We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your time sailing and/or volunteering with us. This notice applies to you if you have registered to become or are a part of our voyage crew or a volunteer. There are other privacy notices for paid staff and donors. There is also a “young person-friendly” version of this document.
Our full Data Protection Policy is available here.
Ocean Youth Trust Scotland is A Company Limited by Guarantee (No. 193204) and Registered as a Scottish Charity (No: SC 029531).
We are not required to appoint a Data Protection Officer but our Data Protection Compliance Manager has overall responsibility for data protection compliance. Contact details are set out in the “Contacting us” section at the end of this privacy notice.
1. PERSONAL INFORMATION WE MAY HOLD ABOUT YOU
You may initially provide us with or we may obtain personal information about you, such as information regarding your:
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- personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers;
- date of birth;
- gender;
- details of next of kin, carer, and emergency contacts;
- identification documents such as passport and identity cards
- voyage start and end date;
- records of your interactions with us such as telephone conversations, emails, facebook and other social media, our website and other correspondence and your instructions to us;
- any credit/debit card and other payment details you provide so that we can receive payments from you and details of the financial transactions with you (for volunteers we may often refund out of pocket expenses)
- records of your attendance at any events hosted by us;
- images in video and/or photographic form and voice recordings;
- your marketing preferences so that we know whether and how we should contact you.
- records and assessment of your voyage including voyage outcome, Duke of Edinburgh reports, SQA Assessments.
- any disciplinary and grievance information.
2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:
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- information about your race or ethnicity,
- information about your health, including any medical condition, health and sickness records, medical records, health professional information and behavioural information
We may not collect all of the above types of special category personal information about you. In relation to the special category personal data that we do process we do so on the basis that
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- it is based on your explicit consent.
- it is necessary for the establishment, exercise or defence of legal claims;
- it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection
In the table below we refer to these as the “special category reasons for processing of your personal data”.
We may also collect criminal records information about you. For criminal records history we process it on the basis of legal obligations or based on your explicit consent.
3. WHERE WE COLLECT YOUR INFORMATION
We typically collect personal information about our voyage crew when you apply to sail with us, when you purchase any services or products we offer, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.
We also occasionally may collect personal information about you from any third party references you provide or contact with the person who may have booked your voyage, such as a school, group leader, carer, parent etc.
If you are providing us with details of referees, next of kin, family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with them.
5. USES MADE OF THE INFORMATION
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.
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Purpose |
Personal information used |
Lawful basis |
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To administer sailing with us and managing our relationship with you, including dealing with payments and any support, service or product enquiries made by you |
All contact and membership details, emergency contact, transaction and payment information, records of your interactions with us, and marketing preferences. |
We need this information to be able to perform and administer your contract with us to come sailing and/or as a volunteer. We have a legitimate interest to use contact information to process your voyage booking, This is necessary to enable us to properly manage and administer your time with us. Emergency contact details and payment records are given and used with your consent. |
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To maintain accurate crew lists and records of who is sailing and sailed with us |
Contact details, date of birth, passport or identity details, Records of your interactions with us. |
We need this information to be able to perform and administer your contract with us to come sailing and/or as a volunteer We have a legitimate interest in knowing and identifying those who sails with us to ensure we remain within our legal carrying capacity and age restrictions; to ensure safe manning and the safety of those who sail with us, including compliance with safeguarding practice. Occasionally we have to provide this information to an external organisation such as race organisers or harbour officials. On certain voyages there is a legal obligation for us to provide this information to immigration and other government agencies. |
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To send you other marketing information we think you might find useful or which you have requested from us, including our newsletters, information about membership, events, products and information about our commercial partners |
Contact details and marketing preferences. |
Where you have given us your explicit consent to do so. |
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To answer your queries or complaints |
Contact details and records of your interactions with us |
We have a legitimate interest to provide complaint handling services to you in case there are any issues with your voyage. |
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Retention of records |
All the personal information we collect. |
We need this information to be able to fulfil our contract with you. We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your time sailing with us and in some cases we may have legal or regulatory obligations to retain records. We also retain details which would allow us to confirm to external parties, if required, information about who sailed with us. For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
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To conduct data analytics studies to better understand voyage attendance and trends |
Records of your attendance on any voyages or at any events hosted by us. |
We have a legitimate interest in doing so to ensure that our voyages meet our charitable aims and objectives and plan for the charity’s future including strategic planning |
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For the purposes of promoting OYT Scotland |
Images in video and/or photographic form. |
Where you have given us your explicit consent to do so. |
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To comply with health and safety requirements
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Records of attendance, medical information about your health, behaviour information
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We have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate in sailing. |
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Dealing with legal disputes involving you, or others including accidents |
All non-‘special categories’ of personal information |
We have a legitimate business interest to ensure that all legal claims are managed effectively. |
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To report to donors, funding partners |
