Summary of how we and the RFU/SRU use your data
• Berwick Rugby Football Club uses your personal data 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 also use your details when you use us for hospitality purposes or when renting Club facilities or equipment from us.
• Some data is shared with the RFU/SRU, who use your data to regulate, develop and manage the game.
• Data is also shared with our website host Pitch Hero Limited. They must also comply with GDPR and data protection policies. Full details of their policy is available on the website.
• Where we or the RFU/SRU rely on your consent, such as any consent we seek for email marketing, you can withdraw this consent at any time.
• Amongst the data we collect from you may be 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 ensure that you are supported appropriately.
• Where you work in a particular role within the game, 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 your Game Management Service (GMS) record.
What does this policy cover?
This policy describes how Berwick Rugby Football Club (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”) and our use of the SCRUMS Management System (”SCRUMS”) provided by the Scottish Rugby Football Union (”SRU”). The policy also describes the RFU’s use of data on GMS and the SRU’s use of data on SCRUMS.
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) or SRU ID (as assigned in SCRUMS);
• your home address, email address and phone number;
• your passport and NI details, where we have to check your eligibility or ability to work for us;
• 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, where you provide these to pay for membership;
• your marketing 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.
Some information will 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 a child, 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 and from the SRU through SCRUMS. 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:
• To fulfil a contract, or take steps linked to a contract: this is relevant where you make a payment for your membership and any merchandise, or enter a competition. This includes:
o taking payments;
o communicating with you;
o providing and arranging the delivery or other provision of products, prizes or services;
• As required by the Club to conduct our business and pursue our legitimate interests, in particular:
o 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;
o we will also use data to maintain records of our performances and history, including match reports, score lines and team sheets;
o we use CCTV cameras to maintain the security of our premises, and may use this video to investigate incidents at the Club or its premises;
o we may choose to send you promotional materials and offers by post or by phone, or by email where we want to send you offers relating to similar products and services that you have already bought;
o we use data of some individuals to invite them to take part in market research;
• Where you give us consent:
o we will send you direct marketing or promotional material by email;
o we may handle medical or disability information you or your parent provides to us, to ensure we support you appropriately;
o on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
• For purposes which are required by law:
o we maintain records such as health and safety records and accounting records in order to meet specific legal requirements;
o we ensure, where you will work with children, that you have undergone an appropriate DBS check – this is also carried out with your consent.
o 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;
o we may respond to requests by government or law enforcement authorities conducting an investigation.
How does the RFU use any of my 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, email address and phone number; and
• your type of membership and involvement in particular teams at the Club, or any key role you may have been allocated, such as Chair, Safeguarding Lead, Membership Secretary etc.
The RFU uses this information as follows:
• As required by the RFU to conduct its business and pursue its legitimate interests, in particular:
o communicating with you or about you where necessary to administer Rugby in England, including responding to any questions you send to the RFU about GMS;
o 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;
o maintaining records of the game as played in England, in particular maintaining details of discipline and misconduct;
o 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;
o maintaining statistics and conducting analysis on the make-up of rugby’s participants;
o 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
o communicating with you to ask for your opinion on RFU initiatives.
• For purposes which are required by law:
o 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.
o The RFU may respond to requests by government or law enforcement authorities conducting an investigation.
How does the SRU use any of my information?
1. What personal information we collect
We may collect, hold and use the following personal information from or about you:
• your name, address, date of birth, telephone number, email address and gender;
• your billing address, bank account and payment card details;
• your purchasing preferences;
• your image (if filmed or recorded when attending our sites or events);
• details of your use of our IT systems, applications and websites (including traffic data, location data, weblogs and other communication data and the resources you access);
• information about your computer, including your IP address, operating system and browser type; and
• any other personal information you provide to us when contacting or corresponding with us, when requesting any products and services from us, when providing any products and services to us, when entering into or performing any contract with us, when signing up to, attending or participating in our events, competitions or matches, or when entering our promotions.
