PRIVACY POLICY

Henley Rugby Football Club – Data Privacy Policy

The GDPR replaces existing data protection legislation on 25 May 2018. Henley Rugby Club has undertaken a detailed review and concluded that it already complies with the GDPR. There are three key facts that are of direct relevance to you as a member.

There is:

• no action that you need to take or any response that you need to provide;
• no change in the way that we will process, store and use your data; and
• no change in the basis of your membership of HRFC.

This policy sets out the following:

• What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, loyalty card and online shop.
• Where we obtain the data from.
• What we do with that data.
• How we store the data.
• Who we transfer/disclose that data to.
• How we deal with your data protection rights.
• And how we comply with the data protection rules.

All personal data is collected and processed in accordance with English and EU data protection laws.

Personal data means any information relating to you which allows us to identify you, such as your name, contact details, customer account/reference number, payment details etc.

We will collect personal data from you when you join or renew your club membership, or when you contact us or register interest.

Specifically, we may collect the following categories of information:

• Contact data (your name, email address, postal address, phone number, date of birth, gender and any other relevant information we need in order to contact or identify you).
• Financial data (your bank account and payment details relating to products and services you receive from us).
• Usage data (information about how you use our website, products and services).
• Marketing and communications data (your preferences in receiving marketing from us and our third parties and your communication preferences).

When will we collect it?

We collect certain personal information from and about you during your membership and when you get in contact with us or use our website, loyalty card system or as part of providing our services to you.

We may also monitor and record any communications we have with you, including phone calls, emails, web chats, letters and social media exchanges to make sure we are providing you an excellent service. We may contact you by telephone, web chat, email, post or in person as necessary.

Your data may be used for the following purposes:

• Providing products and services you request We use the information you give us to perform the services you have asked for in relation to your contract and account. These communications are not made for marketing purposes and cannot be opted-out of.
• Administrative or legal purposes We may use your data for statistical and marketing analysis, systems testing, customer surveys, maintenance and development, or in order to deal with a dispute or claim. Note that we may perform data profiling based on the data we collect from you for statistical and marketing analysis purposes. By providing any personal data you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy;
• Security, health, administrative, crime prevention/detection We may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
• Customer Services communications We use your data to manage our relationship with you as a member of our club and to improve our services and enhance your experience with us;
• Provide tailored services We use your data to provide information we believe is of interest to you, during, and after your membership with us and to personalise the services we offer to you, such as special offers or deals;

Marketing information

When you first provide your personal information to us, we will use Legitimate Interest as the legal basis to process your data. We may use your identity, contact, usage and profiled data to tell you about new products and services from us. We collect data through our website, membership portal and the club loyalty card system. You may be contacted by email, post or telephone.

If you decide you want to opt-out of receiving marketing communications or want to change how you receive them, you can always change your preferences by contacting us at any time. This won’t affect any marketing information we sent to you before you let us know.

Processing your Data

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for. In most cases we will need to process your personal data so we can enter into our contract with you.

We may also process your personal data for one or more of the following reasons:-

• To comply with a legal obligation.
• You have consented to us using your personal data (e.g. for marketing related uses).
• To protect your vital interests or those of another person.
• It is in our legitimate interests in operating as a company (e.g. for administrative purposes and marketing related uses).

We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.

We may disclose your information to trusted third parties for example the RFU for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with English and EU law on data protection rules, although we cannot be held liable to this extent.

Who do we share your data with?

We may also share your personal data with the following third parties for the purpose described in this Privacy Policy:

• Government authorities and regulators for compliance with legal requirements.
• The Rugby Football Union for playing and coaching compliance in line with the club’s affiliation and legal obligations. Details of the RFU’s data protection policy is here (add Hyperlink to GMS page)
• Complaints bodies such as the RFU.
• Trusted service providers we are using to run our business such as OpenSolutions and Bimotech, 81Events.
• Credit and debit card companies and debt collection agencies, which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction.
• Legal and other professional advisers, law courts and law enforcement bodies in order to enforce our legal rights in relation to our contract with you.
• Social media: You may be able to access third party social media services through our website or before coming to our website. When you are registered with your social media account, we will obtain the personal information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalise your use of our website. We may also use social media plugins on our website. As a result, your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of these third-party social media providers to find out more about these practices.

We do not share your data with any of our sponsors or advertisers.

Disclosing information outside the EU

Sometimes the organisations listed above may be outside the EU, so we may pass your personal information to countries that do not have the same standards or protection for personal information as the UK. If we, our agents or our service providers do this, we will try and ensure that these organisations adequately secure your personal information.

Protecting your personal information

We follow strict security procedures to protect your personal information. This includes following certain guidelines (for example, checking your identity when you phone us).

We strongly recommend that you do not disclose any membership or loyalty card account login details to anyone. Please always remember to logout of your account when you have finished using any of our websites.

From time to time, our website may provide hypertext links to sites which are created by external individuals and companies. We do this if the site is relevant to the topic you’re reading about. Whilst we always try to check that the content of these sites is suitable, we cannot take any responsibility for the practices of the companies who publish the sites that we link to, or the accuracy or relevance of the content on them.

Membership Accounts

All data collected within your Membership Account will be processed in line with this Privacy Policy. For clarity, the membership account may refer to membership of HRFC, the club’s loyalty card system and online shop.

We understand the importance of taking extra precautions to protect the privacy and safety of children. You must be over 18 to sign up and have a contract with us, therefore anyone under this age should not have access to any membership account details. We will delete any membership account created by a person under the age of 18, as soon as we are made aware of it.

When our use of your personal data is based on your consent, you have the option to withdraw your consent to our processing and delete your personal data at any time by contacting us and requesting this.

We keep your personal information contained in your membership account until such time you request it is erased. Please note that general retention periods apply to any personal data we collected to enter into a contract with you or to perform that contract or because we have a legal obligation to process it.

Requesting your Data

The club has a dedicated person to oversee compliance with this policy. You have the right to make a complaint at any time to this person.

Under certain circumstances, by law you have the right to:

• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
• 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.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
• 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 transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• 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. 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.

If you want to exercise any of these rights, then please contact us:

• Email at admin@henleyhawks.co.uk
• Post at Henley Rugby Club, Dry Leas, Marlow Road, Henley-on-Thames.
• Phone on 01491 574499

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.

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

Our Privacy Policy may change from time to time, changes will be posted on this page when they do occur. This is version is up to date as of 22nd June 2018.