Torbay Sea School Data Protection and Privacy Policy
If you feel that we are not abiding by our posted privacy policy, you should contact;
Torbay Sea School LLP – Tel: 01803 665556 Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

1 Information Collection and Use
Torbay Sea School LLP is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others in anyway. Torbay Sea School LLP collects information from our users at different points on our website.
2 Lawful, fair and transparent
2.1 TSS collects your personal data on the basis of:
2.1.1 Consent - you consent for us to process your data
2.1.2 Contract – the processing of your data is necessary for the fulfilment of the provision of training
2.1.3 Legitimate Interests – it is necessary for us to process your data in order for it’s use in certification registration and for safety purposes
2.2 Your data is collected to allow TSS to:
2.2.1 Provide appropriate and safe training – TSS must be aware of any medication, medical problems or dietary requirements
2.2.2 Maintain communication with you (via email, telephone of post)
2.2.3 Register a certificate you hold, issued to you by TSS, with the RYA to prove its’ validity
2.2.4 Register you onto the RYA Interactive site in order for you to complete and RYA Interactive training course
2.3 Your data will be treated in confidence by TSS employees only, and stored electronically using:
2.3.1 Microsoft Office – Outlook
2.3.2 Mail Chimp
3 Data minimisation
3.1 TSS will only collect the following details through an online booking form:
3.1.1 Type and Date of the course you have booked on
3.1.2 Full name
3.1.3 Date of birth
3.1.4 Postal address
3.1.5 Email address
3.1.6 Phone number
3.1.7 Next of Kin name, relationship and contact details
3.1.8 Dietary requirements
3.1.9 Regular medication
3.1.10 Medical/health problems
3.1.11 For own boat tuition only Boat name Boat make and model Boat berth and marina
3.2 TSS will collect the following details through an online feedback form:
3.2.1 Type, location and date of the course you attended
3.2.2 Full name
3.2.3 Email address
3.2.4 How you found out about TSS
3.2.5 Your opinion of: General content of the course Relevance of the material covered Amount of material covered The assessment (if any) Whether the course met your expectations Whether you found the course informative Your favourite part of the course Subjects which could be covered in more detail Subjects which could be covered in less detail The instructor’s positivity and effectiveness The instructor’s answers to your questions The information provided to you throughout the course Organisation of the course Presentation of the course The training room or boat Sailing area Quality of food Quality of accommodation Quality of service Information you received prior to the course Administration of the course Your personal preparation for the course And other comments

4 Accuracy
Data held by TSS will be kept up to date by correspondence with you, and by requiring you to complete a booking form for each booking you make to ensure details are as current as your latest booked course.
5 Storage
Your data will be stored by TSS for a minimum of 12 months.
Previous paper copies of details will be archived for 5 years.
Digital copies of your data will be kept for a maximum of 12 months from the date you have provided it.
Upon successful completion of your RYA course* with Torbay Sea School, your name, contact details, date of birth, certificate number and date of issue will shared with the RYA through a secure web portal on The data will be stored on the RYA’s central database. This information allows the RYA to record your qualification, to update any records they may hold for you, and to verify or replace your certificate if required. For further information on how the RYA will deal with your data, please see the RYA’s Privacy Policy at
*This only applies if you have successfully achieved one of the following certificates: Day Skipper Practical Sail, Day Skipper Practical Motor, Coastal Skipper Practical, Level 2 Powerboat Handling, Intermediate Powerboat Handling or Advanced Powerboat Handling Course Completion Certificate.
Upon successful completion of any course with TSS where you have been awarded a certificate or license, youre name, certificate number and date of issue will be stored for up to 5 years. This information allows us to verify or replace your certificate if needed. Data sharing
5.1 Directly with the RYA
As a Recognised Training Centre (RTC), TSS is required to share certain data with the RYA and the RYA to share certain data with TSS. In the case of such shared data, both TSS and the RYA will be Data Controllers.
Data will only be shared in line with the requirements in the RYA’s Recognition Guidance Notices. The data will be retained by the RYA in line with the RYA’s Privacy Notice.
Data shared by the RYA with TSS will only be used for the stated purpose, for example lists of instructors available for work should not be retained for longer than is needed to engage an instructor for that job.
Both the RYA and TSS will individually be data controllers for the data they hold on students of TSS and will be independently responsible for:

5.1.1 The robustness of their data systems;
5.1.2 Their own data breaches and informing the other party about data breaches;
5.1.3 Respecting the rights of the data subject.
5.2 RYA interactive site
To enable access to your online course we need to share some of your personal data with the RYA via your user profile in This learning management website is hosted and maintained by a third party called Learning Pool, who will not use your personal information for any reason other than enabling your course.

