BTM UNITED FC PRIVACY POLICY

1. GENERAL

BTM United FC, is a non-registered community sports organisation, with its office at: Residential Address Privacy Restricted - Available on Request by Emailing Nicola Johns and detailing your request for her address https://www.btmunited.co.uk/contact/contact-official-259294. ("we", "us" and "our") takes the privacy rights of users of the BTM United FC club, mobile applications and website ("Site") extremely seriously.

We are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data (“Data Protection Legislation”).

We are committed to respecting your privacy. This notice is to explain how we may use personal information that we collect before, during and after your membership, or registration with us. This notice also explains how we comply with the law on data protection, what your rights are, and for the purposes of data protection we will be the controller of any of your personal information.

This notice applies to you if you are either:
a. An individual who has registered for membership of the club.
b. An individual or company who sponsors, supports or supplies to the club.
c. An individual player | Participant | Coach | Volunteer | Parent or Guardian of a player for the club, and/or whose details that we have collected from you.
References to we, our or us in this privacy policy are to BTM United FC.

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws - as we are not required to do so. However, [Enter Name], [Main Role], has overall responsibility for data protection compliance in our community sports organisation.

Contact details are set out in the "Contact Us" section at the end of this privacy notice.

2. PERSONAL INFORMATION WHICH WE MAY COLLECT FROM YOU

When you sign up for membership with us, you may provide us with or we may obtain personally identifiable information about you, such as information regarding your:

Personal Contact Details that allows us to contact you directly, such as, Name, Address, Email addresses, and Emergency Telephone numbers;
Date of Birth
Gender
Membership details including start and end date
Bank details that you provide so that we can receive payments from you or make payments to you and details of the financial transactions with you;
Records of your attendance at any activity hosted by us
Images in video and/or photographic form and voice recordings; and
Any disciplinary and grievance information
In light of the COVID-19 Pandemic, and the club being required to collect certain information as stipulated by Football Association Wales (FAW), namely in the Training Session Register; the name of players, which is then linked to their club account and emergency contact details for the purposes of “supporting NHS Wales, Test, Trace and Protect Service (TTPS)”. We may also “be asked to provide this information to TTPS, and this information is exempt from GDPR” Please refer to the FAW’s ‘Safer Return to Training’ documents for confirmation of this position.

Players | Participants | Coach | Volunteers | Parents & Guardians of Players
If you are a player, participant, coach, volunteer, or parent and guardian of a player(s) who has registered his/her interest in participating for the club you may also provide us with, or we may obtain the following additional personal information from you;

Identification documents such as passport, driving licence, identity cards, or photographic proof of your identity for Football Association Wales related requirements, or DBS Certificate requirements;
Details of Next of Kin, family members and emergency contacts;

3. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following “Special Categories” of more sensitive personal information regarding you:

Information about your health, including any medical condition, health and sickness records, or dietary requirements; and

We may not collect all of the above types of special category personal information about you. In relation to the special category personal data that we do process, we do so on the legal basis that;

It is necessary for the establishment, exercise or defence of legal claims;
It is necessary for the purposes of carrying out the obligations and exercising our, or your rights in the field of community sports recreation and volunteering; or
based on your explicit consent.

In the table below, we refer to these as the “special category reasons for the processing of your personal data”.

We may also collect criminal records information from you. For criminal records history, we process it on the basis of legal obligations or based on your explicit consent.

4. WHY WE REQUIRE YOUR PERSONAL INFORMATION

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.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Processing Membership and Registration Forms
Organising Matches
Sending out Match or Club information and updates
Sharing data with Coaches, Managers or Officials to run Training Sessions or enter events
Sharing data with Leagues we are in Membership of, County Associations and other competition providers for entry in events
Sharing data with Club Officers, Management Committee Members to provide information about Club Activities, Membership / Registration Renewals, or invitation to Social events
Sharing data with third party service or facility providers
Publishing Match and League results
To ensure that we understand possible health risks, to keep a current Risk Assessment up to date.

