Worthing Town Football Club Limited - Privacy Notice
We understand how important your personal data is and are committed to protecting and respecting your privacy.
‘Personal Data’ means any information relating to or which identifies you. This can include items such as your name, address, phone number, identification numbers, location data or online identifiers. Personal data can be held electronically or in certain paper records.
The General Data Protection Regulation (GDPR) regulates the processing of personal data. The GDPR seeks to protect your rights to your personal data by setting out, amongst other things, the conditions under which the processing of personal data is lawful, the rights of data subjects and the standards that organisations handling personal data must adopt. This Privacy Notice is issued in compliance with GDPR and seeks to explain:
1. Who we are;
2. Products and services covered by this Privacy Notice;
3. How we collect your personal data;
4. Why we collect your personal data;
5. How long we hold the personal data;
6. The conditions under which we may share it with others;
7. How we keep your personal data secure;
8. Your personal data rights and how to exercise them;
9. Useful information; and
10. Any further questions.
1 - Who we are
Worthing Town Football Club Limited (WTFC) is the organisation that administers the Football Activities of Worthing Town FC. Our registered address is Palatine Park, Palatine Road, Worthing, West Sussex, BN12 6JN and we are registered with the ICO.
WTFC is a ‘Data Controller’ this means that we are responsible for deciding how and why we hold and use personal data about you and or your child.
In this Privacy Notice, ‘we’, ‘us’ and ‘our’ will always mean WTFC, as Data Controller.
2 - Products and services covered by this FPN
This notice applies to all of the activities undertaken by WTFC.
3 - How we collect your personal data
The personal data we hold includes your / your child’s name, postal address, email address, phone number, date of birth and financial information. We may also collect medical information or other sensitive information where this is relevant for the protection of your child whilst undertaking football and other related activities within there parameter of WTFC activities.
We use different kinds of personal data dependent upon the relationship you have with us (Player(adult / child), Parent, and Member). We collect it through a variety of different ways:
Information you provide to us
· By using our website(s);
· By corresponding with us by post, phone, e-mail, or otherwise;
· Application and registration forms/identification documentation; and
· Entering competitions, promotions or surveys.
Information we collect about you when you use our services
· Information about how you logged on and off of our website(s), including your IP address, information about your visit, your browsing history, your device information and how you use our website. This will include the capture of your location information;
· If you contact us electronically, we will collect details about the date and time of contact, and the contact details such as the call reference number and your telephone number;
· Information about the transactions WTFC, including financial data;
· Information on what you view, click on and access in and through our marketing emails and text messages. This includes the geographic location of the device you have used;
· If you contact us via social media, we collect details from your social media account.
Special types of data – The law and other regulations treat some types of personal information as special. We will only collect and use this information if the law allows us to do so. Special types of data are:
· Health data including gender;
· Racial or ethnic origin;
· Religious or philosophical beliefs; and
Keeping your personal data up to date
It is important to us that the personal data we hold about you remains accurate and up to date at all times, but we need your help in doing this. Please help us by ensuring that you review the information held about you regularly and let us know as soon as anything needs updating or correcting.
Other people’s personal data
The information you give us or that we collect through your use of our services, may contain your or another person’s personal data. If you provide us with information about another person, you confirm that they have appointed you to act for them, they consent to you providing their personal data to us and any processing of their personal data and that you have informed them of our identity and the purpose for which their personal data will be processed – as set out in this Privacy Notice.
4 - Why we collect your personal data
In the table below we demonstrate why and how we use your personal data as well as providing the legal reasons which we rely upon.
Under Data Protection legislation we must always have a legal reason for processing your personal data. One of the legal reasons is when we use your personal data for our legitimate interests, this is usually when we have a business reason. However, we must always ensure that we take your interests into consideration too, and ensure that the use is fairly balanced. We tell you below when we rely on legitimate interests and what our legitimate interests are.
Why we use your personal data, How we use your personal data, Our legal reasons for using your personal data
Provision of Football related activities, including the administration and management of such
To manage and operate your membership and to facilitate the administration of your or your child football activities. This includes:
· Retaining records of your instructions and telephone calls and keeping your records up to date.
