PRIVACY NOTICE
OUR PRIVACY POLICY
This document explains why we collect your personal data, what we record, how it is used and stored, and what rights you have relating to it.
We are:
- Independence16 Ltd T/A Scorpion Airsoft, which provides Duke of Edinburgh Gold Residentials, non-residential outdoor adventure activities for young people and adults who come to us as individuals or with their school, college, youth group or families.
For all practical purposes, we are one organisation. The policies, staff and management systems of Independence16 Ltd also cover Scorpion Airsoft and so this Privacy Statement applies to both entities.
Independence16 Ltd is the data controller for all personal data covered by this document.
There is a single point of contact for Independence16 Ltd:
Telephone: 07393 215941
Email: info@scorpionairsoft.uk
Address: Building 23, West Raynham Business Park, Fakenham, NR21 7PL
We are committed to keeping your personal data safe and secure, and to meeting the requirements of the UK General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 (“DPA”), the Privacy and Electronic Communication Regulations 2003 (“PECR”) and other relevant data protection law.
We keep this Privacy Statement up to date to help you understand what we do with your personal data. This is version 2.0 of this document, and we last updated it on 29.12.2023.
YOUR DATA AND HOW WE USE IT
SUMMARY
We protect your personal data and will never sell it to anyone.
We collect and process personal data to fulfil our business purposes and to deliver courses to clients. When we collect your personal data, we aim to be clear about our reasons for doing so, and we will only use it in ways that you would reasonably expect.
In general, when you:
- visit our website
- communicate with us
- apply for or book a course with us
- take part in a course or event with us
at some point, we will need to collect and use some of your personal data. We will do our best to keep your information up to date. Please let us know if your details change.
We want to be open, honest and fair in the way that we use your data. Section 4 of this Privacy Statement gives you details of your legal rights over your personal data.
We keep your data secure and continually improve our systems and processes, using audits and expert advice to help us.
We use carefully chosen suppliers to help us with specific tasks. This sometimes means we need to share some of your personal data with them. For example, this could be to send you an email newsletter that you’ve opted in to, or to process a payment.
We share only the information needed to carry out the particular task. Our contracts with our suppliers require them to only act on our instructions, to keep your data secure and to comply with data protection laws. We always keep control of your data.
Like any other organization in the UK, if asked by the police, or other regulatory or government authority, we may be required by law to pass on your personal data to them, and we might not be allowed to tell you if this happens.
The rest of section 1 goes into more detail about what we do with your personal data depending on your relationship with us.
WHEN YOU VISIT OUR WEBSITE
When you use our website, we collect and process certain types of personal data and place some cookies on your device. For more details, please see the website privacy notice at https://www.scorpionairsoft.uk/TandCs.
IF YOU ARE A COURSE PARTICIPANT OR APPLICANT
If you are completing a participant information form for someone else (such as your child), you should tell them that we will have their data and that they have certain rights relating to it. Show them this section of the Privacy Statement and help them to understand it.
If you are a course participant (or applicant), we may use your personal data for the purposes of:
- Processing your course booking
- Administering your course
- Managing your health, safety and wellbeing and that of people around you
- Statistical analysis to aid evaluation, improvement and reporting
We may be given some of your personal data by your school/college or employer, or by the person who booked your course. This information helps us to plan and prepare your course and accommodation, and usually includes:
- your name
- gender
- age
- and sometimes, your school/college class, your job role, or other contextual information about you or the group you are coming with.
We require you to complete a secure online Personal Information and Consent form/Insurance Waiver before you can take part in an Indepence16 Ltd course. On this form, we ask for some sensitive personal information, including:
- date of birth
- next of kin
- gender
- detailed medical information, including allergies and medical conditions
- information on your dietary needs
- if you are disabled, information about your access needs
- any other information you may decide to tell us that helps us look after you.
This sensitive data is strictly confidential, and we take extra care with it. We mainly use it to manage the health, safety and well-being of you and those around you, including to provide appropriate support and medical care if required.
After your course, we need to keep this data along with other records about your time with us. This helps us to meet our legal responsibilities. We will retain this information for at least three years after your course if you are over 18. If you are under 18, we need to keep it until you are at least 21 years old.
The lawful condition for processing the sensitive data for health, safety and wellbeing purposes is substantial public interest – safeguarding of children and individuals at risk.
We also ask for some sensitive data about your background and characteristics. This is used for statistical analysis. Usually, this is information you’ve chosen to tell us on the Personal Information and Consent form/Insurance Waiver.
The statistical analysis of sensitive data is carried out in accordance with UK GDPR Article 89 and is done in our legitimate interest.
During or after your course we may also collect:
- your responses to any evaluation questions
This information is used to evaluate and report on the impact of our work and to help us improve our courses. It is anonymised whenever possible. We will never identify you in a report or case study without your express permission in advance.
Any feedback you give us.
We use this information to keep improving our products/courses. Feedback and evaluation information is used in line with our legitimate interests.
We also collect: your contact details.
We may need to send you important information about your course. You can’t opt out of receiving this type of message when you book through our online booking portal or contact us directly.
