ASHTON UNITED FOOTBALL CLUB
Privacy Notice – 1/2
ASHTON UNITED FOOTBALL CLUB ("we", "our", "us") take your privacy very seriously.
This Privacy Notice sets out how we use and look after the personal information we collect from you. We are the data controller, responsible for the processing of any personal data you give us. We take reasonable care to keep your information secure and to prevent any unauthorised access to or use of it.
What personal data we hold on you
Personal data means any information about an individual from which that individual can be identified.
We collect, use, store and transfer some personal data of our participants [and their parents or guardians], and other Club members.
You provide information about yourself when you register with the Club, and by filling in forms at an event or online, or by corresponding with us by phone, e-mail or otherwise.
The information you give us may include your name, date of birth, address, e-mail address, phone number, gender, and the contact details of a third party in the case of emergency. We may also ask for relevant health information, which is classed as special category personal data, for the purposes of your health, wellbeing,welfare and safeguarding. Where we hold this data it will be with the explicit consent of the participant or, if applicable, the participant’s parent or guardian.
Where we need to collect personal data to fulfil Club responsibilities and you do not provide that data, we may not be able honour or administer your membership.
Why we need your personal data
We will only use personal data for any purpose for which it has been specifically provided.
The reason we need participants’ and members’ personal data is to be able to run the football club and arrange matches; to administer memberships, and provide the membership services you are signing up to when you register with the club. Our lawful basis for processing your personal data is that we have a contractual obligation to you as a participant or member to provide the services you are registering for.
Personal data that is shared and more importantly needed is listed and may not be limited to the following:-
Who we share your personal data with
When you become a member of the Club, your information, if you are a coach or volunteer will be or if you are another participant may be (depending upon which league(s) your team plays in) entered
Privacy Notice – 2/2
onto the Whole Game System database, which is administered by the FA. We also pass your information to the County FA and to leagues to register participants and the team for matches, tournaments or other events, and for affiliation purposes.
We may share your personal data with selected third parties, suppliers and sub-contractors such as referees, coaches or match organisers. Third-party service providers will only process your personal data for specified purposes and in accordance with our instructions.
We may disclose your personal information to third parties to comply with a legal obligation; or to protect the rights, property, or safety of our participants, members or affiliates, or others.
The Club’s data processing may require your personal data to be transferred outside of the UK. Where the Club does transfer your personal data overseas it is with the sufficient appropriate safeguards in place to ensure the security of that personal data.
Protection of your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
How long we hold your personal data
Your rights regarding your personal data
As a data subject you may have the right at any time to request access to, rectification or erasure of your personal data; to restrict or object to certain kinds of processing of your personal data, including direct marketing; to the portability of your personal data and to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office about the processing of your personal data.
As a data subject you are not obliged to share your personal data with the Club. If you choose not to share your personal data with us we may not be able to register or administer your membership.
We may update this Privacy Notice from time to time, and will inform you to any changes in how we handle your personal data.
If you have any questions about this Privacy Notice then please contact Jackie Tierney.
Data Protection Policy
About this Policy
This Policy is to help clubs, County Football Associations and football leagues deal with data protection matters internally. This should be kept with other club / County Football Association / football league policies and a copy should be given (or made available) to all staff members, volunteers and others who come into contact with personal data during the course of their involvement with the club (ASHTON UNITED) / County Football Association (MANCHESTER FA) / football league
ASHTON UNITED FOOTBALL CLUB (“we”, “our”, “us”) handle personal data about current, former, and on occasion prospective players, employees, volunteers, committee members, coaches, managers, contractors, third parties, suppliers, and any other individuals that we communicate with.
In your official capacity with the football club you may process personal data on our behalf and we will process personal data about you. We recognise the need to treat all personal data in an appropriate and lawful manner, in accordance with the EU General Data Protection Regulation 2016/679 (GDPR).
Correct and lawful treatment of this data will maintain confidence in the football club, and protect the rights of players and any other individuals associated with the Club / Manchester FA / current Football League. This Policy sets out our data protection responsibilities and highlights the obligations of the Club / Manchester FA / Football League, which means the obligations of our employees, committee, volunteers, members, and any other contractor or legal or natural individual or organisation acting for or on behalf of the Club / Manchester FA / Football League..
You are obliged to comply with this policy when processing personal data on behalf of the Club / Manchester FA / Football League and this policy will help you to understand how to handle personal data.
The Club / Manchester FA / Football League & board of Director’s will be responsible for ensuring compliance with this Policy. Any questions about this Policy or data protection concerns should be referred to the committee.
