24 May 2018
Penguin International RFC Privacy Policy
Introduction
Penguin International RFC (encompassing the HSBC Penguin International Coaching Academy and Penguin International Rugby Football Trust) and referred to as the Club in this policy, is committed to protecting the privacy of all Club members, players, coaches, match officials, tour officials, Club officials, suppliers and others who are involved with the Club.
The General Data Protection Regulations (GDPR), which come into force on 25th May 2018, have been reviewed and the Club has updated its Privacy Policy (this policy) to align with these new requirements.
The Club’s website, (www.penguinrugby.com) which contains all the latest news, results, and other Club information, can be viewed without telling us who you are, or revealing any information about yourself. The Club may monitor website usage to help develop the website and its services.
Collection, Use and Sharing of Personal Information
The Club will only collect the personal data from Club members and players (including coaches, referees, medical people and volunteers, and referred to as players in this policy) and retains it in order to keep in touch with them and advise of the Club’s activities. The personal data will be primarily that provided by Club members and players and will only be used as required for a particular purpose as specified below.
- names
- email and postal addresses
- phone numbers
- outline CVs
- date of births and gender
- passport information
- insurance information
- records of subscription payments and donations
- certain types of medical information (in relation to travel insurance and information tour managers should know when on tour (e.g. asthma)
- bank account details when you provide them to pay for membership
The Club may receive information from a third party (e.g. a coach might nominate a player for a match or tour and receive information about you from that coach). Additionally, the Club may need to carry out Disclosure and Barring Services checks and this information will be provided by third parties.
The personal data collected is relevant and not excessive to the Club’s activities. Much of the information listed above must be provided on a mandatory basis so that the Club can make the appropriate legal checks and register you as required by the Club and national rugby football unions.
Some information is optional, particularly information such as your medical information (for players, coaches and referees). However if this is not provided, the Club may not be able to select you on some of its activities nor provide appropriate assistance, support or services.
The Club uses the personal information from its members and players, coaches, officials, supporters and suppliers to:
- manage and administer your membership and/or your involvement across all Club activities and keep in contact with you for these purposes.
- to maintain records of the Club’s performances and history, including match reports, scores, team sheets, photos and videos.
- to pass on to third party suppliers (e.g. airlines, hotels and insurers) who will process this information in connection with the Club’s activities on the Club’s behalf.
The Club with not share any personal information with third parties for marketing purposes but may share personal information with:
- other clubs, national unions, referee organisations etc. so they can maintain appropriate records in organising matches and administering the game of rugby football
- government authorities (e.g. to arrange a travel visa) and law enforcement bodies if required, as mandated by law or if required for the legal protection of the Club or national rugby union’s legitimate interest in compliance with applicable laws.
The Club undertakes a number of trips to many different countries in the world. The Club will only transfer such personal data as is essential for the particular trip and will endeavour to ensure that it is protected in the same way as described in this policy, including requiring any recipient of personal data to agree to protect the data in the same way as described in this policy.
It is assumed that all Club members will want to receive the regular newsletters and other communications the Club produces, so no opt out is required.
Retention of personal data
The Club will hold your personal data for as long as you are an active Club member or involved in Club activities unless you ask it to delete the data, when it will only process the data for a short period after this (to allow it to implement your requests).
There are available on the Club’s website, forms for you to keep the personal data the Club holds up to date. The Club will update its records if it becomes aware of changes (e.g. when an email bounces or a letter is returned with an unknown name at the address). If at any time you wish to update the personal data which the Club hold about you, please contact us.
The Club will keep a record of the fact that you have asked us not to send you Club marketing information or to process your data indefinitely so that it can respect your request in future. When a Club member resigns or passes away the Club will delete the relevant personal data within a reasonable period of time
Where the Club holds personal data in connection with the performance of a contract or for a playing, coaching or refereeing activity, it will keep the data for 6 years from your last interaction with the Club.
The Club will retain information to maintain statutory records in line with appropriate statutory requirements or guidance.
Records of your involvement in a particular match, on team sheets, on results pages or in match reports may be held indefinitely by the Club and the opposition teams or host clubs, provinces or unions, in order to maintain a record of the game.
Security of Personal Data
All electronic data will be kept on computers with log in passwords and individual files will be password protected. Only Club officials who need access to the personal data will have the passwords and will only access the personal date in connection with the Club’s activities
All emails which contain information covered by the data protection legislation will be stored on computers with log in passwords until they are deleted. From time to time the Club will need to transfer personal data via email and the information sent by email will be limited to the specific data required for the purpose of the email
In certain circumstances paper copies are made containing information covered by data protection legislation. Wherever practical these copies are kept secure by the person who has the information. After the purpose for which the copies are made has been completed they are destroyed
Links
The Club’s website has links to other websites. The Club is not responsible for the privacy practices, or the content of external web sites. In particular, the link to Tsunami from the Club’s Merchandise page on the website redirects users to a third party website over which the Club has no control.
Consent
Wherever the Club relies on your consent, you will always be able to withdraw that consent, although the Club may have other legal grounds for processing your personal data for other purposes, such as set out above. By submitting your personal data to the Club, you signify your consent to the Club using the data provided in the manner described above in this policy.
Personal Rights
The legal basis for holding and processing your personal data for the purposes set out in this Privacy Policy is that it is necessary for the pursuit of the Club’s legitimate interests and there is no overriding prejudice to Club members and players by using their personal data for these purposes
You have the right to ask the Club for a copy of your personal data; to correct, delete, restrict, or stop any active processing of your personal data; and to obtain the personal data you provide to the Club for a contract or with your consent in a structured, machine readable format.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where the Club does not have your consent to process the data to meet a contractual or other legal requirement).
These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask the Club to delete data which the Club are required by law to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with the Club using the details set out below.
Email: membership@penguinrugby.com
If you have unresolved concerns, you have the right to complain to the Information Commissioner’s Office.
