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Anti-Doping Privacy Notice

Summary of how and why UKAD uses your data

• The UK Parliament has ratified the UNESCO International Convention Against Doping in Sport, thereby formally committing the UK to the pursuit of doping-free sport based on the principles set out in the World Anti-Doping Code (‘the Code’).

• UKAD is the National Anti-Doping Organisation for the UK, and we process personal data (including sensitive personal data/special category data, such as data relating to Athletes' health and physical condition) to fulfil our regulatory functions under the UK National Anti-Doping Policy and the UK Anti-Doping Rules. This processing is done in exercise of our public interest functions– primarily, for the purposes of eliminating doping in sport.

• Data may be shared with a number of third parties. We share data with the World Anti-Doping Agency (WADA), notably through ADAMS (a web-based data management system developed and administered by WADA), so that it can fulfill its own role under the Code. We also share data with Anti-Doping Organisations as defined in the Code, including other National Anti-Doping Organisations i.e. those in other countries, International Federations, the International Olympic Committee, the International Paralympic Committee and Major Event Organisations, and other relevant organisations, including the National Olympic Committees, National Paralympic Committees, Commonwealth Games Associations, the home country Sports Councils and sports’ national governing bodies. We also share information with the police and other law enforcement agencies, and other relevant regulators and authorities.

• UKAD will share data overseas, both with WADA in Canada and Switzerland using ADAMS, and as necessary with other Anti-Doping Organisations where this is as a result of an Athlete’s travel or competition, or as necessary to share appropriate information and/or intelligence.

• This summary is expanded upon below, where further detail is provided of UKAD’s data processing, as well as details of your data protection rights, your right to object to certain processing, and details of how we ensure the adequacy of international transfers.

• As the National Anti-Doping Organisation for the UK, in most instances UKAD will be the sole data controller for the personal data it collects and processes about you. In some circumstances, we may agree to share responsibility with another organisation within a particular sport or competition.

• In particular, if you are a participant in football, we share responsibility with The Football Association. More information on The FA’s use of your data can be found in their anti-doping privacy policy (available from FASOs and on The FA’s website).

• In some circumstances, we may provide services to other Anti-Doping Organisations – we will make it clear, in these circumstances, which entity is the controller, but may make use of our own Doping Control Forms. The Anti-Doping Organisation with testing authority will provide more details of how they use your data in their own privacy notices.

• Where we carry out Out-of-Competition testing and this reveals the presence of social drugs that are not prohibited under the UK Anti-Doping Rules unless present in a sample taken In-Competition, these results will be shared where this is requested by a relevant governing body. Such governing bodies may have policies or rules in relation to social drug use Out-of-Competition. See the privacy policies of your relevant governing body to find out more about how such data may be processed.

• UKAD seeks Athletes’ consent for the retention of their samples for research purposes after samples would otherwise be destroyed. Where an Athlete agrees, their anonymised sample will be shared with WADA–accredited laboratories to undertake anti-doping research in the pursuit of enhancing the analytical capabilities used to uphold clean sport. Athletes can withdraw this consent at any time until their sample is anonymised. No adverse conclusions will be drawn if an Athlete refuses to provide such consent, or withdraws it.

Further detail

What does this notice cover?

This notice describes how UKAD, as the National Anti-Doping Organisation for the UK, may make use of your data that is collected to fulfil its regulatory functions under the Code, the UK National Anti-Doping Policy and the UK Anti-Doping Rules.

This notice describes your data protection rights, including a right to object to some of the processing which UKAD carries out. More information about your rights, and how to exercise them, is set out below in the “What rights do I have?” section.

As the National Anti-Doping Organisation for the UK, in most instances UKAD will be the sole data controller for the personal data it collects and processes about you. In some circumstances, we may agree to share responsibility with another organisation within a particular sport or competition, or provide anti-doping services to another organisation. We will make it clear if we are carrying out testing or other processing only on behalf of another Anti-Doping Organisation.

In particular, if you are a participant in football, we share responsibility with The Football Association. More information on The FA’s use of personal data – and how our functions are divided - can be found in their anti-doping privacy policy (available from FASOs and on The FA’s website).

What information does UKAD collect?

UKAD collects and processes personal data about Athletes and Athlete Support Personnel, as well as other relevant individuals whose information may be provided to us as part of intelligence about Athletes and Athlete Support Personnel.

The information collected directly by UKAD includes data provided in a Doping Control Form and produced as a result of any sample you provide, any information you provide to fulfill your whereabouts obligations, and any information provided as part of a therapeutic use exemption (TUE) application.

