The United States Sports Academy will comply with the General Data Protection Regulation (GDPR) where and when required. The Academy’s GDPR policy will apply to all personal data processed. The Director of Technology will be responsible for maintaining the GDPR policy and updates. The Director of Technology will review the GDPR policy and GDPR requirements annually.
Data protection principles
The Academy is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
Lawful, fair and transparent processing
To ensire lawful, fair, and transparent data processing, the Sports Academy will mainting a Register of Systems that is reviewed annually. Individuals have the right to see their personal data when requested. The academy will process this information request in a timely manner.
Data processed by the Academy will be done on a lawful bases. These bases include consent, contract, legal obligation, vital interests, public task, or legitimate interests. Opt-in consent, when required, will be stored with personal data. Individuals have the right to revoke their consent when communications are sent based on user consent.
The Academy shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The Academy shall take reasonable steps to ensure personal data is accurate and kept up-to-date where necessary.
Archiving / removal
The Academy has archival and retention policies to ensure data is kept for an appropriate time according to lawful data retention requirements. Data is retained depending on the importance, nature, and need for the data. Data will be classified to identify the archival and retention needs.
The Academy will ensure that personal data is stored, processed, and transported securely using up-to-date software, encryption, and hardware. Access to data will be based on least privileges necessary and secured using standard security practices. Deleted data will be sanitized to ensure that information is not recoverable. Backup and disaster recovery measures are used to maintain accessibility and integrity of data. Security measures are documented in the United States Sports Academy’s Information Security Policy.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, the Academy shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to appropriate authorities.