Your name and email address will be entered on in order to create your user account. On your first access to the site, you will be asked to enter your address and date of birth. You will have access to the site for one year in order to complete your online course. During this period, your personal information will be held on the website by Learning Pool and be available to this training centre and the RYA for the purpose of managing your course.

Instructional support will be provided by this training centre for a period of 12 months from the date of your course booking.

On completion of your course, your name, email, date of birth and address will be transferred to the RYA's central database for the purpose of recording details of the course and any certification you gain as a result of it. This information allows the RYA to record your certification, to update any records they may already hold about you or your qualifications and to verify your certificate if required.

After one year from the date of your enrolment on a course, your user account will be removed from

Full details of how the RYA will deal with your personal information will be displayed when you first access

For the duration of your access to the site, your data will be held in accordance with the RYA Interactive Data Policy, Terms and Conditions.

If you receive a digital certificate downloaded from the RYA Interactive site on completion of your course, your name, address, date of birth and certificate details will be transferred to the RYA database and held in accordance with the RYA’s Privacy Policy.
5.3 Visitors to our websites
When someone visits we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
5.4 E-newsletter and Feedback forms
We use a third party provider, MailChimp, to deliver our online feedback forms and monthly e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice.
5.5 People who email us
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
6 Booking process
To book onto a course you will be required to fill in an online course booking form. Within this form, you must inform TSS of any medical/health/dietary conditions or requirements you have. This form will either be hosted on our website using the programme VikEvents, or on GoogleForms. All access to data input by these methods is password protected and protected by VikEvents and Google’s Privacy Policies.
You will be emailed confirming your place on your chosen course and relevant payment details. If you have not already been in correspondence with a member of TSS staff to confirm that you meet any pre-requisites for this course.
6.1 Fitness to take part and health declaration
To enable you to judge their fitness to take part in any particular course, TSS will give a clear picture of what is involved in the course. This will be specific to the nature of TSS’ operation, the craft TSS uses and the area that TSS operates in.
You are advised to seek medical advice if you are in any doubt of your ability to participate.
TSS will only record what is necessary to ensure the appropriate adjustments or measures are in place.
The process is two-fold:
6.1.1 At the time of booking, you will be asked if there is any medical or other reason why you may require some special consideration. This includes: Dietary requirements Regular medication Medical/health problems
6.1.2 At the time of the course, you will be asked about any needs or condition you have specified to TSS within this form to allow for confirmation of your needs and the structures put in place by TSS to cope with this. This specific information will only be held for the duration fo the course.
6.1.3 When providing details of any requirements, needs or conditions you have, you will explicitly asked for your consent for the use of that information, with a link to this Data Protection Policy included in this option.
7 Joining Letters
You will be sent a joining letter once some form of payment has been received. This will be attached to an email (if one is provided) or posted (if no email address has been given and no alternative arrangements made).
This will include the time and place of the course, contact details for late arrival and guidance for main items to bring with you (such as warm clothing, protective clothing, hats, gloves, sun screen, pen and notepad etc.).
8 Cancellation
TSS’s cancellation policy, as stated in TSS’s terms and conditions, is:
“4. Amendment and cancellation by you
4.1. TSS will make every effort to assist you if you wish to alter any previously agreed arrangements. Requests must be made in writing or by fax and signed by the signatory of the booking form, or by email. In the event of an alteration, TSS reserves the right to make an administration charge of £50 per amendment, together with all communication charges or other expenses incurred by TSS. These charges will be payable whether or not TSS succeeds in confirming your requested amendment.
4.2. All cancellations must be advised in writing or by fax and signed by the signatory of the booking form, or by email. Written cancellation notices should be sent to TSS at Brixham Marina, Berry Head Road, Brixham, TQ5 9BW. Recorded delivery is strongly recommended. Cancellations are effective on the day they are received by TSS.
