Privacy Policy & GDPR Compliance Statement

Introduction

BG Racing and BGR Management Services Limited recognise that data protection and privacy is important and this statement covers our approach to compliance with the General Data Protection Regulation (GDPR), May 2018.

We seek to process any personal data lawfully and transparently and will ensure that we have a legitimate reason for storing and processing data.  We keep personal data up to date and will correct it if necessary.  We will delete personal data that we no longer need and we operate cyber-security and physical security controls to protect personal data.

Our Data

We control, personal data of shareholders and other individuals who wish to receive communications.  Such data is largely limited to names and addresses (both email and post) although various tracking of usage of our website and social media is carried out to ensure we can provide relevant content of interest to individuals (see below).

Most data is stored digitally in password protected software or documents.  Some data is stored in paper files and some personal data may be stored within emails and attachments.

By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analysing the use of the website and services.

We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”).  The transaction data will be used for the purposes of receiving payment and supplying the goods and services.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.

We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication and will be used for the purposes of communicating with you and record-keeping.

Grounds for Processing Data

BG Racing and BGR Management Services have relevant grounds for processing all personal data, these being legitimate business interest or having received consent from the data subject.

Employee Training

All employees will have their attention drawn to their responsibilities as set out in this document.

Data Subject’s Rights

We recognise the rights assigned to data subjects by legislation and in all cases will support an individual seeking to exercise these rights.  Individuals have the right to access their personal data, to demand that it be corrected, to request that it be deleted and the request a restriction in the way that it is processed.  Individuals are entitled to a copy of their personal data.  Legislation provides the data subject with the rights to object to their data being processed or withdraw their consent to processing and gives individuals the right not to be subjected to automated decision making or profiling based on their data.

If an individual believes that BG Racing or BGR Management Services are not handling their data in an appropriate manner then they have the right to complain to the Information Commissioners Office (ICO).

Subject Access Requests

It is the right of an individual to be provided with their personal data.  As a data controller, we will comply with Subject Access Requests (SARs) and provide a response to the data subject.  We will not charge for complying with a Subject Access Request and will endeavour to respond within legislative timescales.  We reserve the right to refuse to comply with a request, if it is felt to be excessive or unfounded, however in such circumstances, we will confirm this to the data subject and provided them with details of how they can seek rectification via supervisory authorities.

Should a data subject object to the ongoing use of their data, then as controller we will either delete the data or confirm to the data subject, why we believe we have a legal right to retain the data.  We will keep a record of any SARs received.

Rectifying & Amending Personal Data

Should we become aware under any circumstances that the personal data we hold is incorrect or out of date, then action will be taken to rectify/amend this as soon as possible.

Retention of Personal Data

We will retain personal data for as long as we feel is necessary.  Shareholders who lapse membership and who do not wish to receive ongoing communications will have their personal data deleted within 5 years of their membership lapsing.  This will allow us to respond to questions and clarify memberships for this period.

Legal Obligations to Disclose Personal Data

We may be obliged to disclose personal data under the following circumstances:

  • We are required to do so by court order or a statutory regulator;
  • We need to disclose it in order to obtain legal advice (it will then be protected by legal privilege);
  • We need to disclose it to protect national security.

Data Processing & Dealing with Data Breaches

We have various tools in place to monitor for and identify data breaches.  If a data breach is identified, we will evaluate it to ensure that appropriate notifications are made to the ICO or data subjects as required by legislation.

All data breaches will be recorded and stored.

Data Privacy Impact Assessments (DPIA)

Should any proposed action or software development undertaken by us be deemed likely to result in a risk of data privacy being compromised, then a Data Privacy Impact Assessment will be carried out.

This assessment will involve an analysis of the proposed action or development, an evaluation of the risk posed, and identification of the steps to be undertaken to minimise such risk.

All DPIA’s will be recorded and stored.  Should an action or development be felt to pose a high risk of data privacy breach and such risk cannot be addressed, then we will consult the Information Commissioners Office (ICO) prior to undertaking the action or work.

Data Protection Officer

Having reviewed the legislation and guidance, we do not believe that it is necessary for the business to appoint a data protection officer.  Data protection responsibilities will be monitored by the management of the business.  Questions or concerns relating to data protection and privacy should be addressed to:

BG Racing, 9 Greenfields Place, Beare Green, Surrey, RH5 4PZ or by email to phil@bgracingsyndicates.co.uk

Contractors & Sub Processors

We may from time to time appoint contractors with responsibility for processing personal data.

Where we are the data controller, we will ensure that we are satisfied that the contractor is compliant with and understands their data protection responsibilities.

Amendments to this Policy

We may update this policy from time to time by publishing a new version on our website.  You should check this page occasionally to ensure you are happy with any changes to this policy.  We may notify you of changes to this policy by email or through the private messaging system on our website.

Third party websites

Our website includes hyperlinks to, and details of, third party websites.  We have no control over and are not responsible for, the privacy policies and practices of third parties.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.  Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We may use WordPress Analytics and Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites and if you block cookies, you will not be able to use all the features on our website.