This statement explains how Beccehamiam Rugby Football Club (BRFC) handles and uses the personal
details which it collects about its Members, Associated Clubs, Individual Associates, Corporate Associates
and officials of BRFC in any capacity (hereinafter collectively called Members) and players of the game of
Rugby Union Football (the Game). Retention of this information regarding Members and players enables
BRFC to keep in touch with them in order to keep them advised of BRFC activities, and to enable BRFC to
discharge its responsibilities and to pursue its legitimate interests as a Community Rugby Club of a
National Sport, i.e. the Game. Data may be shared with Constituent Bodies such as, Kent County Rugby
Football Union (KCRFU) and Rugby Football Union (RFU), which may use such data to regulate, develop
and manage the Game. BRFC is committed to protecting all personal information and being open about
the nature of the information it holds. In the event that BRFC, Constituent Bodies or RFU rely upon an
individual’s consent for holding such data, such consent may be withdrawn at any time.
The extent of this Policy:
This policy describes how BRFC will make use of the data it handles in pursuit of its legitimate interests,
including its use of the Game Management System (GMS) provided by RFU, and also describes the RFU’s
use of data on GMS. It also describes Members’ data protection rights, including a right to object to
some processing which BRFC may carry out.
Personal Data Collected and Held:
The personal information held by BRFC will primarily be that provided by Members and players (or, in the
case of minors, by their parents) in correspondence from Members by post, telephone, email or
otherwise. On occasion, details regarding Members and players may be received from rugby clubs within
other Counties or RFU. The records may contain:
Contact details as supplied and periodically updated by Members and players.
The name, gender, and date of birth of individuals.
An individual’s RFU ID (as assigned in GMS).
Passport and other document details (only when DBS clearance is needed. Details deleted after
Club affiliations and details of membership, offices & positions held within the Game.
Bank account details when provided for payment of membership or other fees or to enable
BRFC to make payments.
Personal data supplied by Members and players for specific purposes (e.g. injuries, medical
conditions and disability requirements).
Any qualifications or work experience supplied by an individual. Some information will be
generated as part of an individual’s involvement with BRFC, including development, training,
performance, involvement in particular matches, details of disciplinary issues, and health and safety
Information received from third parties:
BRFC may receive information from third parties, e.g. information regarding a minor supplied by parents.
BRFC may also receive information relating to existing registrations with other clubs or rugby bodies, or
disciplinary history from RFU through GMS, and, especially in the case of those working with children,
information from the Disclosure and Barring Service and RFU.
Use of Personal Data by BRFC:
Members’ Personal Data may be used by BRFC for:
Sending to Members and players details of its activities and inviting them to
Collecting subscriptions and other payments, which may be due.
Discharging its responsibilities as a Community Rugby Club and as prescribed by the RFU.
Internal record keeping.
Photographing and filming of matches and training sessions for the purposes of:
o Training and performance purposes. o Promoting the activities of BRFC.
Purposes required by law, e.g. maintenance of accounting and health and safety records,
compliance with the requirements of government and law enforcement authorities.
Use of Personal Data by RFU:
The RFU provides GMS but makes its own use of the following information:
The name, date of birth and gender of individuals. An individual’s RFU ID (as assigned in GMS).
Involvement in BRFC teams and administration.
The RFU uses this information as follows:
To conduct its business and to pursue its legitimate interests, in particular:
a) Communicating with or about individuals where necessary to administer the Game in
England, including responding to valid questions sent to the RFU about GMS.
b) Administering and ensuring the eligibility of players, match officials, and others
involved in the Game in England, which 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.
c) Maintaining records of the Game, in particular, maintaining details of discipline and
d) Monitoring use of GMS and using this to help it, monitor, improve and protect its
content and services and investigate any complaints received about GMS.
e) Maintaining statistics and conducting analysis on the make-up of the Game’s
f) Ensuring compliance with all current RFU Rules and Regulations.
g) Communicating to seek opinions on RFU initiatives.
h) For purposes required by law, e.g. to ensure that those working with children have
undergone, with their consent, an appropriate DBS check, providing information to
government or law enforcement agencies carrying out an investigation.
Use of Personal Data by Pitchero:
BRFC’s website is managed by Pitchero and details of how they use your personal data can be found here
BRFC will not use personal data for any direct marketing purposes whatsoever.
Sharing of Data:
BRFC may share some limited information with other stakeholders in the Game, such as other
Constituent Bodies, clubs, schools, academies, recognised development organisations with whom BRFC
deals for legitimate purposes, referee societies, league organisers, in order that they may maintain
appropriate records, and assist in organising matches, administering the Game and developing players.
Personal data may be shared with government authorities and/or law enforcement agencies if mandated
by law, or if required for the legal protection of the legitimate interests of BRFC, Constituent Bodies and
RFU in compliance with applicable laws. Personal data may also be shared with third-party service
providers who will process it on behalf of BRFC.
Members’ and players’ Rights:
Members and players have the right to:
Ask BRFC, Constituent Bodies or RFU for access to, or rectification or erasure of, their
individual data Provided that BRFC, Constituent Bodies and RFU will not delete information
that it is required to keep by law, or to comply with RFU Rules and Regulations. Restrict the data provided, subject to the proviso above.
Object to the receipt of communications by any specific method.
Request the transfer of their individual data to a third party.
Members have the right to lodge a complaint with the Information
Commissioner’s Office at https://ico.org.uk/concerns/
Retention of Data:
Members’ and players’ personal data will be processed for as long as they retain their membership or
active involvement with BRFC and for up to six years thereafter. BRFC will retain information to maintain
statutory records in line with appropriate statutory requirements or guidance. The RFU will maintain
records of individuals 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 on
Records of an individual’s involvement in a particular match, on team sheets, on results pages or in
match reports may be held indefinitely by BRFC, Constituent Bodies and RFU in order to maintain a
record of the game.
The legal basis for processing your personal data for the purposes set out above is that it is necessary for
the pursuit of BRFC’s legitimate interests. BRFC always handles personal data securely and minimises its
use, and there is no overriding prejudice to Members and players by using their personal information for
these purposes. However, there is no statutory or contractual requirement for Members and players to
provide BRFC with any personal data.
Those who have concerns or questions about the information contained in this statement, or who do not
want BRFC to process their personal data for specific purposes, should contact the Honorary Secretary,
who at this time is Andy Munro, Club Treasurer, firstname.lastname@example.org . Where Members or players
have specific requests relating to the management of their personal data, BRFC will endeavour to resolve
these but there may be circumstances where it is unable to comply with a specific request.
Anyone who has any concerns about how the RFU processes their data should get in touch with the RFU
at email@example.com or write to The Data Protection Officer, Rugby Football Union, Twickenham Stadium,
200 Whitton Road, Twickenham, TW2 7BA.