You (and your parent or guardian’s) preferences for receiving marketing messages from us, and contact details for doing so.
You are in control of whether to receive marketing messages from us. Our marketing is done in line with legitimate interests.
We may also hold records of any written communication with us.
WORKING WITH YOUR SCHOOL, COLLEGE OR EMPLOYER
If you come to us with your school, college or employer, we might need them to help us make sure that the Personal Information and Consent form/Insurance Waivers are completed by you and other people on your course.
Your school, college or employer cannot see what you have entered on the form. We do tell them whether you have completed the form or not.
Your school, college or employer may share other information about you with us, and we may share information with them about you. This is part of how we work in partnership to look after you before, during and after your time with us, which includes fulfilling our safeguarding responsibilities.
WORKING WITH PARTNERS
- We deliver some courses that involve working with partner organizations. For example, Trident Adventure. We will share your personal data which relates to Managing your health, safety and wellbeing and that of people around you.
IF YOU CAME ON AN INDEPENDENCE16 LTD COURSE IN THE PAST
We keep an archive of historical courses. If you came on a course with us in the past, we may have records of:
- your name, age and other basic information about you at the time
- photographs of you during your course
- your detailed course report and other paperwork from the course.
IF YOU ARE A CUSTOMER
If you have booked a course with us, we will usually hold the following information about you in order to fulfil our contract with you and to manage your relationship with us:
- your name and contact details
- your job title and other information about your place of work
- your preferences on how to contact you
- your history of bookings with us
- invoicing information
- records of your written communications with us.
We gather this personal information directly from you during the booking process and throughout the course of your relationship with us.
During or after the course you booked, we may also collect:
- your responses to any impact evaluation or feedback opportunities.
This information is used to help us keep improving our courses and the way we work with you and other customers, or to evaluate and report on the impact of our work - in which case it is usually anonymised. We will always ask your permission if we want to use your name in any of our evaluation reports or marketing material. Evaluation and feedback is done in line with our legitimate interest.
MARKETING COMMUNICATIONS
If you have opted in, or if you have previously booked a course, or attended an event with us, then from time to time, we may tell you about news, events, activities or offers which we think may be of interest to you. You can opt out of receiving these messages whenever you like.
We limit the number of marketing messages that we send
If you do not wish to receive marketing messages by post, phone, text or email, you can notify us to change any of your preferences at any time by contacting us at info@scorpionairsoft.uk
HOW WE LOOK AFTER YOUR PERSONAL DATA
We protect your personal data and will never sell it to anyone.
We hold and process your personal data on Independence16 Ltd computer and paper systems. We continually improve our processes and systems. We consider data protection by default and by design.
SECURITY
We take the security of your data seriously. We have Clean Screen and Clean Desk policies and encrypt all data held on phones and computers. Our staff undergo DBS checks and have data protection training before handling personal data. Access to personal data is limited to those people who require it for their roles, and logins are secured with multi-factor authentication. Medical data and other sensitive data gathered through the Personal Information and Consent form/Insurance Waivers are subject to additional access and retention controls and cannot be exported from the system.
Personal Information and Consent forms/Insurance Waivers are only stored and processed within the UK.
SUPPLIERS
We use carefully chosen suppliers to help us with certain tasks. These include processing personal data for managing bookings, administering courses, taking payments and communicating with you. We use Data Processing Agreements and other contractual arrangements to ensure your data is only processed on our instructions, in line with the law. We monitor the performance of our suppliers to ensure that our standards are maintained.
CHANGES TO THIS STATEMENT
We make changes to this Privacy Statement from time to time as part of our commitment to continual improvement. The latest approved version of this policy will always be available on our website.
If we make any significant changes in the purposes that we use your personal data for, we will make this clear on our website or contact you directly.
YOUR DATA RIGHTS
You have the following rights relating to your personal data. If you want to exercise any of your data rights, just get in touch with us at info@scorpionairsoft.uk. To keep your data safe, we may need to check that you are who you say you are.
- The rights to know what data we hold about you, what we use it for, and to request a copy of personal information held about you.
We will provide this information within one month. It will help us if you can be specific about the types of data you would like a copy of.
- The right to request that any inaccuracies be corrected.
We will usually be able to do this immediately, although in some circumstances it might take us up to one month to complete your request.
- The rights to request us to stop processing your personal data and to request us to delete your personal data
There might sometimes be good reasons why we need to keep some data, even if you have asked us to delete it. For example, if you have asked us not to send emails to you, we will need to keep your email address to check against so that we don’t accidentally send you emails in future.
- The right to complain to the Information Commissioner’s Office
You can do this at any time. The Information Commissioner’s Office can be found at ico.org.uk.
CONTACT US
Please get in touch if you have any questions about this policy, would like us to stop sending you messages or using your data, or if you would like to exercise any of your personal data rights.
Telephone: 07393 215941
Email: info@scorpionairsoft.uk
Address: Building 23, West Raynham Business Park, Fakenham, NR21 7PL.
5.1 Data Protection Officer
Our Data Protection Officer is Mark Keddie
Email: info@scorpionairsoft.uk