Knutsford Sports Club (KSC) is a community sports club with around 500 members at the start of 2018. We aim to provide facilities for, and promote participation of, the whole community in the sports of Cricket, Archery, Squash and Tennis. Cricket has been on the site at Mereheath Lane since 1881 and in Victorian times the site was used generally as a sporting area. Tennis was played on the site in the 1930s and was re-formed in 1970. Squash built the courts in 1984. Archery arrived in 2011 as the North Cheshire Bowmen.
KSC is an 'umbrella' club that is responsible for the provision and administration of the club house and all shared services. Most of the members are members of one or more of the four sport sections which also includes membership of KSC. The responsibility for maintaining and controlling the personal data for all these members remains with the sport section(s) that they are members of. This GDPR policy covers the main club and all the sport sections while each sport section has developed their own procedures for meeting the requirements of this policy and GDPR which may also include an additional sport specific policy.
A small number of people are social members of KSC without being active sport participants but they have become members through one of the sport sections and their contact data is held and controlled by that sport section. KSC has the responsibility for controlling the personal data of the honorary members and the data of any employees or contractors that provide services to KSC.
KSC, and the four sport sections, take the privacy of our members' data seriously and will only use personal information for club administration purposes and for communicating with members about their membership and activities within the club. Some information from the sport sections has to be shared with either the Treasurer, auditors and/or the Membership Secretary of the main club committee.
· Data that can be shared for administration is postal address, Date of Birth (if under 18) and data about payments, membership category and membership renewal renewal
· Other data could be held if it records what a member has done while in the Club e.g. handicap, team, position/ structure or is necessary to access member-only information (e.g. logon id and password to get into the website)
· Data held on people who are not members – such as those subscribing to the Jackpot Draw and/or the Gift Aid scheme
· Committee members, Club administrators and any other person having to access any personal data will be expected to comply with this policy
Data on people and/or organisations who hire our facilities is maintained by the bookings manager for the duration of the period covered by the booking. Data on companies and individuals that provide products or services to KSC is maintained by the Treasurer and individuals within KSC and the four sport sections. This data is treated in the same way that members' personal data is treated and is never sold or shared with any third parties. This data is maintained for practical and contractual purposes only. On joining, members will notified of the data protection/ confidentiality policy on the membership application for each section.
All the members of the KSC committee are members of one or more of the sports sections and their personal data is controlled by these sections. However, some contact information is made publicly available so that all members of the sports club can contact them. Names and mobile phone numbers are listed on the KSC website and e-mail addresses may be made available. All committee members have that information for all the committee members. We understand that many electronic devices, programmes and apps automatically store contact information, e.g. MS Outlook automatically retains e-mail addresses that have been used. All committee members are aware of that when making their contact details available.
The personal data held by each sport section will be the minimum that is required for the administration of each sport section and may be required by the sport's governing body. KSC will never share or sell any personal member's data without prior permission. That includes publishing any personal information to allow club members to contact each other for sport or social reasons. Any contact by a sport section with its members will not display names or contact information. Members may set up their own social network contact methods to organise sport and social events additional to anything organised by the sport sections and these are out with the scope of this policy.
Personal Data is information about a living individual that is processed automatically (e.g. by a computer) or held within a relevant filing system (e.g. manual records system) or recorded with the intention of processing or filing it, and which enables the individual to be identified or identifiable. Personal data can include photographs or images, in digital or analogue (non-digital) form, where the name of a person can be linked to the image.
Sensitive Personal Data is personal data (as above) that consists of information on someone's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health condition, sex life, offences (committed or alleged), or proceedings/sentences for those offences. As with personal data, sensitive personal data could take the form of photographs or images. The presumption is that, because information about these matters could be used in a discriminatory way, and is likely to be of a private nature, it needs to be treated with greater care than other personal data.
· Hold your data securely, whether the information is held in paper-based record keeping or on computer;
· Share only where you agree;
· Use your data to provide you with information about KSC;
· Ensure you can update, delete and access your data;
The membership secretary will store the names of the honorary members as described in #MOU 11 either as hard copy or securely on a personal computer. No postal or e-mail address or phone numbers are stored for any honorary members.
If you use other services, like Facebook, to interact with KSC then details about how your personal information is held is described within the relevant social media policy, such as Facebook. We use a third party provider to manage our website but they retain no information about anyone who contacts KSC via the web site or who looks at the web site.
Under the General Data Protection Regulations, you have rights as an individual which you can exercise in relation to the information we hold about you. (You can read more about your individual rights on the Information Commissioner's Office website.) Individuals can find out if we hold any personal information by asking the membership secretary. We intend keeping our Data Policy under regular review to ensure we comply with GDPR and to ensure that your data is kept private. This data policy was last updated on 1st June 2018.
KSC did not need to register with the Information Commissioner because it was established for not-for-profit making purposes and does not make a profit or makes a profit for its own purposes, it not being used to enrich others. That situation is still applicable. In addition we will only:
process information necessary to establish or maintain membership or support
process information on non-members who participate in activities such as the Jackpot Draw, are Gift Aid subscribers or facility hirers
process information necessary to provide or administer activities for people who are members of the organisation or have regular contact with it
share the information with people and organisations necessary to carry out the organisation’s activities
keep the information while the individual is a member or supporter or as long as necessary for member/supporter administration.
The Secretary of the main club committee has been designated as the person responsible for data protection compliance but we do not need to formally designate a Data Protection Officer.
Although the KSC committee have no direct responsibility for controlling the personal data of the members of the four sport sections it was decided that to ensure that each of the sport sections are fulfilling their responsibilities under this policy and GDPR. Therefore an audit procedure is in place whereby the KSC Secretary will carry out an annual audit of the GDPR procedure(s) that each sports section has in place to control and manage the personal data of their members. The purpose of the first audit will be to confirm that appropriate procedures are in place, that members have been informed about these procedures and their rights under the new law and that the procedures are in use. The first audit will be a general 'fact finding' audit to ensure that each sport has procedures in place and subsequent audits may be tailored to suit the procedures each sport has put in place.
Since the KSC GDPR policy was written by the club secretary another member of the KSC committee will carry out an audit of this policy.