· To respond to any complaints and / or data rights that you invoke.
To comply with legal requirements placed upon us.
Our legitimate interests, such as the proper administration of our service and business, for example:
· Keeping our records up to date.
· Seeking your consent when we need it to contact you.
· Operating efficiently.
· Enabling and monitoring your use of our website and services.
· Acting with your consent.
If you choose not to give personal information
We need to collect personal information required by law or under the terms of service you have elected to use. If you choose not to give us the personal data we need, it can mean that we have to cancel or decline a service that you request or have with us. So that you know what information is optional, we make it clear at the time we collect your personal data.
5 - How long we hold your personal data
Personal data will not be retained for longer than necessary for us to achieve the purpose for which we obtained your personal data. We will then either securely delete it or anonymise it so that it cannot be linked back to you. We review our retention periods for personal data on a regular basis.
We will retain personal data for the reasons noted below:
· To respond to enquiries and complaints;
· To demonstrate that your instructions were carried out properly; and
For full details of our retention policies, please contact us.
6 - The conditions under which we can share your personal data with others
The information we hold about you is confidential and we will only share your personal information to enable us to deliver the product(s) or service(s), examples are as follows:
· At your request, or with your consent;
· Banks and other payment service providers to process your payments;;
· Insurance companies – where we need to provide details if and when we need to make a claim;
· Our professional advisors, for example, our lawyers and technology consultants, when they need it to provide advice to us;
We will only transfer your personal information to trusted third parties who provide sufficient security guarantees and who demonstrate a commitment to compliance with applicable law and this policy. Where third parties are processing personal information on our behalf, they will be required to agree, by contractual means, to process the personal information in accordance with the applicable law. This contract will stipulate, amongst other things, that the third party and its representatives shall act only on our instructions, or as permitted by law.
We are also required to share your personal data with external third parties as follows (but not limited to):
· Where the law requires or permits disclosure, or there is a duty to the public to reveal it;
· When we need to defend or exercise our legal rights or those of a third party;
· Debt collecting, debt chasing or another agent for enforcing payment of monies owed to us;
· Police and other law enforcement agencies for the prevention and detection of crime and where a valid permission is applicable;
· As a result of a court order or other regulatory instruction;
· We can transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. At all times, we take steps to ensure your privacy rights continue to be protected as per this Privacy Notice.
7 - How we keep your personal data secure
We understand how important your personal data is to you and we take its security very seriously.
We safeguard your personal data across all our computer systems, networks, websites and offices as much as possible through appropriate procedures and technical security measures.
If you ever receive a communication from us by post, email or by phone that you are concerned it is not genuine, please contact us using the contact details below.
If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice of Get Safe Online, which can be accessed at www.getsafeonline.org.
8 - Your personal data rights and how to exercise them
You have rights in respect of the personal data that we hold about you. They include the right to request a copy of the information that we hold about you, to know about any automated decisions that are made about you and to change your marketing preferences at any time. Details about all of your rights are provided below.
Some of these rights are conditional and depend upon why we are processing your personal data. This means that we cannot always be able to respond to your request in the way that you want. For example:
· If you ask us to erase your personal data and we are processing the information because we are required to do so because of a legal requirement, we will not be able to delete your personal data; however,
· If you ask us to erase your personal data and we are processing the information because you provided us with consent (for example as part of a survey response), we will be able to consider and respond to your request.
This Privacy Notice provides you with the details on how we use and process your data.
The right of access to a copy of any personal data WTFC processes about you, together with certain additional information.
If you request to see your personal data, your initial request will be free of charge; subsequent requests may attract an administration fee. The additional information includes details of the categories and recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
The right to request us to rectify or update it.
This will be relevant where the personal data we hold is or has become inaccurate or incomplete, taking into account the purposes of the processing. Please explain why you consider the data inaccurate or incomplete.
The right to request us to erase your personal data in certain circumstances.
The circumstances when erasure can apply include when we no longer need it to meet a lawful basis for processing unless that basis is consent and you withdraw your consent or you object to the processing or the processing is unlawful.