We may monitor or record your telephone conversations with us for security purposes and to improve the quality of products and services on offer to you.
Please note that CCTV is in operation at our premises, matches and events for safety, security and crime prevention purposes.
Please also note that filming and photography takes places at certain of our matches, competitions and events. By attending any match, competition or event, you agree to your image being filmed, photographed or recorded at that match, competition or event and grant your permission, free of charge, for both Scottish Rugby and its licensees to use such images in pictures and/or films (including publication on the internet and in social media).
2. Why we collect your personal information
We may collect, hold and use personal information from or about you for the following purposes:
• to manage, develop, promote and administer matches, competitions, events and the sport of rugby union;
• to administer and complete any request that you make of us, for example to provide any product or service that you have requested from us (and to keep in contact with you for such purposes);
• to enable us to administer and provide any of our competitions, events or other offers/promotions that you have entered or are taking steps to enter with us (and to keep in contact with you for such purposes);
• to manage, understand and respect your preferences;
• to improve the products and services we offer;
• to obtain feedback on our website or on our events, competitions, products and services;
• for record keeping, research, monitoring and analysis purposes;
• to you keep you informed of any changes to our website;
• to help diagnose server problems and administer our website;
• for the purposes of the performance of any contract that you have entered into or are taking steps to enter into with us (and to keep in contact with you for such purposes);
• to set up and administer any of your online accounts with us;
• to keep you informed via mail, email, SMS or telephone about other offers, events, products and services offered by us, or our sponsors or partners, that may be of interest to you and to personalise and/or tailor any such communications (only if you have agreed to be contacted in this way and subject to your ability to withdraw this agreement at any time); and
• to comply with applicable laws or regulations, court orders, law enforcement and fraud prevention requirements.
We may ask you from time to time if we can collect, hold and use your personal information for other purposes. If we do so, we will provide you with any necessary information on how we will use your personal information for such additional purposes.
3. Who we share your personal information with and why
Unless you specifically agree or ask us to share your personal information with a third-party, your personal information will only be shared as follows:
• with other members of our group of companies;
• with our website hosting, server and IT systems providers;
• with any third-party whose services we require to use for the administration, management or completion of any request that you have made of us or any contract that you have entered into (or taken steps to enter into) with us. Depending on the relevant circumstances, these may include our online ticketing services provider, our catering & hospitality services provider, our retail services provider, our printing and fulfilment providers, our customer relationship management database/services provider, the rugby club, body or society of which you are a member, or any third-party operator of a match, competition or event at one of our sites;
• with any third-party whose services we require to use for credit control, debt collection or payment processing purposes;
• with any actual or potential purchaser of the whole or any part of our business or assets (or those of any members of our group of companies);
• with our sponsors or partners to keep you informed via mail, email, SMS or telephone about other offers, events, products and services offered by them that may be of interest to you (only if you have agreed for your personal information to be shared in this way and subject to your ability to withdraw that agreement at any time);
• with our professional and legal advisers for the purposes of taking such advice; or
• with any third party where necessary to comply with applicable laws or regulations, court orders, law enforcement, fraud prevention, to enforce the terms under which you contracted with us, or to protect our rights, property or the safety and security of users of our website or attendees at our matches, competitions and events.
If we share your personal information with third-parties, they will be “processors” and subject to written conditions to only process your personal information in accordance with our instructions and to protect it. We will only share your personal information with third-parties if we are required to do so for specific purposes and will take reasonable steps to ensure that recipients only process the disclosed personal information in accordance with those purposes.
4. How your personal information is protected and where it is kept
Your personal information will be held within the United Kingdom or in the European Economic Area on a secure server. We will use reasonable security measures to seek to prevent unauthorised access to your personal information.
If a password is required to access certain areas of our website, IT systems or applications, you are responsible for keeping your password secure and confidential. You must not leave your password unattended or disclose your password to any other person.
