CA Data Privacy Notice
This privacy notice describes how the Croquet Association processes the personal information ("the data") it holds about you, or that you are about to share with it. The CA is committed to keeping your information safe and to meet its obligations under the General Data Protection Regulation ("GDPR") to process it fairly. This notice also outlines your rights if you feel it is not doing so.
Identity and Contact Details
The Controllers of the data are the Croquet Association (CA), which is a non-profit-making unincorporated association of its members, and any clubs of which you are a member and which have agreed with the CA to use the database to hold data about their members for their own purposes. The CA operates directly through its Officers, Staff, those serving on its Council, Executive Board, Committees and in other roles (e.g. Tournament Managers, Handicappers, Coaches); and indirectly through its Member Clubs, Member Federations and Coaching Academies when they are acting on its behalf. It can be contacted through its office: The Croquet Association, Old Bath Road, Cheltenham GL53 7DF, e-mail: email@example.com. Please identify any correspondence related to this notice with the subject "Data Protection: FAO CA Manager".
The CA is not required to appoint a Data Protection Officer as defined by GDPR: its Manager and Hon. Secretary are jointly responsible for ensuring that data protection issues are dealt with by the organisation.
Purpose and Lawful Basis for Processing
The CA processes (or will process) information about you in order to administer your membership, sales to you from its online shop, or more generally support its activities, for example, the tournaments, coaching, development and related programmes that it runs.
The lawful basis for holding membership and sales records is to fulfil the contract with you as a member or customer (or potential member or customer) of the CA. More generally, the lawful basis for the processing described above is that it is in the legitimate interests of the CA in pursuit of its aims as stated in its Constitution.
The CA also processes personal data relating to current or potential contracts with staff, landlords, suppliers or service providers, under the lawful basis of fulfilling or entering into those contracts.
Categories of Personal Data
The CA may hold and process the following categories of structured personal data about its current or potential members, customers, contacts and those engaging in activities run under its auspices:
- Contact Details (e.g. postal, e-mail and social media addresses and telephone numbers).
- Financial information relating to subscriptions, sales and other transactions such as tournament entry. No credit card details are held by the CA online and bank account details (for direct debits) are stored offline.
- Handicaps, rankings, eligibility criteria (including nationality, residency and date of birth), qualifications and awards.
- CA and Club membership.
- Committee membership or other positions within the CA.
- Entries to, schedules for and results of events, including selection for and participation in teams or squads.
- Disabilities, such as colour vision deficiency, where to do so would facilitate your participation.
It may also hold data relating to contracts with staff and third parties, as noted above.
In addition, unstructured personal data relating to you may be held in e-mails sent to or from you, or between those acting on behalf of the CA, and in logs of requests you make to its website.
The CA will not pass your data to anyone without your consent, except where necessary to provide its services, as detailed below:
- It may share your contact details and information about goods you have ordered with suppliers of them to enable it and them to fulfil your order.
- It may share financial data relating to you with its payment processor, banks and BACS processor, for the purpose of collecting payments or making refunds.
- It may share your data with clubs to which you belong, for the purpose of maintaining accurate membership records.
- It may share information held about you with members of its Council, Executive Board, Officers, Committees and Staff, to enable them to fulfil their roles within the organisation.
- It may share your postal address with the fulfilment house for delivery of the Croquet Gazette, Royal Mail and other couriers who deliver items to you on behalf of the CA.
- It may share information held about you, including your e-mail address and preferences, with bulk e-mailing services, to communicate with you.
- It publishes your name and CA-related attributes (such as handicaps, coaching and refereeing qualifications, roles and club memberships) in an online Directory that is accessible only to CA Members. With your consent and to facilitate contact between Members we also publish your contact and additional information about you in the Directory, accessible to your fellow club members or to all CA Members as you allow.
- It may publish contact details for representatives of its member clubs and federations, tournament and coaching officials, and those serving on CA Committees.
- It may publish contact details and other information about those who wish to or have entered tournaments or coaching activities on its website, available to those who can log into it, and supply them and financial details relating to payment for entries to those running the events and officers of the clubs hosting them. This may include organisations based overseas if you participate in international tournaments or matches.
- It may publish news, including photographs, tournament results and commentary on its website, sites publishing croquet results, or social media sites.
- It may provide results of ranking games to Ranking Officers working on behalf of the CA or World Croquet Federation.
- It may provide financial and contact information about staff and others paid by the CA to HMRC and pension providers.
- Its website may share information about your use of it with search engine providers, for the purpose of optimising it (and, whilst not the responsibility of the CA, software on devices you use to access it might harvest data relating to your use of it).
- It will give information about you when legally required to do so.
Location of Data Processing
The data is processed on computers (and backups of them) operated by the CA, on those operated by its service providers (e.g. for its website, email, online shop, payments, banking and distribution), and on paper records.
These are all normally located in the UK, European Union or countries which have equivalent data protection safeguards.
Except where required for archiving purposes (such as results of tournaments and club competitions and records of CA activity, such as minute books and membership lists), data about you will be deleted no later than six years after you were last a member of or had financial dealings with the CA.
You have the right to object to how the CA 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, but your participation in events or fulfilment of your membership rights may be restricted if you do so. In addition, you have the right to complain to the CA (see the first section for contact details) and to the Information Commissioner at http://ico.org.uk/global/contact-us.
Please contact the CA (using the contact details above) in the first instance if you have any queries or concerns.
The primary source for the data held about you is the information you provided, or are about to provide, when joining the CA or subsequently updating it, either directly or through a club of which you are a member, or when ordering goods from its shop. Those acting on behalf of the CA in running its activities are a secondary source of data for your results, handicaps, qualifications, etc.
Consequences of Failing to Provide Data
If you do not provide the information required by the CA to become a member or enter a tournament or coaching activity then you will be unable to participate in it. The CA requires at least a postal address to ensure that it can contact its members and those playing in tournaments run under its Regulations.
Software may be used to produce draws and orders of play for tournaments and to assist team and squad selection, but otherwise, no automated decision-making software is used by the CA.
We may update this policy from time to time by publishing a new version on our website: significant changes will be notified in a news item.
Significant changes since version 1, dated 24th April, 2018:
- Clubs may be joint controllers with the CA of data relating to their members
- CA and Club membership added to list of categories of data held
- CA Committees, Staff and bulk e-mailing services added to list of those with whom data may be shared.
Version 2, 24th May, 2020