However, certain exclusions apply - where the processing is necessary for compliance with a legal obligation or to establish, exercise or defend legal claims.
The right to request us to restrict processing it.
This request can be used to stop us processing your personal data: if you disagree over the accuracy of the personal data until we have verified the data; the reason for processing; or if you wish us to retain your personal data for longer than our retention period, e.g. to establish, exercise or defend a legal claim.
The right to request a copy of your information for data portability purposes.
If you have provided personal data to us under contract or because you consented to the processing and use the data by automated means, then you have the right to instruct us to transmit that personal data to you or another data controller in a machine-readable format.
The right to object to us processing your personal data.
You have a right to object to us processing your data where we are processing it for the purpose of legitimate interests.
You can also object to direct marketing communications from us about products, offers, competitions, or services and any profiling that we can perform in relation to direct marketing. You can do this at the point of data collection, through the use of any opt-out functionality on text and emails, via your preference centre or by contacting the helpline service.
You can update your marketing preferences at any time through the use of the opt-out functionality.
You have the right to withdraw your consent at any time. However, this will not affect the lawfulness of processing before the withdrawal.
If you would like to receive the marketing described above, please ensure you have indicated your preferences accordingly.
Rights related to decisions based solely on automated processing.
Where this processing produces legal effects or significantly affects you, you can object to this processing unless the processing is necessary as part of our contract, or is required by legislation.
Right to lodge a complaint with a supervisory authority.
If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection team who will investigate the matter and report back to you.
If you remain unsatisfied with our response or believe we are not processing your personal data in accordance with the law, you are able to contact the data protection authority in your country. In the UK, it is the Information Commissioner’s Office (ICO) who regulates Data Controllers compliance with data protection legislation. They can be contacted by email: firstname.lastname@example.org, post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone: 0303 123 1113.
9 - Useful information
Children (16 years and under) and Vulnerable Adults
We are committed to the privacy protection of children and vulnerable adults. If you are aged 16 or under‚ and we need to process your personal data you must obtain the permission of your parent / guardian before you share your personal data with us. If we are notified that you are a vulnerable adult we will liaise with your authorised representative, once we are in receipt of the appropriate permissions.
Use of ‘cookies’
Cookies are text files placed on your computer to track visitor use of websites and to compile statistical reports on website activity. This helps us to improve our website and deliver a better more personalised service.
You can switch off cookies by setting your browser preferences. However, turning cookies off will result in a loss of functionality when using our websites.
Links to other websites
Our websites can contain links to other websites run by other organisations. When you are on another website, we encourage you to read their privacy policies as they will take precedence over this Privacy Notice.
We are not responsible for the privacy policies and practices of other sites.
Social media, blogs, reviews, and similar services
Any social media posts or comments you make to us (e.g. on our own Facebook page) will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) on which they are made and could be made public by that platform. These platforms are controlled by other organisations, and so we are not responsible for this sharing. You should review the terms and conditions and privacy policies of the social media platforms you use to ensure you understand how they will use your information, what information relating to you they will place in the public domain and how you can stop them from doing so if you are unhappy about it.
You are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.
Changes to this policy
We review our use of your personal data regularly. In doing so, we can change what personal data we collect, how we keep it and what we do with it. As a result, we can change this Privacy Notice from time to time to keep it relevant and up to date.
We will endeavour to alert you to these changes so that you can check you are happy with it before proceeding any further. Please look out for notices from us alerting you to these changes, via our websites or other timely communications. If you use our websites and see such an alert, please take a moment to ensure that you’re happy with any changes.
By continuing to use our services, you will be bound by this Privacy Notice.
However, we will also tell you of the changes where required by law to do so.
10 - Any further questions about this Privacy Notice
We hope that this Privacy Notice has been helpful in setting out how we handle your personal data and your rights to control it. If you have any questions that remain unanswered, please contact our Data Protection Officer:
· By email at email@example.com
· By post at Data Protection Officer, Palatine Park, Palatine Road, Worthing, West Sussex, BN12 6JN
· Telephone 01903 243449.