This information includes (but is not limited to) your name, nationality, date of birth, gender, the sport(s) you participate in, your level of competition, details of your testing pool (if any), details of any Athlete Biological Passport data, testing results and previous doping sanctions.

Should you return a positive test, or if your sample requires further analysis or investigation, then further information may be gathered from you, including any information you provide to us in defence of a charge for an Anti-Doping Rule Violation or as evidence of mitigating circumstances.

What information is provided by third parties for anti-doping purposes?

We actively co-operate with Anti-Doping Organisations as defined in the Code, including other National Anti-Doping Organisations i.e. those in other countries, International Federations, the International Olympic Committee, the International Paralympic Committee, WADA and Major Event Organisations, and other relevant organisations, including the National Olympic Committees, National Paralympic Committees, Commonwealth Games Associations, the home country Sports Councils and sports’ national governing bodies. We also share information with the police and other law enforcement agencies, and other relevant regulators and authorities.

Whenever another organisation has a reason to believe that we need information relating to you, we may receive information from them. 

Information may also be provided by a number of other third parties. For example, we may receive intelligence on doping matters from the media, from members of the public, and from competition organisers. We may also obtain information about you from third party providers who collate publicly available and demographic information, for the purpose of improving the accuracy of our data and our intelligence-led testing and enforcement.

Where you choose to involve a third party such as a lawyer, independent expert, trade union representative or relative, we may also receive information from them.

How does UKAD use this information, and what is the legal basis for this use?

UKAD will use this information for the following purposes:

i. As required to pursue and exercise its public interest functions, in particular:

• planning, targeting, co-ordination and organisation of anti-doping tests

• collecting and analysing samples that you provide as part of the Doping Control process

• the creation and management of a blood passport (Athlete Biological Passport)

• reviewing and assessing information and evidence you provide and managing  applications for, and the granting of, of TUEs

• communicating with you or about you where necessary to manage and enforce the UK National Anti-Doping Policy and the UK Anti-Doping Rules. This includes informing relevant governing bodies and – where you are a professional Athlete or Athlete Support Personnel – your employer, of our intention to bring a charge for an Anti-Doping Rule Violation

• collecting and maintaining intelligence we receive on Athletes and Athlete Support Personnel, and where necessary using this and other information to conduct investigations into potential Anti-Doping Rule Violations

• analysis of results and intelligence, to help us improve our enforcement and educational activities

• applying and enforcing the UK Anti-Doping Rules, including conducting results management, issuing charges and bringing proceedings before the National Anti-Doping Panel for an Anti-Doping Rule Violation, and sharing relevant data with relevant third parties as set out in this notice

• maintaining records of UKAD’s anti-doping missions and test outcomes, and Athletes who have failed to be available for tests at the designated time or provided inaccurate whereabouts information (Whereabouts Failures)

• publishing our decisions, those of the National Anti-Doping Panel and those of other relevant bodies (for example, International Federations or other National Anti-Doping Organisations) in anti-doping cases, for the purposes of ensuring transparency and to comply with the UK National Anti-Doping Policy and the UK Anti-Doping Rules

ii. For purposes required by law, in particular:

• in response to requests by government or law enforcement agencies conducting an investigation

iii. Where you have given your consent, in particular:

• we may anonymise and share your sample with WADA-accredited laboratories to undertake anti-doping research in the pursuit of enhancing the analytical capabilities used to uphold clean sport
• we may share data with and receive information from other third parties you wish to involve in any investigation or charge, such as an expert witness, lawyer, trade union representative or relative

For all of these purposes, we may be required to process your sensitive personal (or 'special category') data - we do this for the purposes of eliminating doping in sport. If an Athlete refuses to provide a sample, or to provide other relevant information on request, this may be an Anti-Doping Rule Violation and might lead to a ban on participation in sport.

How is data shared, where and when?

Data may be shared with a number of third parties. We share data with WADA, notably through ADAMS (a web-based data management system developed and administered by WADA), so that it can fulfill its own role under the Code. We also share data with Anti-Doping Organisations as defined in the Code, including other National Anti-Doping Organisations i.e. those in other countries, International Federations, the International Olympic Committee, the International Paralympic Committee and Major Event Organisations, and other relevant organisations, including the National Olympic Committees, National Paralympic Committees, Commonwealth Games Associations, the home country Sports Councils and sports’ national governing bodies. We also share information with the police and other law enforcement agencies, and other relevant regulators and authorities.

We will also publish certain information, and/or share it with the media, about Anti-Doping Rule Violation investigations, provisional suspensions or charges, and decisions in Anti-Doping Rule Violation cases issued by UKAD, the National Anti-Doping Panel and other relevant bodies (for example, International Federations or other National Anti-Doping Organisations).