We process employee, player, volunteer, member, referee, coach, manager, contractor, committee, supplier and third party personal data for administrative Club / Manchester FA / Football League management purposes. Our purpose for holding this personal data is to be able to contact relevant individuals on Club / Manchester FA / Football League business or administer the terms of your employment, and our legal basis for processing your personal data in this way is the contractual relationship we have with you. We will keep this data for 12 months after the end of your official relationship with the Club / Manchester FA / League unless required otherwise by law and / or regulatory requirements. If you do not provide your personal data for this purpose, you will not be able to carry out your role or the obligations of your contract with the Club / Manchester FA / Football League.
All the key definitions under GDPR can be found here.
What we need from you
To assist with our compliance with GDPR we will need you to comply with the terms of this policy. We have set out the key guidance in this section but please do read the full policy carefully.
Please help us to comply with the data protection principles (set out briefly in section 3 of this policy and in further detail below):
please ensure that you only process data in accordance with our transparent processing as set out in our Privacy notice;
please only process personal data for the purposes for which we have collected it (i.e. if you want to do something different with it then please speak to Jackie Tierney first);
please do not ask for further information about players and / or members and / or staff and / or volunteers without first checking with Jackie Tierney;
if you are asked to correct an individual’s personal data, please make sure that you can identify that individual and, where you have been able to identify them, make the relevant updates on our records and systems;
please comply with our retention periods listed in our Privacy Notice and make sure that if you still have information which falls outside of those dates, that you delete/destroy it securely;
please treat all personal data as confidential. If it is stored in electronic format then please consider whether the documents themselves should be password protected or whether your personal computer is password protected and whether you can limit the number of people who have access to the information. Please also consider the security levels of any cloud storage provider (and see below). If it is stored in hard copy format then please make sure it is locked away safely and is not kept in a car overnight or disposed of in a public place;
if you are looking at using a new electronic system for the storage of information, please talk to Jackie Tierney first so that we can decide whether such a system is appropriately secure and complies with GDPR;
if you are planning on sharing personal data with anybody new or with a party outside the FA structure then please speak to Jackie Tierney before doing so who will be able to check that the correct contractual provisions are in place and that we have a lawful basis to share the information;
if you receive a subject access request (or you think somebody is making a subject access request for access to the information we hold on them) then please tell Jackie Tierney as soon as possible because we have strict timelines in which to comply;
if you think there has been a data breach (for example you have lost personal data or a personal device which contains personal data or you have been informed that a coach has done so, or you have sent an email and open copied all contacts in) then please speak to Jackie Tierney who will be able to help you to respond.
If you have any questions at any time then please just ask Jackie Tierney. We are here to help.
Data protection principles
Anyone processing personal data must comply with the enforceable principles of data protection. Personal data must be:
processed lawfully, fairly and in a transparent manner;
collected for only specified, explicit and legitimate purposes;
adequate, relevant and limited to what is necessary for the purpose(s) for which it is processed;
accurate and, where necessary, kept up to date;
kept in a form which permits identification of individuals for no longer than is necessary for the purpose(s) for which it is processed;
processed in a manner that ensures its security by appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage;
We are responsible for and must be able to demonstrate compliance with the data protection principles listed above.
Fair and lawful processing
This Policy aims to ensure that our data processing is done fairly and without adversely affecting the rights of the individual.
Lawful processing means data must be processed on one of the legal bases set out in the GDPR. When special category personal data is being processed, additional conditions must be met.
Processing for limited purposes
Ashton United Football Club collects and processes personal data. This is data we receive directly from an individual and data we may receive from other sources.
We will only process personal data for the purposes of Ashton United Football Club as instructed by the committee, Football League, the County FA or The FA, or as specifically permitted by the GDPR. We will let individuals know what those purposes are when we first collect the data or as soon as possible thereafter.
One of the lawful bases on which we may be processing data is the individual’s consent.
An individual consents to us processing their personal data if they clearly indicate specific and informed agreement, either by a statement or positive action.
Individuals must be easily able to withdraw their consent at any time and withdrawal must be promptly honoured. Consents should be refreshed every season.
Explicit consent is usually required for automated decision-making and for cross-border data transfers, and for processing special category personal data. Where children are involved then the consent must be in writing from parent/guardian
Where consent is our legal basis for processing, we will need to keep records of when and how this consent was captured.
Our Privacy Notice sets out the lawful bases on which we process data of our players and members.
