UKAD General Privacy Notice
What does this notice cover?
This notice describes how UK Anti-Doping ("UKAD", "we" or "us") will make use of your data on its website and during your interactions with us online and offline, including your communications with us and any communications you make with the intelligence team and data we may handle if you or your employer supplies us.
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
UKAD’s main anti-doping activities are subject to a dedicated anti-doping privacy notice. This can be found here and applies to all personal data handled about athletes, athlete support personnel and other individuals connected with sport.
Summary of how we use your data
• UKAD uses your personal data to allow you to use the features on our website, to administer your online and offline relationships with us, to comply with our legal obligations and communicate with you. Some of this information will be provided by you, and others will be generated by UKAD or provided by third parties.
- Our websites may provide interactive features that engage with social media sites, such as Facebook and Twitter. If you use these features, these sites will send us personal data about you.
- Where we rely on your consent, such as for direct marketing purposes, or to place cookies, you can withdraw this consent at any time.
- Our privacy notice sets out more details of this processing, including details of your data protection rights, including your right to object to certain processing.
What information do we collect?
We collect and process personal data about you when you interact with us and our websites and social media pages, when you make an identifiable doping report, when you purchase any products or training from us, where you visit our premises, when we carry out market research and when you deal with us as a supplier or an employee of a supplier or stakeholder. This will typically be provided directly by you, and may include information you provide in a form or an email, or any registration. The details being provided by you will be made clear in any forms you complete or will usually be chosen by directly by you in volunteering information in communications or content you provide us.
What information do we generate or receive from third parties?
We may generate or collect information about you ourselves. In an online context, much of this is set out in our Cookies Policy. More detail on this is set out below. In an offline context, we may particularly collect information about you through maintaining records of identifiable anti-doping reports and an intelligence database, or by keeping access records of our sites.
Sometimes, we receive information about you from third parties. For example, if you use a "like" or a "share" button for a feature on our sites or apps, then the third party will share information with us. We sometimes will receive relevant information from third party sales sites we partner with, such as the Coachwise Hub, to help us manage your purchases.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
To fulfil a contract with you, or take steps linked to such a contract: this is relevant where you make a purchase of our content, download our app or where you are a supplier of UKAD. This includes:
- communicating with you;
- administering our contractual relationship; and
- providing any services we may have agreed to offer you. To this extent this might involve processing sensitive data, we do this with your explicit consent. We do not make any further use of this information for our own purposes.
As required by UKAD to pursue and exercise our public interest functions:
- we will use your information to provide communications or services you have requested and to respond to any comments or complaints you may send us;
- we monitor use of our websites and online services and apps, and use your information to help us improve and protect our services, content, and websites;
- we use information you provide as well as information which we have collected about you to investigate any complaints received from you or from others, about our website or services; and
- we process data you provide when you report an anti-doping violation or other intelligence in an identifiable form. If this involves sensitive personal data, such as details about your own conduct or the circumstances of report, we do this to help us eliminate doping in sport.
As required by UKAD to carry out processing data for its legitimate interests, in particular:
- we may carry out market research activities.
Where you give us consent:
- we will send you promotional communications about relevant services, content or events that UKAD offers;
- we place cookies and use similar technologies in accordance with our Cookies Policy (see below) and the information provided to you when those technologies are used; and
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
For purposes which are required by law:
- where we are required to hold or collect personal data to meet legal requirements on us, such as keeping health and safety records and details of our relationships with suppliers; and
- where in response to requests by government or law enforcement authorities conducting an investigation.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
What cookies and/or tracking technologies does UKAD use?
When you visit one of our websites, we may also collect, process and use information about you and your use of the website, including any forums you visit and how you arrived at our site. Such information may be collected through "traffic data" and may entail the use of "cookies" or other tracking technologies, IP addresses or other numeric codes used to identify your computer. For more information on Cookies please click on the link to our Cookies Policy.
Apple iOS and Android Devices
By accessing a UKAD application from these devices you consent to cookies being stored to your device (and other tracking technologies being used to read data from your device) for the following purposes: keeping you logged in, ensuring that an appropriate version of content is presented, analytics and advertising. Many of these cookies and technologies are essential to the operation of the application. It is not currently possible to opt out or remove these cookies (or prevent use of these technologies) from the device without deleting the application.
Who will we share this data with, where and when?
We will share your data with relevant third parties for the purposes set out above, in particular we will share details of intelligence about possible anti-doping rule violations or other possible doping activity you may provide with relevant Anti-Doping Organisations, other regulators and agencies (such as national and international governing bodies, law enforcement agencies, WADA, Major Event Organisers and other National Anti-Doping Organisations as necessary to action the intelligence).
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on behalf of UKAD for the purposes identified above. Such third parties include providers of website hosting, security services, and software hosting and support. Some of our suppliers may be separate data controllers, such as Coachwise Hub, our legal advisers and market research organisations. Some of these may provide you with their own privacy notice where appropriate.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request by contacting us using the details set out below.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where it would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This likely to be the Information Commissioner’s Office in the UK.
Data that is mandatory is indicated on relevant forms that you complete. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, obtain a service or otherwise engage with UKAD. All other provision of your information is optional.
How do I get in touch with you, or your data protection officer?
UKAD hopes that it can satisfy queries you may have about the way it processes your data. If you have any concerns about how your data is processed by UKAD, you can get in touch with UKAD’s Data Protection Officer at firstname.lastname@example.org or by writing to UKAD, Fleetbank House, 2-6 Salisbury Square, London, EC4Y 8AE.
How long will you retain my data?
We will retain details of intelligence we obtain from you in accordance with our Anti-Doping privacy notice.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data in connection with performing a contract, we keep the data for 7 years from your last interaction with us or from when the contract ends.
Where we process personal data to meet legal requirements, we hold this for as long as the law requires.
Effective Date: This Privacy Notice was updated on 24 May 2018 and is effective as of that date.