Keswick Mountain Rescue Team, KMRT Headquarters, Lakeside Car Park, Lake Road Keswick, Cumbria, CA12 5DJ (“the Team”).
- The Team carries out rescues of members of the public and provides support to statutory services such as police, fire and ambulance services. We are an independent charity and operate under the association of Mountain Rescue England and Wales. The Team takes the security and privacy of your data seriously. We need to gather and use information or ‘data’ about you in pursuit of this task which is carried out in the public interest. We intend to comply with our legal obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy and security. We have a duty to notify you of the information contained in this notice.
- This notice applies to members of the public who are subject to search and rescues or provide financial donations. If you fall into one of these categories then you are a ‘data subject’ for the purposes of this notice.
- The Team has measures in place to protect the security of your data, if you require further information in this regard, please contact the Data Protection Lead.
- The Team will hold data in accordance with this privacy notice. We will only hold data for as long as necessary for the purposes for which we collected it.
- The Team is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data.
- This notice explains how the Team will hold and process your information and explains your rights as a data subject.
- This notice can be amended by the Team at any time. It is intended that this notice is fully compliant with the 2018 Act and the GDPR. If any conflict arises between those laws and this notice, the Team intends to comply with the 2018 Act and the GDPR.
- Data Protection Principles
- Personal data must be processed in accordance with six ‘Data Protection Principles.’ It must:
- be processed fairly, lawfully and transparently;
- be collected and processed only for specified, explicit and legitimate purposes;
- be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
- be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;
- not be kept for longer than is necessary for the purposes for which it is processed; and
- be processed securely.
We are accountable for these principles and must be able to show that we are compliant.
- How we define personal data
- ‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.
- This notice applies to all personal data whether it is stored electronically, on paper or on other materials.
- This personal data might be provided to us by you, or someone else, or it could be created by us.
- We will collect and use the following types of personal data about you:
- your name, address, phone number, date of birth;
- the contact details for your next of kin;
- your gender;
- your name and contact details (if provided)
- How we define special categories of personal data
- ‘Special categories of personal data’ are types of personal data consisting of information as to:
- your health, including allergies, and medications used by you
In rescues we may process this special category of your personal data in accordance with the law.
- How we define processing
- ‘Processing’ means any operation which is performed on personal data such as:
- collection, recording, organisation, structuring or storage;
- adaption or alteration;
- retrieval, consultation or use;
- disclosure by transmission, dissemination or otherwise making available;
- alignment or combination; and
- restriction, destruction or erasure.
This includes processing personal data which forms part of a filing system and any automated processing.
- How will we process your personal data?
- The Team will process your personal data (including special categories of personal data) in accordance with our obligations under GDPR and the 2018 Act.
- We will use your personal data for:
- complying with any legal obligation;
- your vital interests, or those of another person;
- to support the police, fire and ambulance services by undertaking search and rescue operations in the public interest
- if it is necessary for our legitimate interests (or for the legitimate interests of someone else). However, we can only do this if your interests and rights do not override ours (or theirs). You have the right to challenge our legitimate interests and request that we stop this processing. See details of your rights in section 9 below.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.
We can process your personal data for these purposes without your knowledge or consent. We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it.
- We will only process special categories of your personal data (see above) in certain situations in accordance with the law. For example, we can do so if we have your explicit consent. If we asked for your consent to process a special category of personal data then we would explain the reasons for our request. You do not need to consent and can withdraw consent later if you choose by contacting the Data Protection Lead.
- We do not need your consent to process special categories of your personal data when we are processing it for the following purposes, which we may do:
- where it is necessary to protect your vital interests or those of another person where you/they are physically or legally incapable of giving consent;
- where it is necessary for the purposes of preventative medicine, medical diagnosis and or the provision of treatment;
- where the data is public;
- where processing is necessary for the establishment, exercise or defence of legal claims;
- where processing is necessary for the purposes of preventative medicine, medical diagnosis, the provision of health or social care or medical treatment.
- Sharing your personal data
- Sometimes we might share your personal data with the police and other emergency services and agents as set out in 6.4 above.
- The Team may share your personal data with any third-party service providers who process your personal data for the maintenance of the Team’s IT systems.
- We do not send your personal data outside the European Economic Area.
- Subject access requests
- Data subjects can make a ‘subject access request’ (‘SAR’) to find out the information we hold about them. This request must be made in writing to the Data Protection Lead.
- We must respond within one month to a SAR unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.
- There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.
- Your data subject rights
- You have the right to information about what personal data we process, how and on what basis as set out in this notice.
- You have the right to access your own personal data by way of a subject access request (see above).
- You can correct any inaccuracies in your personal data. To do you should contact the Data Protection Lead.
- You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do so you should contact the Data Protection Lead.
- While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do so you should contact the Data Protection Lead.
- You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.
- With some exceptions, you have the right not to be subjected to automated decision-making.
- You have the right to be notified of a data security breach concerning your personal data.
- In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact the Data Protection Lead.
- You have the right to complain to the Information Commissioner. You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (ico.org.uk). This website has further information on your rights and our obligations.
- Data Security
- We have put in place measures to protect the security of your data. Details of these measures are available upon request from the Data Protection Lead.
- Third parties will only process your data on our instructions and where they have agreed to treat the data confidentially and to keep it secure.
- We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your data to those Team members, agents, contractors and other third parties who have a need to know to deal with Team activities. They will only process your data on our instructions and they are subject to a duty of confidentiality.
- We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
- Data retention
- We will only retain your data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal data are available from the Data Protection Lead. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- The Team’s Data Protection Lead is Craig Dring and can be contacted on firstname.lastname@example.org at Keswick Mountain Rescue Team, KMRT Headquarters, Lakeside Car Park, Lake Road Keswick, Cumbria, CA12 5DJ. You should direct any questions in relation to this notice to the Data Protection Lead.