Contents...

• 1. Purpose of the Agreement
• 2. Croquet England Subscriber Data Purposes
  • 2.1 Scope
  • 2.2 Purposes of Sharing Information
  • 2.3 Information Sharing Requirements
  • 2.4 Information to be Shared
  • 2.5 Use of Information
• 3 Handling Affiliated Club Specific Data
  • 3.1 Scope
  • 3.2 Use of Information
  • 3.3 Sharing of Core Data
  • 3.4 Additional Data
• 4 Consent
  • 4.1 Sharing with Croquet England
  • 4.2 Using the Database for the Club's Own Purposes
• 5 Data Access and Storage
• 6 Data Transfer
• 7 Data Quality
• 8 Information Retention
• 9 Data Protection Act
• 10 Review of This Agreement
• 11 Roles and Responsibilities
• Changes Log

1. Purpose of the Agreement

This document provides the basis for an agreement between Croquet England and its Affiliated Clubs to share some personal details of club members. It has been written following advice from the Information Commissioner's office.

All playing members of clubs affiliated to Croquet England, the sport's governing body will have the option, at no cost to themselves, to become a subscriber of Croquet England. To facilitate this, clubs must share information about those members with Croquet England.

The primary benefit of sharing this data between Croquet England and clubs is that those members will be Croquet England associates and receive the benefits as defined by the Croquet England. It will also help to ensure that the clubs' subscriptions to Croquet England are accurately calculated on the basis of the number of club members.

Secondly, the on-line directory enables Affiliated Clubs to maintain their own membership data. This information may include people who will not be associated with Croquet England, and may also include data of interest to the club but not necessarily to Croquet England, as identified by the club.

2. Croquet England Subscriber Data Purposes

2.1 Scope

This part of the agreement is limited to the data sharing between Affiliated clubs and Croquet England to facilitate club members to become Croquet England Associates. The agreement covers the sharing of information between Croquet England and Affiliated clubs that are identified as holding relevant information for the purposes of ensuring that accurate membership records are maintained.

Information will be personal in nature and may only be shared where a club member wishes to be a Croquet England Associate. See Section 4 below about consent.

2.2 Purposes of Sharing Information

Under the terms of this agreement, information may be shared for the purpose of maintaining accurate subscriber records and enabling croquet club members to receive Croquet England Associate benefits, which may include the following:

• Tournament Entry
• Maintenance of handicap data
• Maintenance of qualification (coaching/refereeing/handicapper) data
• Access to the Subscribers' Area of the website
• Inclusion in the secure online Croquet England Directory
• Access to the online Fixtures Calendar
• Access to the online Croquet Gazette

This is not an exhaustive list as new or changed benefits and qualifications may be identified and these will be incorporated into this agreement during the monitoring and review process.

2.3 Information Sharing Requirements

2.4 Information to be Shared

We require the following minimum set of data from the club for anyone who is or wishes to be a Croquet England Associate:

• Name
• Postal Address
• Croquet Handicaps
• For club members that have a primary club elsewhere, an indication that this is the case
• An indication of whether the member has consented to having their details visible in the Croquet England Directory:
  • To members of your or any croquet club of which they are a member
  • To all Croquet England subscribers

In addition, for members who the club is claiming as young people:

• Date of birth

Note that Croquet England will retain date of birth once known, even after the member ceases to have young person status. It may also collect and hold date of birth directly from individuals for other purposes, such as qualifying for senior or veteran events.

Croquet England also asks clubs to provide the following:

• email address
• telephone numbers

This greatly helps Croquet England with communication to its subscribers, and also increases the options available to them - for example subscribers will not be able to log in to the website without an email address and therefore cannot access the electronic gazette and other information.

Other information that will be held by Croquet England where known:

• Skype Address
• Coaching Qualifications
• Referee Qualifications
• Handicapper Qualifications
• Croquet-relevant special-needs such as Colour Vision Deficiency

To complete the information provided, we will also need the number of playing members a club has that do NOT have a primary club elsewhere, and who do NOT want their information shared with Croquet England. This then enables us to calculate the club's subscription.

2.5 Use of Information

The information will be held by Croquet England in a database that is linked to Croquet England's website to facilitate:

• Accurate assessment of club subscriptions
• Tournament and coaching course entry
• Accessing secure subscribers' area
• Accessing Croquet Gazettes
• Accessing Croquet England Documents
• Use of the Croquet England Directory (subscribers-only and in a secure area)
• Subscribers maintaining their own personal data including profile

3 Handling Affiliated Club Specific Data

3.1 Scope

This part of the agreement covers the use of Croquet England database facilities by Affiliated clubs for their own purposes. The data to be held will be defined by and be the responsibility of the club concerned.

