Mountain Training Privacy Notice

Who we are

Mountain Training UK & Ireland is an awarding body and the coordinating organisation for five Mountain Training organisations that administer leadership qualifications and training schemes in walking, climbing and mountaineering: Mountain Training Cymru, Mountain Training England, Mountain Training Scotland, Mountain Training Board Ireland and Mountain Training UK & Ireland.

Collectively these organisations are referred to publicly as ‘Mountain Training’.

Mountain Training UK & Ireland is responsible for managing the Mountain Training website and the data stored in the Candidate Management System (the ‘System’).

The System is actually software as a service. The system intellectual property is owned by Pathfinder Systems Limited and the software is developed and operated by Tahdah Verified Limited. When we refer to the ‘System’, we mean the part of the software that contains personal data relating to Mountain Training candidates and association members as detailed below. It is accessed via the following url: https://mt.tahdah.me.

As well as Mountain Training candidate training records, the System stores membership information for the four associations: the Mountain Training Association (MTA), the Association of Mountaineering Instructors (AMI), the British Association of International Mountain Leaders (BAIML) and British Mountain Guides (BMG).

• The Mountain Training Association is the membership section of Mountain Training UK & Ireland. It is an optional membership association designed to support those who hold or are working towards all Mountain Training qualifications.
• The Association of Mountaineering Instructors is the representative body for professionally qualified Mountaineering Instructors in the UK and Ireland.
• The British Association of International Mountain Leaders is the UK-based representative body for International Mountain Leaders. It is a member of the Union of International Mountain Leader Associations (UIMLA).
• British Mountain Guides is the UK-based representative and awarding body for Mountain Guides. It is a member of the International Federation of Mountain Guide Associations (IFMGA).

Mountain Training UK & Ireland will be a “controller” of the personal information that candidates provide to us through the System, unless otherwise stated, on behalf of its constituent Mountain Training organisations named above.

What we need

When you create an account on the System we will ask you for the following personal information:

• First name
• Last name
• Date of birth
• Email address

If you would like to register on one of our schemes we will ask you for the following personal information:

• Emergency contact name and phone number
• Billing address and delivery address
• Equality information

You can choose to share the following special categories of data with us to enable us to tailor communication and monitor the diversity of the candidates on our schemes. It can be removed by you, the candidate, at any point:

• Gender
• Honours (CBE, OBE etc.)
• Ethnic origin
• Business/personal website
• Main phone number
• Alternative phone number
• Languages spoken
• Special requirements

Under 16s

There are two mechanisms through which we process information about candidates who are under 16:

• If you are under 16, we will process limited personal data about you (first name, last name, date of birth, gender), entered on to the System by the provider of your course. The course provider is required to obtain the necessary consent from a parent/guardian.
• If you are the parent or guardian of a child under 16, we may process limited personal data about you so that you can give consent for your child to access Mountain Training schemes. We may use your contact details to communicate with you about the child’s account or use of services.

Why we need your personal information – legitimate interests

Candidate personal data:

We process our candidates’ personal information in pursuit of legitimate interests to:

• develop and maintain an accurate record of our candidates’ qualifications and skills scheme attendance. This includes the completion of course reports by approved course directors, sending email communications to inform you of upcoming courses, renewal requirements and verify that you have completed any mandatory training requirements;
• develop and maintain an accurate record of our candidates'/members' workshop attendance;
• monitor candidate engagement and participation in walking, climbing and mountaineering activities through the use of the digital logbook (DLOG) and inviting our candidates to participate in surveys for researching and development purposes;
• respond to and communicate with candidates regarding questions, comments, support needs or complaints, concerns or allegations in relation to our schemes. We will use your personal information to investigate your complaint or appeal in line with our complaints and appeals policies.

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us on info@mountain-training.org. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for the benefit of you as a candidate.

Why we need your personal information – equality monitoring requirements

We are required by Sport Scotland, Sport England and Sport Wales to use our candidates’ personal information relating to gender, racial or ethnic origin or disability status for equality monitoring purposes.

