Data policy

Summary of how Southwold Rugby and the RFU use your data
> Southwold Rugby uses your personal data to manage and administer your membership and your involvement with its teams and the club, and to keep in contact with you for these
> Some data is shared with the RFU, who use your data to create a personal RFU Membership ID as well as to regulate, develop and manage the game.
> Where Southwold Rugby rely on your consent, such as any consent we seek for email marketing of club events, you can withdraw this consent at any time.
> Amongst the data we collect from you may be relevant medical (including injury) information. We will hold this where you (or your parent) have given consent, so that we can ensure we
are aware of your condition and can that you are supported appropriately.
> Where you work in a particular role within the club, you may be required to undergo a Disclosure & Barring Service check using the RFU’s eDBS system. The result of this check will
be input into the RFU’s Game Management Service (GMS) record.

What does this policy cover?
This policy describes how Southwold Rugby (also referred to as “the Club”, “we” or “us”) will make use of the data we handle in relation to our members and players, including our use of the Game Management System (“GMS”), provided by the Rugby Football Union (“RFU”).
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
What information do we collect?
We collect and process personal data from you or your parent when you join and when we carry out annual renewals of your membership. This includes:
> your name
> your gender,
> your date of birth,
> your RFU ID (as assigned in GMS)
> your home address, email address and phone number;
> your school or college for research and marketing purposes:
> your type of membership and involvement in particular teams, or any key role you may have been allocated, such as Chair, Safeguarding Lead, Membership Secretary etc.;
> your payment and/or bank account details, IF you provide these to pay for membership;
> your contact preferences, including any consents you have given us;
> your medical conditions or disability, where you provide this to us with your consent (or your parent’s consent) to ensure we are aware of any support we may need to provide to you;
> your passport and NI details, where we have to check your eligibility/ability to fulfill particular roles at Southwold Rugby.
Some information MAY be generated as part of your involvement with us, in particular data about your performance, involvement in particular matches in match reports and details of any disciplinary issues or incidents you may be involved in on and off the pitch, such as within health and safety records.
What information do we receive from third parties?
Sometimes, we receive information about you from third parties. For example, if you are in our Minis or Youth sections, we may be given information about you by your parents.
We may receive information relating to your existing registrations with other clubs or rugby bodies or disciplinary history from the RFU through GMS. Additionally, for certain role holders or those working with children, we may receive information from the Disclosure and Barring Service and RFU on the status of any DBS check you have been required to take.

How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
> taking payments;
> communicating with you;
> As required by the Club to conduct our business and pursue our legitimate interests, in particular:
> we will use your information to manage and administer your membership and your involvement with its teams and club, and to keep in contact with you for these purposes;
> we will also use data to maintain records of our performances and history, including match reports, score lines and team sheets;
> we may use CCTV cameras to maintain the security of our premises, and may use this video to investigate incidents at the Club or its premises;
> Where you give us consent:
> we will send you club news and invitations to club events by email;
> we MAY text important news and invitations to club events;
> we MAY text you match details/cancellations
> we MAY handle medical or disability information you or your parent provides to us, to
ensure we support you appropriately;
> For purposes which are required by law:
> we maintain records such as health and safety records in order to meet our duty of care and specific legal requirements;
> we ensure, where you will work with children, that you have undergone an appropriate DBS check – this is also carried out with your consent.
> where you hold a role at the Club requiring us to check your right to work, we may process information to meet our statutory duties;
> we MAY respond to requests by law enforcement authorities conducting an investigation.

How does the RFU use your information?
The RFU provides GMS, but make its own use of the following information:
> your name;
> your gender;
> your date of birth;
> your RFU ID (as assigned in GMS);
> your home address as well as relevant email addresses and phone numbers;
> your type of membership and involvement in particular teams at the Club, or any key role you may have been allocated, such as Chair, Membership Secretary, Communications Officer etc.

The RFU uses this information as follows:
> As required by the RFU to conduct its business and pursue its legitimate interests:
> communicating with you or about you where necessary to administer Rugby in England, including responding to any questions you send to the RFU about GM;
> administering and ensuring the eligibility of players, match officials and others involved in English rugby – this may involve the receipt of limited amounts of sensitive data in relation
to disabled players, where they are registered for a disabled league or team, or in relation to anti- doping matters;
> maintaining records of the game as played in England, in particular maintaining details of discipline and misconduct;
> monitoring use of GMS, and using this to help it monitor, improve and protect its content and services and investigate any complaints received from you or from others about GMS;
> maintaining statistics and conducting analysis on the make-up of rugby’s participants;
> ensuring compliance with the current RFU Rules and Regulations including those on the affiliation of clubs, referee societies, constituent bodies and other rugby bodies, and registration of players; and
> the RFU MAY communicate with you to ask for your opinion on RFU initiatives.
> For purposes which are required by law:
> The RFU will ensure, where you will work with children and where this is required, that you have undergone an appropriate DBS check – this is also carried out with your consent.
> The RFU may respond to requests by government or law enforcement authorities conducting an investigation.

Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below in the “How do I get in touch with you or the RFU?” section.

Who Southwold Rugby share this data with, where and when?
In addition to sharing data with Southwold Rugby coaches, team managers and nominated club officers we will share with the RFU through the GMS.
We are required to share RFU ID numbers, names and dates of birth of Minis and Youth members with tournament organisers.
We are required to share some data with Suffolk RU and Eastern Counties RU team managers if you are selected for trials or representative teams.
We MAY share limited information with other stakeholders in rugby, such as other clubs, Constituent Bodies, referee societies, league organisers, so that they can maintain appropriate records and assist us in organising matches and administering the game.
Personal data MAY be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our or the RFU’s legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on our behalf for the purposes identified above. Such third parties include the RFU as the provider of GMS database and Blythweb as provider of the club’s secure database.
The Club will NOT share your data with any other third parties.

What rights do you have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; The Membership Renewal Form that you receive and sign (or have signed by a parent on your behalf) every year allows you the opportunity to do this.
You have the right toobtain the personal data you provide to us 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 we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
You have the same rights for data held by the RFU for its own purposes on GMS.
To exercise any of these rights, you can get in touch with us at data-protection@southwoldrfc.co.uk or speak to the relevant Membership Secretary (details are on the website and in the Fixture book).
If you have any concerns about how the RFU process your data, you can get in touch at legal@rfu.com or by writing to The Data Protection Officer, Rugby Football Union, Twickenham Stadium, 200 Whitton Road, Twickenham TW2 7BA.

How long will Southwold Rugby retain your data?
Where we process personal data for updating you on club news and marketing club events purposes we will continue to process the data unless you ask us to stop, when we will only process the data for a short period after this (to allow us to time to implement your requests).
We will retain information held to maintain statutory records in line with appropriate statutory requirements or guidance.
The RFU will maintain records of individuals who have registered on GMS, records of DBS checks and the resulting outcomes and other disciplinary matters for such period as is set out in the RFU’s privacy notice to be set out on www.englandrugby.com.
Records of your involvement in a particular match, on team sheets, on results pages or in match reports may be held indefinitely by us on the club website and social media as well as by the RFU in order to maintain a record of the game.