Voyage details, voyage reports, outcome wheel statistics, health and background information |
We have a legitimate interest to ensure your voyage is funded in whole or part. This includes reporting back to donors and funding partners, this may be a condition of their grant funding. Unless we otherwise have your consent all reports are anonymised. |
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To report to schools , care workers, social workers and other referrers |
Voyage details, voyage reports, outcome wheel statistics, health and background information |
If your voyage was arranged by a school group or third party it is likely we will have to report back to them about your voyage. We have a legitimate interest in doing so as this is part of the benefit of what we offer you and the referring party and will in part be the reason the voyage was arranged. |
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To use information about your physical or mental health (including any injuries) or disability status, to ensure your health and safety and to assess your fitness to participate in sailing with us and to provide appropriate adjustments to our voyage |
Health and medical information |
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. We do this on the basis of your consent. |
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For the purposes of equal opportunities monitoring |
Name, title, date of birth |
We have a legitimate interest to promote a sports environment that is inclusive, fair and accessible. |
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To comply with legal obligations, for example, regarding people working with children or vulnerable adults to comply with our safeguarding requirements |
Information about your criminal convictions and offences |
For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
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Additionally for Volunteers |
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Making a decision about your appointment as a volunteer and managing the appointment process |
All the personal information we collect from you as part of the application process. |
We need this information to be able to perform and administer your contract with us as a volunteer. We have a legitimate interest and a legal obligation to ensure that our volunteer staff are capable of working safely at sea and with young or vulnerable people. |
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For the purposes of ensuring the security of our systems and information as well as member/customer information |
Use of our information and communications systems, including the computers and fixed and mobile phones that we allow you to use. |
We have a legitimate business interest in ensuring our systems are secure. |
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To send you information about volunteering opportunities, technical and safety notices or other significant notices regarding our operations |
Personal contact details such as name, title, email addresses and telephone numbers |
We have a legitimate interest in ensuring you are kept appraised of any significant matters relating to our Safety Management Systems, operations or volunteering with us |
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To gather evidence for possible grievance or disciplinary hearings |
All the personal information we collect |
We have a legitimate interest in doing so to provide a safe and fair environment for all those who sail with us and to ensure the effective management of any disciplinary hearings, appeals and adjudications. |
If you chose not to provide us with the personal information we have asked for then we may not be able to let you sail or volunteer with us.
Where you have given us your consent to use your personal information, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below. Please note the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information on bases other than your consent. Withdrawing consent may mean we are no longer able to let you sail.
5. DIRECT MARKETING
A regular e-newsletter is our primary means of direct marketing. You will be given an opportunity to consent to receiving this. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the messages we send to you.
6. DISCLOSURE OF YOUR PERSONAL INFORMATION
We share personal information with the following parties:
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- Any party approved by you.
- Our governing bodies such as the RYA, ASTO, Duke of Edinburgh, Scottish Qualification Authority (SQA), Institute for Outdoor Learning and race organisers such as Sail Training International.
- Other service providers:for example, our newsletter distributor (but only with your consent and only for the newsletter); we use Office 365 for email and documentation retention; and jotform for your booking. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.
- Organisations who provide funding: for the purposes of helping you sail with us (information for donors is anonymized unless we have specific consent otherwise).
- Any medical authorities should you require treatment.
- Our insurers should the need arise
- We will not share it with anyone else unless there is a legal or regulatory obligation to do so.
7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY
The personal information we collect is not transferred to and stored in countries outside the UK and the European Union.
8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?
The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements.
Generally, where there is no legal requirement we retain all physical and electronic records up to your 26th birthday or 4 years from your last voyage with us if you are over the age of 22. We will retain the names of people who sailed with us, their date of birth, and the dates they sailed indefinitely so any future query by an outside party as to who sailed with us can be answered if necessary.
Information that may be relevant to personal injury or discrimination claims or child welfare concerns may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after the event.
Volunteers and paid staff personnel files and training records (including disciplinary and working time records) will be kept for six years after employment / volunteering ceases unless there are concerns about the behaviour of an adult who was working with children or vulnerable people, where they may have harmed someone, committed an offence, or their behaviour indicates they are unsuitable to work with children or vulnerable people. In this case records will be retained until normal retirement age or ten years if that is longer.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, Contact us by using the details set out in the “Contacting us” section below.
9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
As a data subject you may have the right at any time to request access to, rectification or erasure of your personal data; to restrict or object to certain kinds of processing of your personal data, including direct marketing; to the portability of your personal data. To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details at the end of this Privacy Notice
If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office. More information about your legal rights can be found on the Information Commissioner’s website.. We are here to help and encourage you to contact us to resolve your complaint first.
10. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so.
In the event of any query or complaint in connection with the information we hold about you, please email the Chief Executive at office@oytscotland.org.uk or write to us at Ocean Youth Trust Scotland, Room 21, Victoria House, 5 East Blackhall Street, Greenock, PA15 1HD.