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Club Data GDPR Privacy Notice Template


(3rd Draft, 1 January 2024)

Rubric

This is a template for the privacy notice that a croquet club is required, under the General Data Protection Regulation (GDPR), to publish to its current and potential members, visitors and tournament players about whom it processes, or is about to acquire, personal data. It is probably best to publish it on a website and refer to and possibly summarise it on application forms and in any club handbook, as including the whole text would seem disproportionate, though paper copies should be available on request to those who are unable to access it online. It has been drafted for use by a typical club, but should be edited to suit local circumstances; it may also be useful to Federations. It has been written in the light of guidance from the Information Commission's Office at https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-notices-transparency-and-control/privacy-notices-under-the-eu-general-data-protection-regulation/, rather than specific legal advice.

<XYZ Croquet Club> Privacy Notice

Introduction

This privacy notice describes how the <XYZ Croquet Club> processes personal information ("the data") it holds about you, or that you are about to share with it. The club will endeavour to meet its obligations under the General Data Protection Regulation ("GDPR") to process your information fairly, but this notice outlines your rights if you object to how it treats your information.

Identity and Contact Details

The controller of the data is the <XYZ Croquet Club> ("the club"), which is [an unincorporated association of its members]/[a company limited by guarantee with registration number DDDDDD]/[other structure]. [Its registered address is ….]/[It can be contacted through its Honorary Secretary at ..]. The club has not appointed a Data Protection Officer under GDPR: its committee is collectively responsible for its obligations.

The data is processed by club members acting in a voluntary capacity on its behalf and by Internet service providers hosting its website and e-mail services.

Purpose and Lawful Basis for Processing

The club processes (or will process) information about you in order to administer your membership and/or support its activities, for example, the tournaments it runs and the entertainment of visiting groups.

The lawful basis for holding membership records is to fulfil the contract with you as a member (or potential member) of the club. More generally, the basis for the processing described above is that it is in the legitimate interests of the club in pursuit of the aims stated in its rules, yourself and/or the sport more widely.

The club may also process personal data relating to current or potential contracts with landlords, suppliers or service providers, under the lawful basis of fulfilling or entering into those contracts.

Categories of Personal Data

The club may hold and process the following categories of personal data about its current or potential members, tournament players and visitors:

In addition, it may hold data relating to contracts with third parties, as noted above.

Information Sharing

The club will share your data with Croquet England if you elect to become an associate of the Organisation or play in a tournament subject to its regulations, and may do so with other individuals, clubs and federations connected with the sport, in connection with your participation in it.

It will publish your name, contact details, membership class and handicap(s) in membership lists made available in the <clubhouse> and to fellow members, to facilitate contact between members and to help them arrange games.

It will provide results of ranking games to ranking officers working on behalf of the World Croquet Federation and may publish tournament results and other information about club activities on www.croquetscores.com, Croquet England, Federation or its own websites.

It will not pass your data to other organisations without your consent, unless under a legal obligation to do so.

International Transfers

Data processed by the club will be held on servers held in the UK, European Union or countries which have equivalent data protection safeguards.

Retention Periods

Except where required for archiving purposes (e.g. results of tournaments and club competitions and records of club activity, such as minute books and membership lists), data about you will be deleted six years after you last had financial dealings with the club.

Your Rights

You have the right to object to how the club processes your personal information. In particular, you can request that your contact details are not shown in published membership lists. You also have the right to access, correct, and, in some cases, delete and restrict the use to which your information is put. In addition, you have the right to complain to the club (see the first section for contact details) and to the Information Commissioner at ico.org.uk/global/contact-us.

Please contact <the club secretary> in the first instance if you have any queries or concerns.

Data Sources

The primary source for information about the club's members, tournament players and visitors is the people themselves. For those who are associates of Croquet England, information may also be taken from its website.

Consequences of Failing to Provide Data

If you do not provide the information required by the club to become a member, enter a tournament or visit the club then you will be unable to do so.

Automated Decision Making

Software may be used to produce draws and orders of play for tournaments, but otherwise, no automated decision-making software is used by the club.