1 Information Collection and Use
1.1 Torbay Sea School LLP (TSS) is the sole owner of the information collected on www.torbayseaschool.co.uk. We will not sell, share, or rent this information to others in any way. Torbay Sea School LLP collects information from our users at different points on our website.
2 Lawful, fair and transparent
2.1 TSS collects User’s personal data on the basis of:
2.1.1 User’s prior consent for us to do so
2.1.2 Fulfilling a contract –
220.127.116.11 To provide training or other services
18.104.22.168 To administer and register Users with external service providers (such as RYA Interactive)
22.214.171.124 To administer and register certification as a result of User’s training or other services provided to the User
2.1.3 Our legitimate interests (which are not overridden by User’s interests)
126.96.36.199 To obtain feedback on our courses, facilities and instructors
3 Purpose Limitation
3.1 User’s data is collected to allow TSS to:
3.1.1 Provide appropriate and safe training – TSS must be aware of any medication, medical problems or dietary requirements
3.1.2 Maintain communication with Users (via email, telephone or post)
3.1.3 Register a certificate Users may hold, issued to them by TSS, with the RYA to prove its’ validity
3.1.4 Register Users on the RYA Interactive site in order for them to complete RYA Interactive training courses
4 Data minimisation
4.1 TSS will only collect the following details through an online booking form:
4.1.1 Type and Date of the course the User has booked on
4.1.2 Full name
4.1.3 Date of birth
4.1.4 Postal address
4.1.5 Email address
4.1.6 Phone number
4.1.7 Next of Kin name, relationship and contact details
4.1.8 Prior Experience
4.1.9 Dietary requirements
4.1.10 Regular medication
4.1.11 Medical/health problems
4.1.12 Agreement to Terms and Conditions
4.1.13 For own boat tuition only
188.8.131.52 Boat name
184.108.40.206 Boat make and model
220.127.116.11 Boat berth and marina
4.2 TSS will collect the following details through an online feedback form:
4.2.1 Type, location and date of the course the User attended
4.2.2 Full name
4.2.3 Email address
4.2.4 How the User found out about TSS
4.2.5 User’s opinion of:
18.104.22.168 General content of the course
22.214.171.124 Relevance of the material covered
126.96.36.199 Amount of material covered
188.8.131.52 The assessment (if any)
184.108.40.206 Whether the course met your expectations
220.127.116.11 Whether the User found the course informative
18.104.22.168 User’s favourite part of the course
22.214.171.124 Subjects which could be covered in more detail
126.96.36.199 Subjects which could be covered in less detail
188.8.131.52 The instructor’s positivity and effectiveness
184.108.40.206 The instructor’s answers to User’s questions
220.127.116.11 The information provided to Users throughout the course
18.104.22.168 Organisation of the course
22.214.171.124 Presentation of the course
126.96.36.199 The training room or boat
188.8.131.52 Sailing area
184.108.40.206 Quality of food
220.127.116.11 Quality of accommodation
18.104.22.168 Quality of service
22.214.171.124 Information received prior to the course
126.96.36.199 Administration of the course
188.8.131.52 User’s personal preparation for the course
184.108.40.206 Additional comments
5.1 Data held by TSS will be kept up to date by correspondence with Users, and by requiring Users to complete a booking form for each booking made to ensure details are as current as User’s latest booked course.
6.1 User’s data will be treated in confidence by TSS staff only, and stored electronically using:
6.1.1 Microsoft Office – Outlook
220.127.116.11 Outlook emails
18.104.22.168 Outlook Calendar events
6.1.2 Google Drive
22.214.171.124 Google Forms
126.96.36.199 Google Spreadsheet
6.1.3 Joomla framework (including VikEvents)
6.1.4 Mail Chimp
6.2 User’s data will be stored by TSS for a minimum of 12 months.
6.3 Previous paper copies of details will be archived for a maximum of 5 years.
6.4 Digital copies of User’s data will be kept for a maximum of 12 months from the date Users have provided it.
6.5 Upon successful completion of any course with TSS where Users have been awarded a certificate or license, User’s name, certificate number and date of issue will be stored for up to 12 months. This information allows us to verify or replace certificates if needed.
7 Data sharing
7.1 Directly with the RYA
7.1.1 As a Recognised Training Centre (RTC), TSS is required to share certain data with the RYA and the RYA to share certain data with TSS. In the case of such shared data, both TSS and the RYA will be Data Controllers.
7.1.2 Data will only be shared in line with the requirements in the RYA’s Recognition Guidance Notices. The data will be retained by the RYA in line with the RYA’s Privacy Notice.
7.1.3 Data shared by the RYA with TSS will only be used for the stated purpose, for example lists of instructors available for work should not be retained for longer than is needed to engage an instructor for that job.
7.1.4 Both the RYA and TSS will individually be data controllers for the data they hold on students of TSS and will be independently responsible for:
188.8.131.52 The robustness of their data systems;
184.108.40.206 Their own data breaches and informing the other party about data breaches;
220.127.116.11 Respecting the rights of the data subject.
*This only applies if the User has successfully achieved one of the following certificates: Day Skipper Practical (Sail or Motor), Coastal Skipper Practical, Level 2 Powerboat Handling, Intermediate Powerboat Handling or Advanced Powerboat Handling Course Completion Certificate.
7.1.6 Upon successful completion of the User’s RYA course not covered by 7.1.5*, User’s name, certificate number and date of issue will be stored for up to 12 months. This information allows us to verify or replace User’s certificate if required.
*This only applies if the User has successfully achieved one of the following certificates: Start Yachting, Competent Crew, Helmsman, Powerboat Level 1, Safety Boat, Intermediate Powerboat, First Aid, Radar, Sea Survival, Diesel Engine.