Where we collect personal data directly from individuals, we will inform them about:
the purpose(s) for which we intend to process that personal data;
the legal basis on which we are processing that personal data;
where that legal basis is a legitimate interest, what that legitimate interest is;
where that legal basis is statutory or contractual, any possible consequences of failing to provide that personal data;
the types of third parties, if any, with which we will share that personal data, including any international data transfers;
their rights as data subjects, and how they can limit our use of their personal data;
the period for which data will be stored and how that period is determined;
any automated decision-making processing of that data and whether the data may be used for any further processing, and what that further processing is.
If we receive personal data about an individual from other sources, we will provide the above information as soon as possible and let them know the source we received their personal data from;
We will also inform those whose personal data we process that we, Ashton United / Manchester FA / Football League, are the data controller in regard to that data, and which individual(s) in Ashton United / Manchester FA / Football League are responsible for data protection.
Adequate, relevant and non-excessive processing
We will only collect personal data that is required for the specific purpose notified to the individual.
You may only process personal data if required to do so in your official capacity with Ashton United / Manchester FA / Football League. You cannot process personal data for any reason unrelated to your duties.
Ashton United / Manchester FA / Football League must ensure that when personal data is no longer needed for specified purposes, it is deleted or anonymised.
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at the start of each season. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
We will not keep personal data longer than is necessary for the purpose(s) for which they were collected. We will take all reasonable steps to destroy or delete data which is no longer required, as per our Privacy Notice.
Processing in line with data subjects’ rights
As data subjects, all individuals have the right to:
be informed of what personal data is being processed;
request access to any data held about them by a data controller;
object to processing of their data for direct-marketing purposes (including profiling);
ask to have inaccurate or incomplete data rectified;
be forgotten (deletion or removal of personal data);
data portability; and
not be subject to a decision which is based on automated processing.
Ashton United is aware that not all individuals’ rights are absolute, and any requests regarding the above should be immediately reported to the committee, and if applicable escalated to the Manchester FA / FA for guidance.
We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
We have proportionate procedures and technology to maintain the security of all personal data.
Personal data will only be transferred to another party to process on our behalf (a data processor) where we have a GDPR-compliant written contract in place with that data processor.
We will maintain data security by protecting the confidentiality, integrity and availability of the personal data.
Our security procedures include:
Entry controls. Any stranger seen in entry-controlled areas should be reported.
Secure desks, cabinets and cupboards. Desks and cupboards should be locked if they hold personal data.
Methods of disposal. Paper documents should be shredded. Digital storage devices should be physically destroyed.
Equipment. Screens and monitors must not show personal data to passers-by, and should be locked when unattended. Excel spreadsheets will be password protected.
Personal Devices. Anyone accessing or processing Ashton United / Manchester FA / Football League’s personal data on their own device, must have and operate a password only access or similar lock function, and should have appropriate anti-virus protection. These devices must have Ashton United / Manchester FA / Football League’s personal data removed prior to being replaced by a new device or prior to such individual ceasing to work with or support Ashton United / Manchester FA / Football League. Disclosure and sharing of personal information
We share personal data with Manchester FA & The FA, and with applicable leagues using Whole Game System.
We may share personal data with third parties or suppliers for the services they provide, and instruct them to process our personal data on our behalf as data processors. Where we share data with third parties, we will ensure we have a compliant written contract in place incorporating the minimum data processer terms as set out in the GDPR, which may be in the form of a supplier’s terms of service.
We may share personal data we hold if we are under a duty to disclose or share an individual’s personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the individual or other agreements; or to protect our rights, property, or safety of our employees, players, other individuals associated with the Ashton United / Manchester FA / Football League or others.
Transferring personal data to a country outside the EEA
We may transfer any personal data we hold to a country outside the European Economic Area (EEA), provided that one of the appropriate safeguards applies.
Reporting a personal data breach
In the case of a breach of personal data, we may need to notify the applicable regulatory body and the individual.
If you know or suspect that a personal data breach has occurred, inform a member of the committee immediately, who may need to escalate to the Manchester FA / FA as appropriate. You should preserve all evidence relating to a potential personal data breach.
Dealing with subject access requests
Individuals may make a formal request for information we hold about them. Anyone who receives such a request should forward it to the board/committee immediately, and where necessary escalated to the Manchester FA / FA for guidance. Nobody should feel bullied or pressured into disclosing personal information.
When receiving telephone enquiries, we will only disclose personal data if we have checked the caller's identity to make sure they are entitled to it.
Ashton United / Manchester FA / Football League must implement appropriate technical and organisational measures to look after personal data, and is responsible for, and must be able to demonstrate compliance with the data protection principles.
Ashton United / Manchester FA / Football League must have adequate resources and controls in place to ensure and to document GDPR compliance, such as:
providing fair processing notice to individuals at all points of data capture;
training committee and volunteers on the GDPR, and this Data Protection Policy; and
reviewing the privacy measures implemented by the Ashton United / Manchester FA / Football League.