4.3. In the event of a cancellation being notified to TSS more than four weeks prior to the commencement of the course, all monies paid will be refunded with the exception of the non-refundable registration fee (clause 2.3). In the event that the cancellation is notified to TSS later than four weeks prior to the commencement of the course, the client remains liable for the full amount of the fees, and therefore no sums paid over will be refunded. However, TSS will endeavour to sell the place and, if successful, will refund the amount of the Client’s Final Payment (less an administration fee of £50 so long as this amount has been matched from the sale of the space to the replacement client.
5. Amendment and cancellation by TSS
5.1. TSS makes every effort to operate its courses as advertised but it may very occasionally be necessary to modify a course before its commencement. If the modification is significant in that it substantially undermines the course for which you have contracted, TSS will notify you as soon as practicable and offer you three choices. You may (1) accept the modification, (2) change your booking to another available course or (3) cancel and receive a full and prompt refund. If you choose another available course which is more expensive, you must pay the difference, but, if it is cheaper, TSS will make the appropriate refund. If there is a minor modification before you depart (that is a change not included in the definition of a significant modification set out above), TSS will try to notify you, although it is not obliged to do so nor is it obliged to pay any compensation.
5.2. If TSS becomes unable to provide a significant element of your course after it has commenced, suitable alternative arrangements will be made for you at no extra charge to you or, alternatively, you will be returned to your point of departure and given a refund which TSS in its sole discretion considers appropriate to the circumstances.
5.3. In the event that the vessel on which the course booked was due to be conducted is not available, TSS reserves the right to conduct the course on another vessel. In the unlikely event that a suitable vessel is not available for the course, TSS will advise you immediately and the provisions of clause 5.1 will apply.
5.4. TSS reserves the right to cancel your course. However, it guarantees that it will not do so for any reason other than force majeure after the date on which the final payment is due. “Force majeure” means unusual and unforeseeable circumstances beyond TSS’s control, the consequence of which neither TSS nor its suppliers could avoid, including, but not limited to, war, threat of war, riot, civil strife, terrorist activity (actual or threatened), industrial dispute, technical problems with transport, machinery equipment, power failure, natural or nuclear disaster, fire, flood or other adverse weather conditions. In the event of a cancellation due to force majeure, TSS will use reasonable endeavours to arrange an alternative course of a comparable standard. In the event that this does not prove possible or practicable, the Company undertakes to give an appropriate refund having regard to the circumstances.”
9 Complaints
Complainants should usually submit their complaint in writing, either by email or letter. Receipt of the complaint requires acknowledgment by return or, if this is not possible, at the earliest possible time informing the complainant that you will be instigating an investigation and when they should expect to receive a response.
Any investigation usually requires the instructor, other students on the course and any other independent witnesses to be canvassed to get a balanced view.
The Principal should instigate an investigation quickly and respond objectively to the complainant with conclusions and any corrective action that has or will be taken.
Experience has shown that dealing with a complaint in a timely fashion and showing a willingness to listen to the customer's concerns objectively goes a long way towards resolving matters quickly and amicably.
10 Employees
TSS will maintain accurate personnel records detailing qualifications held and expiry/issue dates of any supporting certificates such as first aid, medical fitness or criminal records checks. For RYA instructors, a letter of appointment or instructor certificate is also required. This will be in the form of a spreadsheet.
A declaration of the acceptance of contracts and confirmation that staff have read and understood TSS’s operating procedures will be held.
Instructors requiring commercial endorsements must hold a current medical fitness certificate which must be checked for any restrictions.
TSS will make clear to all staff the terms under which they are engaged.
11 Your rights
You have the following rights with regard to your data:
11.1 The right to be informed.
11.2 The right of access.
11.3 The right to rectification.
11.4 The right to erasure.
11.5 The right to restrict processing.
11.6 The right to data portability.
11.7 The right to object.
11.8 The right not to be subject to automated decision-making including profiling.
11.9 Users reserve the right to complain to the ICO if they believe TSS are mishandling data. To request to see the data we have on a subject or to request removal of subject data, please contact us: This email address is being protected from spambots. You need JavaScript enabled to view it. or 01803665556

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