Introduction
Old Brodleians RUFC appreciates the trust placed by Club members and non-members alike in appropriately collecting, using and protecting their personal data. Additionally, it is important for individuals to understand their rights, and how to exercise them.

Executive Summary

Old Brodleians RUFC uses personal data of Club members to manage and administer your personal membership and level of involvement with individual teams, and the overall club; furthermore, this personal data is required to maintain contact with you for such purposes.
Business functions of the Club require the use of personal data of members or the general public, such as hiring the club for an event.
There is a requirement to share some personal data with third parties, such as the RFU, who use collected data to regulate, develop and manage the game.
Individual consent can be withdrawn at any time, but records can be retained if there is a statutory obligation for purposes such as insurance, tax or accounting.
It is essential to have accessible sensitive personal data within a contact sport environment, specifically relating to pre-existing medical conditions, to ensure that we are aware of how to fully support you routinely or in the event of a serious incident.
Some roles require a specific Disclosure and Barring Service check using the RFU’s eDBS system in order to be appointed. The result of this background check will be input into your personal Game Management Service (GMS) record.

What does this policy cover?
This policy describes how Old Brodleians RUFC (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.

What information do we collect?
We collect and process personal data from you or your parent/guardian when you join and when we carry out annual renewals of your membership. This includes:

Full name.
Gender.
DOB.
RFU ID (as assigned in GMS).
Home address, email address and telephone number.
Passport and National Insurance details (prospective employees).
Type of membership and roles/ responsibilities held for particular teams, or any key role within the Club such as Chair, Safeguarding Lead, Membership Secretary etc.
Payment and/or bank account details, when disclosed for membership payment.
Marketing preferences, including any consents you have provided.
Any medical conditions or disabilities, in conjunction with your/ parental consent to ensure that we are aware of the appropriate level of support we need to provide.

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, we may receive contact information for members next of kin or appointed emergency contact.
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:

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:

Taking payments.
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 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 CCTV cameras to maintain the security of our premises, and may use this video to investigate incidents at the Club or wider premises.
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
We use data of some individuals to invite them to take part in market research.

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/guardian 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.

How does the RFU use any of my information?
The RFU provides GMS, but make it’s own use of your following personal data:

Name.
Gender.
DOB.
RFU ID (as assigned in GMS).
Home address, email address and phone number.
Type of membership and roles/ responsibilities held for particular teams, or any key role within the Club such as Chair, Safeguarding Lead, Membership Secretary etc.

The RFU uses this information as follows:

As required by the RFU to conduct it’s business and pursue legitimate interests, in particular:

Communicating with you or about you when 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.
Communicating with you to ask for your opinions 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 will we share this data with, where and when?
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 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 (http://www.englandrugby.com/about-the-rfu/privacy-policy/) as the provider of GMS and providers of the Clubs website such as Pitchero (http://www.pitchero.com/privacy-policy) .

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.

To exercise any of these rights, you can get in touch with us– or, as appropriate, the RFU or it’s 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. Disclosure of some important personal data 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?
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 webmaster@oldbrodleians.co.uk or by writing to Old Brodleians RUFC, Woodhead Park, Hipperholme, Halifax, West Yorkshire, HX3 8JT.

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 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 your membership finishes.

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; albeit, there will be a requirement to continue processing the data for a short period after this (to allow us to implement your requests). We retain 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 the 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.

Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

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.