5.How long your personal information is kept
Your personal information will be held for no longer than is reasonably necessary for the purpose for which it was obtained. We will carry out periodic reviews of the personal information that we hold about you to ensure that this is the case.
We will also retain your personal information to maintain historical, statistical and statutory records in accordance with applicable laws, regulations or guidance.
6. Your rights
You have the right to request that any inaccurate or incomplete personal information that we hold about you is modified or corrected at any time.
In certain circumstances, you have the right to request that we delete the personal information we hold about you at any time (although this may adversely affect your ability to attend or participate in our matches, competitions or events, to obtain products and services from us, or to use our website).
In certain circumstances, you have the right to request that we restrict or stop the processing of your personal information for specific purposes at any time (although this may adversely affect your ability to attend or participate in our matches, competitions or events, to obtain products and services from us, or to use our website);
In certain circumstances, you have the right to request that we provide your personal information to you in a particular format for your own re-use.
You have the right to access (without charge) the personal information that we hold about you by making a “subject access request” of us at any time.
To exercise any of the above rights, please contact us using the details set out below. Any requests will be considered under applicable data protection legislation. If you remain dissatisfied, you have the right to raise a complaint with the Information Commissioner’s Office at ww.ico.org.uk.
Scottish Rugby Union Limited, BT Murrayfield, Edinburgh EH12 5PJ, email: email@example.com
May 2018 © Scottish Rugby Union Limited 2018
End of SRU policy.
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/SRU?” section.
Who will we share this data with, where and when?
In addition to sharing data with the RFU/SRU, we will share your data with: Pitch Hero Limited for maintaining the Club’s website and communication purposes via that site. They are a registered company based in Leeds, West Yorkshire and are also fully subject to GDPR regulations. Details of their policy is accessible via a link on the bottom of the Club’s website page.
Some limited information may be shared 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/SRU’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, the SRU as the provider of SCRUMS, and providers of website hosting, accounting records and social media.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request.
What rights do I 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; and to obtain 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 and for data held by the SRU for its own purposes on SCRUMS.
To exercise any of these rights, you can get in touch with us– or, as appropriate, the RFU/SRU or its data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to the Information Commissioner’s Office.
Much of the information listed above must be provided on a mandatory basis so that we can make the appropriate legal checks and register you as required by RFU/SRU Rules and Regulations. We will inform you which information is mandatory when it is collected. Some information is optional, particularly information such as your medical information. If this is not provided, we may not be able to provide you with appropriate assistance, services or support.
How do I get in touch with you or the RFU/SRU?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org or by writing to The Data Protection Officer, Berwick Rugby Football Club, 11 Derwentwater Terrace, Scremerston, Berwick upon Tweed, Northumberland, TD15 2QY.
If you have any concerns about how the RFU process your data, you can get in touch at email@example.com or by writing to The Data Protection Officer, Rugby Football Union, Twickenham Stadium, 200 Whitton Road, Twickenham TW2 7BA.
If you have any concerns about how the SRU process your data, you can get in touch at firstname.lastname@example.org or by writing to The Data Protection Officer, Scottish Rugby Union Limited, BT Murrayfield, Edinburgh, EH12 5PJ.
How long will you retain my data?
We process the majority of your data for as long as you are an active member and for 6 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data for 6 years unless you ask us to stop, when we will only process the data for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data in connection with performing a contract or for a competition, we keep the data for 6 years from your last interaction with us.
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.
The SRU will maintain records of individuals who have registered on SCRUMS, records of DBS checks and the resulting outcomes and other disciplinary matters for such period as is set out in the SRU’s privacy notice which is set out on www.scottishrugby.org . A copy of this policy on 9 September 2018 is copied above.
Records of your involvement in a particular match, on team sheets, on results pages or in match reports may be held indefinitely both by us and the RFU/SRU in order to maintain a record of the game.