5. WHERE WE COLLECT YOUR INFORMATION

We typically collect personal information about our members when you register for membership of our football club, via either in person registrations, or renewals, or via the clubs ‘Club Website’ and ‘Club App’, or ‘Manager App’ set of applications.

Regarding the clubs website and apps, these are purchased for use by us, that are provided to us by Pitch Hero Limited, a company registered in England with company number 06361033 whose registered office is at Sterling House, Capitol Park East, Tingley, Leeds, West Yorkshire, WF3 1DR. Therefore, their Privacy Policy is also of importance to you, as your personal information will be stored within their digital storage solutions, when registering and using the ‘Club Website’, and ‘Club App’, or ‘Manager App’. You can find their Privacy Policy, here: https://www.pitchero.com/privacy-policy

If you are a player/participant, we also may collect personal information about you from other referrals such as from managers or talent scouts.

If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and also how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

6. USES MADE OF YOUR INFORMATION

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to process and store this data.

Purpose of Collection	Personal Information Used	Lawful basis
A) For All Members:
To administer your membership that you have with us and managing our relationship with you.	All contact and membership details, transaction and payment information, records of your interactions with us, and marketing preferences.	This is necessary to enable us to properly manage and administer your membership contract with us.
To send you information which is included within your membership joining package, or renewal package.	All contact and membership details.	This is necessary to enable us to properly manage and administer your membership contract with us.
To send you other information that we think you might find useful, or which you have requested from us.	All contact, membership details and marketing preferences.	Where we believe that we have a legitimate interest to keep you up to date with information about the club.

To answer your queries or complaints.	Contact details and records of your interactions with us.	We have a legitimate interest to provide complaint handling services to you, in case there are any issues with your membership.
Retention of records	All the personal information we collect.	We have a legitimate interest in retaining records whilst they may be required in relation to queries or complaints. We need to retain records in order to properly administer and manage your membership, and in some cases, we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. For criminal records history we process it on the basis of legal obligations or based on your explicit consent.

Purpose of Collection	Personal Information Used	Lawful basis
B) Sponsors, Supporters, & Suppliers:
To administer your sponsorship, support, or supply that you have with us, and managing our relationship with you.	All contact and membership details, transaction and payment information, plus records of your interactions with us	This is necessary to enable us to properly manage and administer your contract or agreement with us.
To send you information which is included within your sponsorship, support, or supply benefits package.	All contact and membership details.	This is necessary to enable us to properly manage and administer your contract or agreement with us.
To send you other information which we think that you might find useful, or which you have requested from us.	All contact, membership details and marketing preferences.	Where we believe that we have a legitimate interest to keep you up to date with information about the club.
To answer your queries or complaints.	Contact details and records of your interactions with us.	We have a legitimate interest to provide complaint handling services to you, in case there are any issues with your contract or agreement.
Retention of records.	All the personal information we collect.	We have a legitimate interest in retaining records whilst they may be required in relation to queries or complaints. We need to retain records in order to properly administer and manage your sponsorship, support, or supply. We may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category For criminal records history we process it on the basis of legal obligations, or based reasons for processing of your personal data” referred to in section 2 above. For criminal records history we process it on the basis of legal obligations, or based on your explicit consent.

Purpose of Collection	Personal Information Used	Lawful basis
C) Players, Participants, Volunteers:
To administer your playing membership or volunteering that you have with us and managing our relationship with you.	All contact and membership details, transaction and payment information, plus records of your interactions with us	This is necessary to enable us to properly manage and administer your playing membership or employment and any contract with us.
To use information about your physical or mental health (including any injuries) or disability status, to ensure that your health and safety, and to assess your fitness to participate, to provide appropriate adjustments to our facilities and to monitor and manage sickness absence.	Health and medical information.	We have a legitimate interest in doing so, to provide a safe and accessible environment for you to train and compete. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. For criminal records history we process it on the basis of legal obligations or based on your explicit consent.
To gather evidence for possible grievance or disciplinary hearings.	All the personal information we collect including any disciplinary and grievance information.	We have a legitimate interest in doing so, to provide a safe and fair environment for all members, and to ensure the effective management of any disciplinary hearings, appeals and adjudications. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. For criminal records history we process it on the basis of legal obligations or based on your explicit consent.
To facilitate movement to/from the club from another club.	Contact details.	To allow players to move clubs freely within the rules of the competitions that we play in.
Retention of records.	All the personal information we collect.	We have a legitimate interest in retaining records whilst they may be required in relation to queries or complaints. We need to retain records in order to properly administer and manage your sponsorship, support, supply. We may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. For criminal records history we process it on the basis of legal obligations or based on your explicit consent.

