The definitions used in this document are the same as those used in the Byelaws, Rules and Regulations of the Club, available on our website: www.heatonssports.club
1. WHO WE ARE
1.1 The Heatons Sports Club playing rugby, cricket, tennis and lacrosse and we collect, use and are responsible for certain personal information about Members and prospective Members. This will also include non-playing social members.
1.2 When we do this, we are regulated under the General Data Protection Regulation which applies across the United Kingdom, and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
2. THE PERSONAL INFORMATION WE COLLECT AND USE
2.1 In order to make an application to join The Heatons Sports Club, prospective Members must provide personal data which they enter onto membership application forms. In addition, the Club and the Sections may supplement the data gathered at the point of application for membership with additional data gathered in the course of a Member’s membership of the Club. This data may be gathered, for example, during Club activities, via email or via each Section’s website or social media presence.
2.2 The Club will gather personal data on each Member which is sufficient but not excessive for the purposes for which the data will be used, which include the following:
2.2.1 to administer the Club’s membership and in order to collect Member subscriptions;
2.2.2 to contact Members in order to inform them about things which we consider will be of interest to them as Members of the Club;
2.2.3 to arrange sporting fixtures and coaching sessions;
2.2.4 to maintain affiliations to leagues / competitions / National Governing Bodies;
2.2.5 to record, monitor and share player performances and statistics;
2.2.6 to publish contact details for Club officials; and
2.2.7 to ensure the wellbeing of Members.
2.3 The lawful bases upon which we collect and use personal data are that:
(a) by joining the Club, a Member has given consent to the processing of their personal data for the specific purposes set out above;
(b) processing is necessary for the performance of the contract of Membership (i.e. the agreement to become and remain a Member);
(c) processing of data (especially medical data) may be necessary to protect a Member’s vital interests;
(d) the Club has a legitimate interest in processing personal data.
2.4 To explain the Club’s legitimate interest in collecting and using personal data in more detail:
(a) the legitimate interest of the Club is the furtherance of our objectives in the Club’s Articles of Association: “to cultivate, promote and practice the games of Rugby, Cricket, Tennis, and Lacrosse “;
(b) the processing of personal data of Members is necessary to achieve that interest; and
(c) we have done a balancing test and are confident that each Member’s individual interests do not override the Club’s legitimate interests in processing personal data. Specifically, the processing of personal data of Members for the purposes set out above is reasonably expected by Members, has a minimal impact upon each Member’s personal interests, rights and freedoms and will not cause Members unjustified intrusion or harm.
2.5 Within the Club, the Membership Secretary will regularly share data relating to all Members of the Club with the Sectional Membership Officer of each Section in order to allow the Sections to monitor and administer their own Members.
2.6 Within Sections, officers, captains and coaches will have access to Member data to the extent that they reasonably require it in order to carry out their roles (for example player names, contact information, emergency contact details and medical conditions will normally be shared with team captains / coaches). Sections may also choose to publish player names, performances, statistics and officer contact details on their own websites and/or to disseminate such information by email or in newsletters.
2.7 In some instances, the Club may share some of the personal data which it collects from Members with third parties outside the Club. This may result in the information being used on publicly accessible websites and in publications such as handbooks, etc. (e.g. team coaches and captains will usually have their contact details published to allow them to be contacted in relation to Club business). We will also share personal information with law enforcement or other authorities if required by applicable law.
2.8 In all cases where data is shared outside of the Club, the Club will share the minimum amount of personal data which is necessary in the circumstances.
2.9 Other than as set out above or where:
(a) the Club has a legitimate interest in so doing; or
(b) it is necessary to protect a Member’s vital interests, personal data which the Club collects from Members will not be shared with any third party without the prior consent of each Member.
2.10 The Club will record and process personal data relating to all of its Members for as long as they remain Members of the Club. When a Member resigns their Membership or ceases to be a Member for any other reason, their personal details will be retained and archived for the purposes of statistical analysis and monitoring membership trends.
3. YOUR RIGHTS
3.1 Under the General Data Protection Regulation, Members have a number of important rights free of charge. In summary, those include rights to:
3.1.1 fair processing of information and transparency over how we use your use personal information;
3.1.3 require us to correct any mistakes in your information which we hold;
3.1.4 require the erasure of personal information concerning you in certain situations;
3.1.5 receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations;
3.1.6 object at any time to processing of personal information concerning you for direct marketing;
3.1.7 object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
3.1.8 object in certain other situations to our continued processing of your personal information;
3.1.9 otherwise restrict our processing of your personal information in certain circumstances;
3.1.10 claim compensation for damages caused by our breach of any data protection laws.
3.2 For further information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
3.3 If you would like to exercise any of these rights, please email our Secretary, who acts as our Data Protection Officer: firstname.lastname@example.org When doing so, please provide:
3.3.1 enough information to identify you (e.g. your membership number);
3.3.2 proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
3.3.3 details of the information to which your request relates (e.g. your membership record).
3.4 If you would like to unsubscribe from any email newsletter or similar which you may receive as a Member, you can also click on the ‘unsubscribe’ button at the bottom of the relevant email or contact an officer of your Section or the Club to confirm your preferences.
4. STORAGE OF DATA
4.1 The personal data which is gathered when Members apply to join the Club, and any updates to that data collected at a later date to reflect changes to the circumstances of a Member, are entered onto a computer database and stored electronically. This database is protected by encryption and is backed-up regularly. The backup is stored in encrypted form at a separate location to the main database to minimise the risk of data loss.
4.2 The Club’s main database of Member data is only accessible to the Membership Secretary and a small group of people to whom the Membership Secretary may delegate membership administration tasks from time to time (usually the Sectional Membership Officer for each Section).
4.3 In this way, we seek to ensure that your data is protected from being accidentally lost, used or accessed in an unauthorised way. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
4.4 Your personal information may be transferred outside of the United Kingdom as a consequence of the storage of that data on servers located outside of the UK. This may apply to the membership application data entered onto our online application form, your membership record on our membership database, information which is entered online onto Club websites or social media platforms, or where data is transmitted by email using servers outside of the UK.
5. ACCURACY OF DATA
5.1 The Club will take all reasonable and necessary steps to ensure that the personal data gathered from Members is accurate and is kept up-to-date for as long as each Member remains a Member of the Club.
5.2 The Membership Secretary will record any changes to the circumstances of a Member of which he is notified by entering these changes onto the membership database as soon as reasonably practicable after such notification is received. In addition, Members can log in to the Club’s website and maintain their own contact detail themselves.
5.3 Where data relating to a Member is provided by a third party and recorded on the database, a note will be made of the source of that data wherever reasonably possible.
5.4 If a Member considers that the Club holds data which relates to them which is inaccurate, they may make a written request to the Membership Secretary to have such inaccuracies corrected or erased. The Membership Secretary will comply with such requests unless he/she considers that it would not be reasonable to do so.
6. COMPLAINTS OR QUERIES
6.1 The Club seeks to meet the highest standards when collecting and using personal data. For this reason, it takes any complaints it receives about this very seriously. People are encouraged to bring it to the Club’s attention if they think that the Club’s collection or use of data is unfair, misleading or inappropriate. The Club would also welcome any suggestions for improving its procedures.
6.3 The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at
https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
7.2 This policy was last updated on 1st March 2022