Changes to this policy
We reserve the right to change this policy at any time. Where appropriate, we will notify you by email.
This policy sets out how we collect, process and hold your personal data if you visit our online shop or otherwise provide personal data to us. We are Kaizen Ticketing Solutions LTD of 459b Green Lanes, London, N13 4BS. We are the data controller of your personal data.
This policy affects your legal rights and obligations so please read it carefully. If you have any questions, please contact us via email or call us on 0208 858 0709.
Personal data we collect
We collect, process, store and use personal data when you book a ticket or purchase a piece of merchandise including your name, address and email address together with payment information. We may also collect personal data that you give to us about other people if you register them to attend an event. You agree that you have notified any other person whose personal data that you provide to us of this privacy notice and, where necessary, obtained their consent so that we can lawfully process their personal data in accordance with this policy.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect identify fraud, we will record this.
You do not need to provide us with any personal data to view our online shop. However, we may still collect the information set under the Data we automatically collect section of this policy, and marketing communications in accordance with the Marketing Communications section of this policy.
When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
Data we automatically collect
When you visit our online shop, we, or third parties on our behalf, automatically collect and store information about your device and your activities. This information could include (a) your computer or other device's unique ID number; (b) technical information about your device such as type of device, web browser or operating system; (c) your preferences and settings such as time zone and language; and (d) statistical data about your browsing actions and patterns. We collect this information using cookies in accordance with the Cookie section of this policy and we use the information we collect on an anonymous basis to improve our online shop and the services we provide, and for analytical and research purposes.
If you opt in to receive marketing communications from us you consent to the processing of your data to send you such communications, which may include newsletters, blog posts, surveys and information about new events. We retain a record of your consent.
You can choose to no longer receive marketing communications by contacting us via email, clicking unsubscribe from a marketing email or updating your preferences in your online account. If you do unsubscribe to marketing communications, it may take up to 5 business days for your new preferences to take effect. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.
Lawful processing of your personal data
We will use your personal data in order to comply with our contractual obligation to supply to you the tickets to an event that you have booked or merchandise you have ordered, including to contact you with any information relating to the event or merchandise, and to deal with any questions, comments or complaints you have in relation to the event or merchandise.
We may also use your personal data for our legitimate interests, including dealing with any customer services you require, enforcing the terms of any other agreement between us, for regulatory and legal purposes (for example anti-money laundering), for audit purposes and to contact you about changes to this policy.
Who do we share your data with?
We may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, email communication providers, IT service providers, accountants, auditors and lawyers.
Under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering processes or protect a third party's rights, property, or safety.
We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
Where we hold and process your personal data
Some or all of your personal data may be stored or transferred outside of the European Union (the EU) for any reason, including for example, if our email server is located in a country outside the EU or if any of our service providers or their servers are based outside of the EU. We shall only transfer your personal data to organisations that have provided adequate safeguards in respect of your personal data.
A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites to identify when users revisit that website.
We also use Google Analytics to monitor how the online shop is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to the online shop, where visitors generally came from, how long they stayed on the site, and which pages they visited. Google Analytics places several persistent cookies on your computer's hard drive. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. All information you provide to us is stored on our secure servers. Any payment transactions are encrypted using SSL technology.
Where we have given, or you have chosen a password, you are responsible for keeping this password confidential.
However, you acknowledge that no system can be completely secure. Therefore, although we take these steps to secure your personal data, we do not promise that your personal data will always remain completely secure.
You have the right to obtain from us a copy of the personal data that we hold for you, and to require us to correct errors in the personal data if it is inaccurate or incomplete. You also have the right at any time to require that we delete your personal data. To exercise these rights, or any other rights you may have under applicable laws, please contact us via email.
Please note, we reserve the right to charge an administrative fee if your request is manifestly unfounded or excessive.
If you have any complaints in relation to this policy or otherwise in relation to our processing of your personal data, you should contact the UK supervisory authority: the Information Commissioner (www.ico.org.uk).
If you register with us, we shall retain your personal data until you close your account.
If you receive marketing communications from us, we shall retain your personal data until you opt out of receiving such communications.
If you have otherwise made a booking with us or contacted us with a question or comment, we shall retain your personal data for 48 months following such contact to respond to any further queries you might have.
If any provision of this policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.
This policy shall be governed by and construed in accordance with the law of England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.
We may change the terms of this policy from time to time. You are responsible for regularly reviewing this policy so that you are aware of any changes to it. If you continue to use our online shop after the time we state the changes will take effect, you will have accepted the changes.