For some of your personal information you will have a legal, contractual, other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to admit you as a member, or we may not be able to properly perform our contract with you, or comply with our legal obligations, and we may have to terminate your position as a member or playing member. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it, then we may not be able to properly perform our contract with you.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contact Us" section below.

However, please note, that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain member benefits to you.

7. DISCLOSURE OF YOUR PERSONAL INFORMATION

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 onto the COMET database, which is administered by the FAW.

We also pass your information to the South Wales Football Association (SWFA), and to leagues, namely Taff Ely & Rhymney Valley Alliance League (TERVA) 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.

We share personal information with the following parties:

Any party approved by you.
To any governing bodies or organisations to which the club affiliates: to allow them to properly administer the sport.
Other service providers;
Our supply chain partners & sub-contractors, such as couriers, import/export agents, shippers;
The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
Police, law enforcement, security services and other statutory agencies: to assist with the investigation and prevention of crime, the protection of national security and safeguarding.

We DO NOT disclose personal information to anyone else except as set out above.

8. MARKETING TO YOU

In addition to the uses described in sections 2 to 7 above, we may also use your data for our legitimate interests including for marketing, market research and related purposes, such as:

Providing you with information about our clubs products and services, or related products and services via email/post/telephone/text which may be of interest to you;
Asking you to participate in market research, for example surveys about topical issues, our services and products. We will always try to tell you before you participate in a survey, how any information you provide in the survey will be used.
Where we have your consent, we may use your data to market the services and products of sports focused brands, and ask you to participate in related market research via email/post/telephone/text which may be of interest to you.
We will always inform you before collecting your data if we intend to use your data for marketing, market research and related purposes. Where we intend to use Your Data for the marketing of services and products of third-party organisations, and/or disclose Your Data to any third party for such purposes we will obtain your prior consent.

Your right to opt-out - You have a right to opt-out of receiving any marketing information (from ourselves and/or a third party) at any time. To opt-out of receiving such information you can:

Amend your preferences accordingly in your Pitchero on-line account; or
Use the facility contained in any marketing communication which you receive; or
Email us at https://www.btmunited.co.uk/contact/contact-official-259293.
Where you have subscribed to receive marketing correspondence from us, we will keep personal data for the period set out in section 6 of this policy.

9. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

The duration for which we retain your personal information will differ, depending on the type of information and the reason of why we collected it from you.

However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement, we retain all physical and electronic records for a period of [1 year] after your last contact with us. Exceptions to this rule are:

Information that may be relevant to personal injury claims, or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period, as the limitation period might not start to run until a long time after you have volunteered for us.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address.

10. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

The right to be informed about how your personal information is being used;
The right to access the personal information we hold about you;
The right to request the correction of inaccurate personal information we hold about you;
The right to request the erasure of your personal information in certain limited circumstances;
The right to restrict processing of your personal information where certain requirements are met;
The right to object to the processing of your personal information;
The right to request that we transfer elements of your data either to you or another organisation; and
The right to object to certain automated decision-making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them, and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of your personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contact Us" section below.

If you are unhappy with the way we are using your personal information, you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first and foremost.

11. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

12. CONTACTING US

In the event of any query or complaint in connection with the information that we hold about you, please email https://www.btmunited.co.uk/contact/contact-official-259293 specifically detailing your enquiry, and we shall be in touch promptly, at our first opportunity.

Version dated 17th August 2020.

Club Constitution

Club Officers & Management Committee 2020-21