Information of a positive test may also be shared with your employer, if relevant, who may be involved in coordinating your response to any charge. You may choose to involve other third parties in your response to a charge or investigation (in particular, you may choose to involve external lawyers, trade union representatives or relatives). We may share information with that third party where you have given you consent.

Personal data may be shared with police and other law enforcement agencies, government and/or other relevant organisations, regulators and authorities as necessary, if mandated by law or if required for the protection or furtherance of our legal or legitimate interests in compliance with applicable laws. This includes sharing information with the police and relevant professional regulators where there is evidence of criminal conduct or professional misconduct. We will also share information with our legal advisors and the National Anti-Doping Panel where we seek to apply or enforce the UK Anti-Doping Rules.

Personal data may also be shared with third party service providers, who will process it on behalf of UKAD for the purposes identified above. This includes the providers of WADA-accredited laboratory services, UKAD's IT service providers and Sample Collection Agencies that we use to conduct testing overseas and that are not signatories to the Code, for example PWC, IDTM and Clearidium.

Where we carry out Out-of-Competition testing and this reveals the presence of social drugs that are not prohibited under the UK Anti-Doping Rules unless present in a sample taken In-Competition, these results will be shared where this is requested by a relevant governing body. Such governing bodies may have policies or rules in relation to social drug use Out-of-Competition. See the privacy policies of your relevant governing body to find out more about how such data may be processed.

UKAD will share your data overseas, both to WADA in Canada and Switzerland using ADAMS, and as necessary with other Anti-Doping Organisations overseas where this is as a result of an Athlete’s travel or competition, or as necessary to share appropriate intelligence.

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, and where no exemption applies, 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 – you can ask for this using the contact details below.

In the case of transfers to WADA and International Federations based in Switzerland, data is in these cases transferred to countries considered to adequately protect data under an EU adequacy decision.

What rights do I have?

You have the right to ask us for a copy of your personal data and to correct, delete or restrict (stop any active) processing of your personal data. 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 legal requirement).

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 interests in keeping.  Relevant exemptions are included in both the General Data Protection Regulation (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 UKAD – which you can do through our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to the Information Commissioner’s Office.

Where we require personal data to perform our functions as an Anti-Doping Organisation under the Code and the UK Anti-Doping Rules, including the collection of information on a Doping Control Form, whereabouts details and information we seek following analysis of a sample, then provision of such data is mandatory: if you fail to provide information you are obliged to provide under the Code OR UK Anti-Doping Rules then this may itself be an Anti-Doping Rule Violation.  In all other cases, provision of requested personal data is optional and will not have consequences you refuse to provide this data.

How do I get in touch with UKAD, or its data protection officer?

We hope that we can satisfy any queries you may have about the way we process 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 ukad@ukad.org.uk  or by writing to UKAD, Fleetbank House, 2-6 Salisbury Square, London, EC4Y 8AE.

How long will you retain my data?

Your doping control-related data will be stored by WADA in ADAMS in accordance with the WADA International Standard for the Protection of Privacy and Personal Information. UKAD will also store doping-control data in ADAMS in accordance with this Standard. In practice, this involves retention for a period of ten years following the provision of any sample, being the period within which a charge may be brought following an Anti-Doping Rules Violation pursuant to the Code or the UK Anti-Doping Rules. UKAD retention periods are in line with the WADA International Standard for the Protection of Privacy and Personal Information, with the exception of TUE application forms and supporting medical evidence which will be retained for a period of 5 years. This is in case of associated legal challenge to a decision.

Information relating to intelligence gathered in relation to anti-doping matters, and details of any actions or decisions taken by UKAD to apply or enforce the Code, UK National Anti-Doping Policy and UK Anti-Doping Rules will be regularly reviewed. If we consider that ongoing retention is justified, we will continue to retain relevant information until at least the next review. We will also review the information we hold about you at the end of any investigation or case to ensure this remains relevant. For particularly serious cases, and where you may have an ongoing role in sport, we may inevitably hold information indefinitely, but this will remain subject to review.  We aim to hold your personal data for only as long as it is needed.

If you have been sanctioned by UKAD and subject to a period of Ineligibility, your whereabouts information shall be retained by UKAD for the duration of that period of Ineligibility. Otherwise, any whereabouts information is only retained in ADAMS for 18 months.

Where we publish information relating to a decision made by the National Anti-Doping Panel, we will remove this information from our website at the end of the longer period of either one month or the length of any ban being served.

Capitalised terms used in this notice are used as defined in the Code or the UK Anti-Doping Rules, as appropriate.

Download the Anti-Doping Privacy Notice here

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