3.2 Use of Information

All information held under this part of the agreement will be kept confidential between the clubs and Croquet England officers, except that name and handicap only will be visible on the Croquet England Directory. It will not otherwise be used by Croquet England except for statistical analysis, with any published results being strictly anonymised. It will be the club's responsibility to maintain the data, including removing any data no longer required. The Club is the Data Controller and Croquet England is the Data Processor.

3.3 Sharing of Core Data

Core data on a member is the same data as is defined in section 2.4. Core data on a member is stored only once, even where an individual is a member of several clubs, or a member of a club and Croquet England. Only organisations (clubs or Croquet England) that the member has explicitly joined will have access to this information.

This means that if a member belongs to two or more clubs, any one of the clubs may change the core data, and the other clubs will see this change.

3.4 Additional Data

Clubs may define additional data they wish to hold on a member. Any additional data is held privately to the club and is not accessible to any other club or to Croquet England outside of its officers.

4 Consent

4.1 Sharing with Croquet England

It is the club's responsibility to seek consent from their members to become subscribers of Croquet England and hence to share and process information for the purposes identified. Visibility of their details in the online Directory is optional, and thus requires specific consent. Consent must be sought from club members by club secretaries. The EU General Data Protection Regulations (GDPR) require that each club member must explicitly have given their consent. Clubs will need to record when that consent was given and the form of words used. Croquet England may, if required, request to see this consent.

If a club member does not agree to becoming a Croquet England subscriber, the club should not send their details to Croquet England and the club member will not benefit from being a Croquet England Associate.

4.2 Using the Database for the Club's Own Purposes

Where a club stores information on members for its own purposes, it is normally allowed to do this as a 'legitimate interest' without seeking explicit consent from the member. Clubs should always make information about how they store data available to its members, and notify them if this is to change. Using the Croquet England database for this purpose is no different from any other method of storing membership data in this respect.

5 Data Access and Storage

Data in transit is encrypted using Secure Sockets Layer (SSL). Stored personal data including backups and logs, except for the subject's name, is encrypted and Croquet England holds the keys.

A club member's/Croquet England subscribers record may be accessed and altered by nominated and authorised Croquet England club officers, Croquet England staff and officials, and the individual to ensure that records are accurate. Other Croquet England subscribers may also access data through the secure area of the website for information purposes only and cannot alter records. Examples of this include tournament managers, handicappers, club team captains, referees, and subscribers looking for doubles partners. This list is not exhaustive but access must be limited to croquet-related matters and only through a secure login process. Subscribers, clubs and Croquet England may not access the data to use it for any other purpose, which includes passing data to third parties or selling data.

Club contacts' details, limited to those that are relevant, are displayed on the Croquet England website.

6 Data Transfer

Data should be transferred electronically between clubs and Croquet England using the website. Clubs that cannot transfer data electronically should send the information on paper to the Croquet England Office. All information must be labelled with the originator - name of club and person supplying it - and dated.

7 Data Quality

Clubs are responsible for ensuring that all data shared with Croquet England is accurate and limited only to the information required in this agreement. Clubs should have a process in place to ensure that data is checked for accuracy prior to sharing. Before sharing data, the responsible club officer should check that the information being shared is accurate and up to date to the best of their knowledge. Members whose details have been uploaded will also be able to access and change the data to ensure accuracy and reflect any changes in the data.

8 Information Retention

Information in the online Croquet England Directory will be retained for as long as an individual remains a member of the club or a subscriber of Croquet England. When an individual ceases to be a subscriber, their records in the online Croquet England Directory will be marked as inactive, but retained whilst financial records relating to them are still required. Before being deleted, a copy of the records will be retained for historical and statistical purposes by Croquet England in an offline database and not used for any other purpose.

9 Data Protection Act

Clubs must ensure that they comply with their own data protection policies where they exist. Clubs that have an exemption from registration with the ICO must still comply with the EU General Data Protection Regulations (or the UK ones made after the departure from the EU) and ensure that they adhere to best data protection practice as outlined on the ICO website.

10 Review of This Agreement

Croquet England will review and monitor this agreement every three years unless legislation or policy changes dictate otherwise.

New parties to this agreement may be included at any time, the formal arrangements for which will be managed by Croquet England.

Any proposed amendments or changes to this agreement will be notified to clubs.

11 Roles and Responsibilities

In signing up to this agreement, the signatories agree to the following roles and responsibilities:

Changes Log

Version 3, March 2024:

• Revised to reflect the transition to Croquet England, References to the Croquet Association changed to Croquet England, References to Croquet Association Members changed to Croquet England Associates or Subscribers
• Section 1 updated to reflect that clubs can now maintain their own members data on the database

Version 2, November 2020:

• Clauses 3.3, 3,4 and 4.2, relating to use of the Croquet Associations database for maintaining a club's membership records added.
• Clause 2.6 relating to information retention moved to clause 8 and revised.
• Additionally, the agreement has been reviewed, as required by clause 10, resulting in minor updates.

Version 1, September 2017. Initial version.