Updated 28th March 2021
WHO ARE WE?
Blackheath Football Club Limited (BFCL) is a limited company known as 'Blackheath Rugby', is registered in England and Wales whose registered office is Blackheath FC, Well Hall, Kidbrooke Lane, Eltham, London SE9 6TE.
We operate as Data Controller for the information you provide to us as members of the Club, and for members who are also players or coaches or medical support staff. The Club’s Data Officer is Huw Gronow, Honorary Secretary, Blackheath FC.
- Summary of how we and the RFU use your data
- What does this policy cover?
- What information do we collect?
- What information do we receive from third parties?
- How do we use this information, and what is the legal basis for this use?
- How does the RFU use any of my information?
- Withdrawing consent or otherwise objecting to direct marketing
- Who will we share this data with, where and when?
- What rights do I have?
- How do I get in touch with you or the RFU?
- How long will you retain my data?
- Further Information
1. Summary of how we and the RFU use your data
- Blackheath Football Club 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 purposes and to keep you up-to-date with club news and events.
- Some data is shared with the Rugby Football Union (RFU), who uses your data to regulate, develop and manage the game.
- Data is also shared with third parties to provide necessary training.
- Where we or the RFU 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 in the case of a junior player, 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 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 record in the RFU’s Game Management Service (GMS).
- Data, by way of footage, is collected via Blackheath Football Club’s CCTV.
2. What does this policy cover?
This policy describes how Blackheath Football Club (henceforth 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”). The policy also describes the RFU’s use of data on GMS.
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.
3. What information do we collect?
We collect and process personal data from you or your parent/legal guardian 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 passport and National Insurance 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.
4. 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. 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.
5. 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:
- communicating with you;
- 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:
- we will use your information to manage and administer your membership and your involvement with its teams and the 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 use data of some individuals to invite them to take part in market research;
- 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
- we record the 1st XV matches with high-definition video and will use this record to analyse the match and promote the team through social and other media.
Where you give us consent:
- we will send you direct marketing or promotional material by email;
- we may handle medical or disability information you or your parent provides to us, to ensure we support you appropriately;
- 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:
- we maintain records such as health and safety records and accounting records in order to meet 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 government or law enforcement authorities conducting an investigation.
6. 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:
- 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;
- 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
- communicating 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.
7. 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 optout 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.
8. Who will we share this data with, where and when?
In addition to sharing data with the RFU, we will share your data with:
(a) In the case of Directors’ and/or Officers’ data:
- Companies House for the registration of the Club and its Directors
- HMRC to facilitate tax returns and payments
- Community Amateur Sports Club (Gov.UK) to secure tax relief and other benefits for the Club
- Our Building Security Company for alarm maintenance & activation support
- Banks to provide the Club with depositing and payment facilities of its money
- Insurance companies to mitigate against loss
(b) In the case of the Bar Manager:
The local Alcohol Licencing Authority for the licence to serve alcohol within agreed parameters
(c) In the case of Volunteers:
- Training providers to help improve the quality of the Club’s services
- Disclosure and Barring Service (DBS) checking company to help safeguard children by checking for criminal records
(d) In the case of Players:
- Schools to assist parents in sharing necessary injury information that might impact school life
- Doctors and Hospitals in case of major injury to provide information during the diagnostic process.
- Tour providers to allow them to facilitate activities, accommodation, food, travel and special requirements highlighted by the touring person or their parent/guardian. Optional third-party communication applications are sometimes used to supplement
communications via e-mail. These third parties will have their own Privacy Terms and Conditions and will require a direct agreement between the user and the provider. This agreement is outside the control of the Club. All information required for membership will be available via e-mail. Optional third-party applications used are:
- Team Facebook© pages, which are available and are closed groups (see the Club’s Social Media Policy). A request to join the group will be accepted as the data owner’s consent to participate.
- WhatsApp©, which some age groups’ Managers use to co-ordinate team selection and training. This will require data owners’ consent prior to adding to the group as members will see each other’s data.
Some limited information may be shared with other stakeholders in rugby, such as other clubs, Constituent Bodies, referee societies and 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, and our website developer Waterhouse Design and Advertising Limited and our host company PriorityOne, who are both UK based and subject to GDPR. Waterhouse Design and Advertising Limited only process the provided information for publishing on the Club’s website.
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.
9. 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.
To exercise any of these rights, you can get in touch with us, or, as appropriate, the RFU 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 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.
10. How do I get in touch with you or the RFU?
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 using the email address firstname.lastname@example.org or by
writing to The Data Officer, Blackheath Football Club, Kidbrooke Lane, Eltham, London SE9 6TE.
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.
11. 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 one year after this.
Where we process personal data for marketing purposes or with your consent, we process the data until 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.
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 in order to maintain a record of the game.
12. Further Information
This policy and any subsequent appendices to this policy will be available as separate
documents on the Club’s website to make viewing easier.
FURTHER INFORMATION ON PRIVACY NOTICES CAN BE FOUND HERE: