GDPR
Record of Processing Activities
This Record of Processing Activities (Record) describes how the Club processes personal data. The Club recognizes that Article 30 of the EU General Data Protection Regulation (GDPR) imposes documentation requirements on controllers and processors of data. This Record is Club confidential information but the Club will provide it to the appropriate supervisory authority on request as required by Article 30.
Data Controller Details:
Name: Bradford Ice Hockey Club
Address: 19 Little Horton, Bradford, West Yorkshire, BD5 0AD
Telephone Number: 01274 733535
Website: www.bradfordbulldogs.co.uk
Data Protection Officer:
Name: Jonathan Lutwyche
Mobile Tel No: 07739 899 843
Email: j.lutwyche@yordasgroup.com
Categories of Data Subjects
Club collects personal data from the following categories of data subjects:
Club Players and their Parents/Guardians
Club employees, officials, coaches, volunteers and applicants for these positions.
Club vendors or suppliers.
Club Sponsors, supporters and website visitors.
Categories of Personal Data
Club collects the following categories of personal data about Players and their Parents/Guardians:
Personal details including name, gender, address and date of birth.
Parents/Guardians’ consents and personal information.
Emergency contact information.
Financial, Credit card information and payment details obtained via Standing Order Mandates.
Contractual details including services provided by the Club.
Personal details including name and contact information.
Training and performance details and Player statistics.
Photographs, CCTV and video recordings.
Special categories of personal data, including data relating to a Player’s health and medical information.
Club collects the following categories of personal data about Club employees, officials, coaches, volunteers and applicants for these positions.
Personal details including name and contact information
UK Passport or Visa details
Date of birth
Emergency contact information
Government identification documents and numbers
Training details
Bank account details
Wage and benefit information
Expenses payment details
Performance information
Employment details (if employed)
Photographs, CCTV and video recordings
Special categories of personal data, including data relating to an employee’s:
DBS checks records (criminal convictions)
Health (medical information).
Club collects the following categories of personal data about vendors or suppliers:
Name and contact information.
Financial and payment details.
Club collects the following categories of personal data about its Sponsors, supporters and website visitors:
Name and contact information (where provided)
Financial and payment details (where provided)
Photographs, CCTV and video recordings (during Arena visits)
Which age group they support/wish to support
Purposes of Data Processing
Club collects and processes personal data about Players and their Parents/Guardians for the following purposes:
Maintaining and enhancing Club’s services
Providing services and Player/ Team management
Account management
Complying with legal obligations
Complying with the Club’s obligations to its governing bodies
Club collects and processes personal data about Club employees, officials, coaches, volunteers and applicants for these positions for the following purposes:
Recruitment and selection
Personnel management
Human resources administration including payroll and benefits
Expenses administration and evidencing
Complying with legal obligations
Education, training, and development activities
Maintaining and enhancing the Club’s services
Complying with the Club’s obligations to its governing bodies
Club collects and processes personal data about vendors or suppliers for the following purposes:
To obtain products and services
Vendor administration, order management, and accounts payable
Evaluating potential suppliers
Club collects and processes personal data about sponsors, supporters and website visitors for the following purposes:
Maintaining and enhancing Club’s products and services
Providing products and services and supporter/sponsor management
Account management
Direct marketing
Supporting network and system security
Detecting and preventing fraud
Complying with legal obligations
Conducting web analytics
Categories of Personal Data Recipients
Club discloses personal data to the following categories of recipients:
The Club’s Governing Bodies
Auditors and professional advisors, such as lawyers and consultants
Government and local law enforcement officials
Third-party service providers, such as providers of:
IT system management
Information security
Human resources management
Payroll administration
Retirement plan administration
Club does not usually transfer personal data to the Countries outside of the EAA or those which do not have a Privacy Shield Certification. On a rare occasion of the Players being selected to attend matches or training in the countries outside of the EEA or US, a separate data protection information assessment is conducted and additional consents obtained.
Club makes limited personal data transfers subject to the second subparagraph of Article 49(1) which are necessary for the Club’s compelling legitimate interests. Club provides appropriate safeguards for these limited personal data transfers through training and contractual provisions.