We will process such personal information through aggregated and anonymised reports to identify and keep under review the existence or absence of equality of opportunity or treatment between groups of people within the same categories to promote or maintain equality within our sport.

Why we need your personal information – marketing

If you would like to receive email marketing communications from us, please select your preferences from the Subscriptions page within your account.

You may change your preferences at any time or request that we stop sending you email marketing communications by logging in to your account at https://mt.tahdah.me. There is also an ‘unsubscribe’ button at the bottom of every email communication we send.

Other uses of your personal information

We may ask you if we can process your personal information for additional purposes. For example, we may prompt you to fill in more information to help us with an impact report. Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes and it will always be optional.

Who we share your personal information with

We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include the Health & Safety Executive, The Disclosure and Barring Service, Disclosure Scotland, and the Police for the purposes of safeguarding children and vulnerable adults.

We may also share personal information with our professional and legal advisors for the purposes of seeking advice or legal counsel.

In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

Payment processing

Mountain Training UK uses the System to administer our candidate database, as part of which Tahdah contracts third party payment providers to process your payments on our behalf. Tahdah and its payment providers process candidates’ personal information on our behalf as “processors” and are bound by written contractual conditions to only process that personal information under our instructions and protect it.

Mountaineering council membership

You can use the System to join a mountaineering council (British Mountaineering Council (BMC), Mountaineering Scotland or Mountaineering Ireland). If you choose to do this, the System will share some of your basic personal data with the mountaineering council and you will be entering into a contract with them.

Association membership

The System stores membership information for the four associations named above. The associations use the System to communicate with their members and manage their membership services. As a Mountain Training candidate you can use the System to join an association and manage your membership. If you choose to join an association you are entering into a contract with the association. The association is able to view the personal data of its members on the System.

At certain stages of the qualification pathway, an association may offer you complimentary membership for a period of time. In this instance, you will be notified by email from Mountain Training and have the option of accepting the complimentary membership or not.

Association services

All of the associations contribute to a joint association magazine, The Professional Mountaineer, which is printed and posted to members by Vertebrate Publishing (‘Vertebrate’). Mountain Training shares a list of members’ names and delivery addresses with Vertebrate on a quarterly basis for this sole purpose. The mailing lists are not stored for longer than is necessary.

Mountain Training Association and Association of Mountaineering Instructors members receive a membership card. These cards are printed by Elemental who accesses the System to download a list of membership letters, delivery address labels and print the cards. Elemental is only able to access this information and it is for this sole purpose. Any files downloaded are not stored for longer than is necessary and are securely destroyed once no longer necessary.

How we protect your personal information

Candidate personal information is stored on the System and the servers are based in the European Union. The System is accessed by our staff, approved providers and administrators for the purposes set out above.

We are required to transfer your personal information outside the European Union if you attend an International Mountain Leader course in Switzerland. Switzerland is regarded by the European Commission as having an adequate level of protection for personal data and your information will only be transferred when an approved course director accesses the system to view your DLOG or complete a course report.

How long we keep your personal information

We will keep your personal information for as long as necessary to provide you with services and in line with our legitimate interests outlined above. Unless you ask us not to, we will review and possibly delete your personal information in the case an account has been created on the system and no further action has been taken after one year.

We will keep certain personal information of candidates for longer in order to confirm your identity when you purchase something from our shop or complete a training/assessment course. We need to do this to comply with the Companies Act 2006, which requires us to keep financial records.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold. This sets out different retention periods and you can request a copy by contacting us at info@mountain-training.org.

Your rights

You can exercise any of the following rights by writing to us at info@mountain-training.org or by logging on to your account at https://mt.tahdah.me.

Your rights in relation to your personal information are:

• you have a right to request access to the personal information that we hold about you by making a “subject access request”;
• if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information;
• you have a right to request that we restrict the processing of your personal information for specific purposes; and
• if you wish us to delete your personal information, you may request that we do so. We do not have to comply with this request if you have gained a qualification, however, we may agree to anonymise some of your personal details.

Any requests received by Mountain Training UK will be considered under applicable data protection legislation and we will need to check your identity before taking any action. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner’s Office at www.ico.org.uk