General Data Protection Regulation - CGS Kids Virtual Triathlon
Information on the protection of children and their parents / guardians regarding the processing of personal data
Please read the following information carefully on the processing of personal data in the light of your child’s participation in daily sports activities of the CGS Sports Club, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and Greek legislation.
Categories of Personal Data subject to processing
The CGS Sports Club, as the Controller, processes (receives, maintains and uses) the following categories of personal data:
1) Your child’s data which is completed in the application-declaration of participation (full name, father’s name, mother’s name, school and age / year of study, etc.), as well as other personal data provided by current legislation
2) Your (as parents-guardians) contact information (name, telephone numbers, e-mail address, home address / mailing address) and any of our correspondence (printed or electronic) with you.
3) Photographs and/or videos of your child during his her attendance at the CGS Sports Club as well as from his/her educational, sporting, cultural and other activities, provided that you grant your consent in the next separate field.
Purpose of and legal basis for the processing
1) Your child’s participation in the sporting activities of the CGS Sports Club. In this case, the legal basis for the processing is the conclusion and execution of the contract between us, under which your child participates in the sporting activities of our Club, in combination with current legislation.
2) The organisation and coordination of our activities and management of our communication on issues related to the activities we provide you and your child. In this case, the legal basis is the fulfillment of our contractual obligations to you and the legitimate interest of our Club in response to any suggestions and special requests in order to both satisfy you with our activities and to make improvements.
3) Safeguarding the personal data of your child, other participants, employees, third parties and our Club. In this case, the legal basis for processing is our compliance with our legal obligations to you and third parties and the safeguarding of the vital legal interests of our Club to ensure the protection of the aforementioned goods (your child’s and third parties’) and to preserve its reputation as a safe place for the provision of sporting activities.
4) Your communication and information (and / or third party information) about the activities of the CGS Sports Club with newsletters that are sent to you via post, e-mail or SMS and social media sites. In this case, the legal basis is the legitimate interest of the CGS Sports Club on the one hand to inform you about activities that take place within the community and, on the other hand, to meet the obligation of caring for your child.
5) The use by you and your child – but also by the CGS Sports Club – as a memento and the promotion of the activities organized and conducted by the CGS Sports Club – of photos/videos of your child, but only with your prior explicit consent, also provides the legal basis for such processing.
Recipients of personal data:
The processing is limited within the CGS Sports Club and personal data will be available exclusively to our administrative staff, which is bound by an obligation to maintain confidentiality. The CGS Sports Club does not transmit your data to countries outside the EEA (European Economic Area).
Recipients of the data are:
(a) public authorities (The Inland Revenue, the Centre for Special Education or corresponding public bodies).
(b) judicial and prosecuting authorities in the event of a claim or criminal case.
(c) organisations with which the CGS Sports Club cooperates on a case-by-case basis within the framework of educational, sporting, cultural and other activities.
(d) CGS Sports Club’s external partners, such as photo and/or video service providers (in the event of your direct contract with any of these persons, please contact them to be informed of the terms of your data processing and the exercise of your rights), printers and editors of commemorative publications of the CGS Sports Club, lawyers, etc., who are bound by an obligation to maintain confidentiality, and only to the extent required to perform the specific tasks / instructions that everyone has in the context of the aforementioned purposes.
Personal data retention time:
The afore-mentioned personal data will be retained at the time specified for each of them in the applicable law and, in the event of a claim, for as long as is required for their irrevocable resolution.
On completion of your child’s sporting activity, the CGS Sports Club will retain your contact information for the purpose of informing and communicating with you regarding your child’s activities, unless the right of opposition is exercised, which is mentioned below in the next field.
Your child’s audio-visual material (photos / videos) will be retained for five (5) years from its receipt, unless you withdraw your consent earlier, provided in a separate field below, in which case it will be deleted immediately.Photos / videos on the CGS Sports Club Website and social media can be posted for a period not exceeding five years.
Parents’/guardians’ rights :
By means of a written request to the CGS Sports Club, you can, at any time, exercise the following rights:
(a) The right to access, namely to be informed as to whether the personal data concerning you and your child is being processed, and receive copies of this data as well as any other information concerning the processing carried out.
(b) The right to rectify and supplement inaccurate and incomplete data.
(c) The right to portability for all data we process on a legal basis by contract, law and consent (see Section 2 above).
(d) The right to request the deletion of data and/or a restriction on its processing,
(e) The right to object to:
(i) The sending of notifications via post, e-mail or sms, by sending us a relevant request to the the following e-mail firstname.lastname@example.org . In this event, we will cease sending updates.
(ii) The transfer of data to the insurance companies that provide us with liability and health insurance. In this event, if you exercise the right of objection, by sending us a relevant request to the following e-mail email@example.com ,we will consider whether the reasons you cite, and which must relate to your own particular situation, are in the interests of the CGS Sports Club for the transfer, which are mainly based on our obligation to meet our duty of care for the duration of your children’s stay at the CGS Sports Club, as well as if there are alternatives for the better protection of the data concerning you and your children.
(iii) The transfer of data to third parties for judicial use, always of course provided that the CGS Sports Club deems, after due consideration, that their granting is necessary and appropriate in supporting the rights of the (third party) before judicial authorities.
(iv) With regard to this, we inform you that, in the event that the transfer of data is necessary for the establishment, exercise or support of legal claims in court or out of court, the legal interests of the CGS Sports Club are superior and it is not possible to satisfy the right of any objection you may exercise.
(f) The right to withdraw, at any time, the consent you have granted for the editing of your child’s photos/videos.In addition, in case you consider that your personal data and that of your child’s are affected in any way, you can file a complaint with the Data Protection Authority (www.dpa.gr) at any time. However, we will be more than happy to give you the opportunity to resolve any issues that are of concern to you before you appeal to the Authority.
Data Processing and Communication Officer: For the exercise of your above rights as well as for any communication regarding personal data, please contact us (the CGS SPORTS CLUB, based in Pallini, Attica, GR-153 51) by email: firstname.lastname@example.org or by phone 210 6030411. Information and consent regarding the collection and editing of my child’s image (in photos and videos)
Information prior to consent:
1. The CGS Sports Club intends to receive and maintain commemorative photos and videos of your child from his/her attendance and participation in educational, sporting, cultural and other activities of the CGS Sports Club. Photos and videos are sent to you and may be published in CGS Sports Club publications and/or posted on the CGS Sports Club website (e.g. photos of sports teams, etc.) or on social media. What is more, the photos are printed in commemorative albums/forms that the CGS Sports Club publishes and distributes to all participants and their parents.
2. You are free to withdraw fully or partially your consent to the following at any time, so that your child’s corresponding photos and videos will be deleted. This obligation obviously does not exist for photographs that have been included in commemorative albums/publications of the CGS Sports Club. Moreover, in the case of photos/videos, which display more children, your possible refusal to consent to the appearance of your child or the subsequent withdrawal of your consent, does not imply the non-taking – or respectively the destruction- of the photos/videos, but only the blurring of the image (face and body) of your child so that it is not recognizable.
3. The withdrawal of consent does not affect the legality of the processing that has previously taken place (publication in an album, posting on the website, etc.).
In the event of the posting of photos/videos of your child on the CGS Sports Club website, i) it will be without the student’s name and surname, so that the photo/video will not be able to be connected to the personal data in general of the participant and ii) every effort will be made to ensure that our websites, which contain photos/videos in search engines, are not indexed. Furthermore, in the case of withdrawal of consent, we will take reasonable measures to inform the third party responsible for processing the data.