The Hampshire Golf Club
General Data Protection Regulation
Privacy Policy
Introduction
The General Data Protection Regulations (GPDR) replaces the Data Protection Act 1998 on 25th May 2018. This Privacy Policy details how The Hampshire Golf Club will be honest, transparent and clear as to how, when and why we collect and process your information and how we will protect this information in order to comply with the requirements of the GPDR.
Definition
‘Us’, ‘We’ or ‘Our’ means The Hampshire Golf Club
Our Commitment
The Hampshire Golf Club promise to respect the confidentiality of any personal data you share with us, to keep it safe, and make every effort to protect your privacy.
Lawful Basis for Processing Information
We are required to inform you as to the legal basis for which we require to process your information and the type of information that we hold. There are 6 categories that provide the legal basis to hold and process information, of which only 2 are relevant to The Hampshire Golf Club: Contract and Consent.
Contract. When you join as a member we require certain personal information to administer your membership and provide you with the services, products and information as part of this contract. We will only capture and store the minimum amount of information that we need to administer your membership:
Name – Allocation of membership card, P4G account, registering and recording information for competitions and maintenance of handicap information.
Date of Birth – To determine initial and on-going eligibility for different categories of membership plus entry criteria for certain competitions.
Gender – To determine eligibility for competitions, as there are male and female only, mixed and open competitions; and to manage handicaps, as there are different handicap allowances for male and female golfers, and therefore, we need to know whether you are male or female.
Contact Details – this includes address, telephone number(s) and email address to enable us to communicate with you either by post, telephone or email.
Occupation – To determine initial and on-going eligibility for certain discounted membership schemes that from time-to-time we may offer, such as the current membership offer for Her Majesty’s Armed Forces and Emergency Services.
Consent. We are required to seek your permission for providing you with marketing information. Under GPDR you will need to specifically opt-in for receiving any marketing information. We would like to send you information about our own products and services, by email and/or SMS (SMS requires a mobile telephone number). If you agree to our contacting you with this marketing information, you will need to sign a separate consent form, where you can select what marketing information you receive and how to wish to receive this information. You can at any time change your preferences for receiving marketing information, by informing us of the change.
The Hampshire Golf Club marketing. The different types of internal marketing information we would like to send you are:
Social Events at the Hampshire Golf Club
Golf tuition promotions from the Professional at the Hampshire Golf Club
Product and service promotions at The Hampshire Golf Club
Third Party Marketing. We would also like to share your information with other selected golfing product suppliers, namely Foremost Golf, so that they may send you information about their products and services by email, if you agree to your information being shared in this way.
Data Processing
Club Systems Club V1. As an affiliated club within the English Golf Union we are required to comply with the R&A rules of golf and maintain handicaps in accordance with the CONGU Unified Handicapping System. To enable us to meet these requirements, we use Club Systems software Club V1, CONGU approved software, to manage competitions, scores and handicaps. The results of competitions and changes to handicaps are automatically fed into:
Club Systems How Did I Do (HDIDO) at Golf. The HDIDO website with the Club name, your name, handicap and competition results.
English Golf Union Central Database of Handicaps (CDH). On achieving a handicap you are registered with the English Golf Union and allocated a life-time ID, which is portable from club-to-club throughout your golfing career, so that handicap information can be transferred easily between affiliated clubs. When your handicap changes, Club V1 updates the EGU CDH.
BRS. We use BRS to manage tee time bookings. For members this facility is available online via The Hampshire Golf Club website using your membership number and the booking is confirmed via email.
The Hampshire Golf Club Website. We do not capture any personal information when you visit our website.
Data Retention Periods
We will only retain your personal information for the minimum period for which it is needed. For members this will be for the period of you membership. When you leave the Hampshire Golf Club we will delete all your personal information that you have provided to us during your period of membership.
Your Rights
The GDPR gives you certain rights and these are listed below, further clarification of your rights is available on the Information Commissioners website https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
- You have a right to be informed when your personal data is being collected, what is collected and how it will be used or shared, as detailed in this Privacy Policy.
- You have a right of access to your personal data: the right of access allows you to be aware of and verify the lawfulness of the processing of your personal data. You can obtain a copy of the information, which we hold on you. This information will be provided free of charge. The application should be made in writing, by letter or email, and addressed to The Hampshire Golf Club; contact details shown below, enclosing two proofs of identification.
- Applicants should be aware that where requests are manifestly unfounded or excessive, in particular because they are repetitive, The Hampshire Golf Club may:
- charge a reasonable fee taking into account the administrative costs of providing the information; or
- refuse to respond.
- You have a right to have inaccurate personal data rectified, blocked (restrict processing), erased (right to be forgotten), or destroyed.
- You have a right in certain circumstances to object to the processing of your personal data for such reasons as direct marketing.
- You have a right in certain circumstances to data portability.
In certain situations, these rights may not apply, for example if you are a valid member we will need to communicate with you about your membership and those services afforded to you as part of that membership.
We collect and process your personal data because you have provided it to us to enable us to deliver a service to you. We will only process your personal data as you would reasonably expect us to do.
Under 16’s data
While we need to collect data to administer membership for under 16s, any contact information will be for the Parent or lawful guardian of the under 16 only.
Sensitive information
We do not collect any personal information on members classified as ‘sensitive’ under GDPR.
How we keep your information safe and who has access to it
We ensure that there are appropriate physical and technical controls in place to protect your personal details.
We undertake regular reviews as to who has access to information that we hold to ensure that your personal information is only accessible by appropriate staff and Club officials.
Changes to this Privacy Policy
We may need to amend this privacy policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear by notifying you directly.
Complaints
If you are unhappy with how we have processed your personal information, please firstly contact the Data Protection Officer at The Hampshire Golf Club.
Mrs Lizette Flake
Data Protection Officer
The Hampshire Golf Club, Winchester Road, Goodworth Clatford, Andover, Hampshire,SP11 7TB
Tel: 01264 357555 | Email: golf@thehampshiregolfclub.co.uk
If you are still unhappy you may contact the Information Commissioner’s Office:
Information Commissioner’s Office
Wycliffe House
Water Lane, Wilmslow
Cheshire, SK9 5AF
On line: https://ico.org.uk/concerns
Helpline: 0303 123 1113 (local rate) or ++44 1625 545 745