Personal Data Retention Periods
Except as otherwise permitted or required by applicable law or regulation, Club only retains personal data for as long as necessary to fulfil the purposes Club collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, Club considers the amount, nature, and sensitivity of personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for processing the personal data, whether it can fulfil the purposes of processing by other means, and any applicable legal requirements.
Club typically retains personal data for the periods set out below, subject to any exceptional circumstances or to comply with laws or regulations that require a specific retention period:
Information about Players/their Parents/Guardians:
Statistical Performance Information: 1 year. (Please note that some statistical performance information is not considered private as soon as it is published by the official or regulatory body)
personal details including name and contact information: 1 year (since the end of membership)
Photographs and video recordings: 1 year (unless they were used on the website or in social media)
Information about Club employees, officials, coaches, volunteers and applicants for these positions:
DBS forms: 6 years
Personal details including name and contact information: 6 years
Date of birth: 6 years
Gender: 6 years
Emergency contact information: 1 year
Passport, Visas, government identification numbers: 1 year
Education and training details: 6 years
Bank account details and payroll information: 1 year
Wage and benefit information: 1 year
Performance information: 1 year
Photographs, CCTV and video recordings: 1 year (unless they were used on the website or in social media)
Special categories of personal data, including information that relates to health: 1 year
Information about vendors or suppliers or sponsors:
Name and contact information: 1 year
Financial and payment details: 1 year from the end of contractual relationship
Financial and account details: 1 year from the last (outstanding) payment
Contractual details: 6 years from the end of contractual relationship
Information about supporters or website visitors:
Device details: 1 year
User activity details and user preferences: 1 year
Browser history details: 1 year
Location details: 1 year
Electronic identification data including IP address and information collected through cookies: 1 year
Contractual details including the goods and services provided: 6 years
Technical and Organisational Security Measures
Club has implemented the following technical and organisational security measures to protect personal data:
Pseudonymisation of personal data
Encryption of personal data
Access control and user authentication
Employee, Officials and Coaches’ training on information security
Written information security policies and procedures
Changes to this Record of Processing Activities
Club reserves the right to amend this Record of Processing Activities from time to time consistent with the GDPR and other applicable data protection requirements.
Effective Date: 25 June 2018
Data Privacy Statement
What is the purpose of this document?
Our Club is committed to protecting the privacy and security of your and your child/ward’s (your Player’s) personal information.
This privacy notice describes your rights and our obligations and helps you and the Club to be fully compliant with the provisions of General Data Protection Regulation (GDPR).
Club is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you and your Player.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you and your Player, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of information we hold about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
Please see our Record of Processing Activities for the information we collect, store, and use.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your and your Player’s interests (or someone else’s interests).
2. Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
The situations in which we will process your personal information are listed in the attached Record of Processing Activities. We have indicated the purpose or purposes for which we are processing or will process your and your Player’s personal information, as well as indicating which categories of data are involved.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you and your Player or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of your Player).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with the GDPR.
3. Where it is needed in the public interest, such as for equal opportunities monitoring.
4. Where it is needed to assess your Player’s capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information in the course of our legitimate activities with the appropriate safeguards.
Information about criminal convictions
(if you are not only a Parent/guardian but also a Club Official, coach or volunteer)
We may only use information relating to criminal convictions where the law allows us to do so.
This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with the GDPR and requirements of the Club’s governing bodies.
Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We may also process such information about you in the course of our legitimate activities with the appropriate safeguards.
We will use information about criminal convictions and offences in the following ways:
Where we need to comply with a legal obligation and
Where us using the information is in public interest.
We are allowed to use your personal information in this way.
Data sharing
We may have to share your data with third parties, including third-party service providers.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the training to your Player or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents). The following activities may be carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT, Human Resources.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the Club. We may also need to share your personal information with a governing body or a regulator or to otherwise comply with the law.
Data security
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, officials, coaches, volunteers, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are as stated in the Record of Processing Activities.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you or your Player is no longer a member of our Club, we will retain and securely destroy your personal information in accordance with the applicable laws and regulations.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you or your Player is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data protection officer
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
We are registered with the ICO as a Data Controller.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the Data Protection Officer.