. Lawful Purposes

a. All data processed by the Club must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance on the Information Commissioner’s Office website for more information).
b. The Club shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Club’s systems.

5. Data Minimisation

The Club shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. The personal data the club collects may include the following:

  • Contact details such as name, address, email address and phone number;
  • Birthdays;
  • Gender;
  • Swim England membership number and information;
  • Records of any contact or correspondence;
  • Any feedback;
  • Necessary bank details for processing payments;
  • Videos and photos of members;
  • Hobbies and experiences;
  • Details of any application for funding or other relevant information to the necessary running of the Club;
  • Any information pertaining to welfare cases.

6. Accuracy

a. The Club shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / Removal

a. To ensure that personal data is kept for no longer than necessary, the Club shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

a. The Club shall ensure that personal data is stored securely
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Club shall promptly call an urgent committee to assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioner (more information on the ICO website).