BASI Privacy and Data Protection Policy
The British Association of Snowsport Instructors Limited (“BASI”, “we”, “us” or “our”) is committed to protecting and respecting your privacy and adhering to all relevant Data Protection Legislation. In this Policy, “Data Protection Legislation” means all applicable legislation which relates to the protection of individuals with regards processing personal data, including the General Data Protection Regulation (EU) 2016/679. We are data controller of any personal data that you provide us.
This policy (and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us by you visting our website, www.basi.org.uk (“Website”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Why we collect information
You must join BASI as a member as soon as you book your first course. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we have to process your personal information in order to fulfil the contractual obligations we have with our members or to take steps to enter into a contract with you;
- Where necessary for our legitimate interests (or those of a third party) in cases where your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation.
- Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or you can update your communication preferences here;
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Information we may collect from you
We will collect and process the following data about you:
Information you give us. You may give us information about you by joining as a member of BASI, by filling in forms on our Website or by corresponding with us by phone, e-mail, text, letter or otherwise. This includes information you provide when you register to use our Website, use our Member Area, subscribe to our services, search for a service or a product, place an order on our Website or carry out a transaction with us, post or contribute to our Website, participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey or when you report a problem with our Website. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, medical information and photograph.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
Information we collect about you. With regard to each of your visits to our Website we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Information we receive from other sources. We are also working closely with third parties (including for example, partner organisations, our trainers and sub-contractors, payment and delivery services and credit reference agencies) and may receive information about you from them.
Uses made of the information
We use information held about you in the following ways:
Information you give to us. We will use this information as shown below (and as shown in the section on Information we collect about you, below):
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services you have asked to receive through your communication preferences, you can update your communication preferences here;
- to respond to any of your comments and queries;
- to ensure that the content from our Website is presented to you in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our Website if you choose to do so;
- to keep and maintain the BASI organisational records and databases;
- to notify you about changes to any of our services;
- to supply to partner organisations as outlined under ‘Disclosure of your information’ below.
Information we collect about you. We will use this information, as noted in the section on Information you give to us, above, and also:
- to administer our Website, our membership data and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- as part of our efforts to keep our Website safe and secure;
Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
As a data subject, you may notify us of which communications you would like to receive and how you would like to receive them, by updating your communication preferences here or via your Members’ Area.
In accordance with your communication preferences (where applicable) we will communicate with you by telephone, letter, texts, emails or other reasonable means with updates and information about goods and services which were the subject of a sale to you or an enquiry from you.
Disclosure of your information
We may share your personal information with selected third parties including:
- Service providers to BASI for the purposes of fulfilling your order, processing your payment details and providing support services e.g. Providing an address to a mailing house for delivery of your manual;
- Trainers, business partners, suppliers and sub-contractors for the fulfillment of any contract we enter into with them or you;
- Sage Pay Europe Limited (or any successor organisation) so that they can process a payment transaction on our behalf. This means that your credit/debit card details are provided directly to Sage Pay Europe Limited and are never stored by us;
- Analytics and search engine providers that assist us in the improvement and optimisation of our Website;
We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Condition as defined here, or in order to enforce or protect any of our rights, property or safety (or those of our members). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination inside the European Economic Area ("EEA"). It may also be processed by staff operating inside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
In the event that we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it. This may involve implementing one or more of the following safeguards:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. All information which you provide to us is stored on secure servers and any payment transaction with us will be encrypted.
Where you have been given (or you have chosen) a password which enables you to access parts of our Website, then you are responsible for keeping that password confidential. We would ask that you not share or disclose a password with any third party.
How long we store your Data
Unless you request otherwise:
We will store the following information for 20 years after your membership ends in our database in order to identify members wishing to rejoin and reactivate their BASI qualification/licence after a prolonged lapsed period. We will contact you prior to deleting this data to ensure you have no need for us to retain this information:
- Membership number
- Email address
- Course history
- Course reports
- Log sheets (teaching hours and tours)
We will store the following information for 10 years
- Membership subscription history
We will store the following information for 6 years:
- Credit card receipts
- Direct debit mandates
- BASI invoices
We will store any complaints from or about our members, for 2 years
We will store the following for 3 months:
- Videos of candidates on the course taken by the trainer for individual feedback
- Written projects
We will delete the following immediately after processing:
- Disclosure certificates
- First Aid certificates
- Safeguarding children certificates
- External CPD certificates
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
Under the General Data Protection Regulations, you have the right in certain circumstances to:
- Request access to your personal information (commonly known as a “data subject access request”).This enables you to receive a copy of the personal information we hold about you and to check we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- Withdraw your consent to the processing of your personal information at any time.
You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.