7.2 RYA interactive site
7.2.1 To enable access to User’s online course we need to share some of the User’s personal data with the RYA via the user profile in www.ryainteractive.org. This learning management website is hosted and maintained by a third party called Learning Pool, who will not use User’s personal information for any reason other than enabling the User’s course.
7.2.2 User’s name and email address will be entered on www.ryainteractive.org in order to create their user account. On the User’s first access to the site, Users will be asked to enter their address and date of birth. Users will have access to the site for one year in order to complete their online course. During this period, the User’s personal information will be held on the website by Learning Pool and be available to this training centre and the RYA for the purpose of managing the User’s course.
7.2.3 Instructional support will be provided by this training centre for a period of 12 months from the date of the User’s course booking.
7.2.4 On completion of the User’s course, User’s name, email, date of birth and address will be transferred to the RYA's central database for the purpose of recording details of the course and any certification Users gain as a result of it. This information allows the RYA to record User’s certification, to update any records they may already hold about the Users or their qualifications and to verify their certificate if required.
7.2.5 After one year from the date of User’s enrolment on a course, their user account will be removed from www.ryainteractive.org.
7.2.6 Full details of how the RYA will deal with User’s personal information will be displayed when Users first access www.ryainteractive.org.
7.2.7 For the duration of User’s access to the site, User’s data will be held in accordance with the RYA Interactive Data Policy, Terms and Conditions.
7.3 Visitors to our websites
7.3.1 When someone visits www.torbayseaschool.co.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
7.4 E-newsletter and Feedback forms
7.4.1 We use a third party provider, MailChimp, to deliver our online feedback forms and monthly e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice.
7.5 People who email us
7.5.1 We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Users have a responsibility to ensure that any email Users send is within the bounds of the law.
8 Booking Forms
8.1 To book onto a course Users will be required to fill in an online course booking form. Within this form, Users must inform TSS of any medical/health/dietary conditions or requirements they have. This form is hosted on our website using the Joomla! Component VikEvents, and on Google Forms. Access to data input by these methods is password protected and protected by VikEvents’ and Google’s Privacy Policies.
8.2 User’s suitability for the course they have booked on to will be confirmed by
8.2.1 Previous experience field on all booking forms
8.2.2 Expectations for the course field on booking forms
8.2.3 Correspondence between the User and TSS, where experience and queries may be raised, may be used to verify the information Users have already provided and may take the form of conversation by phone, in person, by email, and by post.
8.2.4 Requirements for the course Users have booked onto are clearly stated in the steps prior to completion of the booking form
8.3 Fitness to take part and health declaration
8.3.1 To enable us to judge User’s fitness to take part in any particular course, TSS will give a clear picture of what is involved in the course. This will be specific to the nature of TSS’ operation, the craft TSS uses and the area that TSS operates in.
8.3.2 Users are advised to seek medical advice if they are in any doubt of User’s ability to participate.
8.4 TSS will only record what is necessary to ensure the appropriate adjustments or measures are in place. The process is two-fold:
8.4.1 At the time of booking, Users will be asked if there is any medical or other reason why they may require some special consideration. This includes:
18.104.22.168 Dietary requirements
22.214.171.124 Regular medication
126.96.36.199 Medical/health problems
8.4.2 At the time of the course, Users will be asked about any needs or condition they have specified to TSS within this form to allow for confirmation of User’s needs and the structures put in place by TSS to cope with this. This specific information will only be held for the duration of the course.
8.4.3 When providing details of any requirements, needs or conditions Users have, Users will explicitly asked for their consent for the use of that information, with a link to this Data Protection Policy included in this option.
8.5 Users will be emailed confirming their place on their chosen course and relevant payment details. If Users have not already been in correspondence with a member of TSS staff to confirm that they meet any pre-requisites for this course.
9.1 Upon completion of the User’s booked course, an email containing a link to an online booking form (hosted by Google Forms) will be sent to the email address provided on User’s booking form.
9.2 Feedback may be anonymous, however fields to provide name and email are included to allow any issues or complaints raised to be addressed.
9.3 Answers to this feedback form will be held
9.3.1 On Google Drive
188.8.131.52 As Individual Form responses
184.108.40.206 As Individual responses on a linked Google Spreadsheet
10 Staff and Employees
10.1 TSS will maintain accurate personnel records detailing qualifications held and expiry/issue dates of any supporting certificates such as first aid, medical fitness or criminal records checks. For RYA instructors, a letter of appointment or instructor certificate is also required. Copies of these certificates will be held digitally using Microsoft One Drive.
10.2 A declaration of the acceptance of contracts and confirmation that staff have read and understood TSS’s operating procedures will also be held digitally using Microsoft One Drive
10.3 Instructors requiring commercial endorsements must hold a current medical fitness certificate which must be checked for any restrictions.
10.4 TSS will make clear to all staff the terms under which they are engaged, and their role (if any) in data processing within the company.
11 User’s rights
11.1 Users have the following rights with regard to the personal data we hold about them
11.1.1 The right to be informed.
11.1.2 The right of access.
11.1.3 The right to rectification.
11.1.4 The right to erasure.
11.1.5 The right to restrict processing.
11.1.6 The right to data portability.
11.1.7 The right to object.
11.1.8 The right not to be subject to automated decision-making including profiling.
11.2 Users reserve the right to complain to the Information Commissioner’s Office (ICO) if they believe TSS are mishandling data: https://ico.org.uk/concerns/
12 Subject Access Requests
12.1 Users have the right to request access to our data about them
12.2 All requests will be addressed within 31 days