View Data Protection Policy as pdf

Church Broughton Tennis Club (“the Club” or “the Tennis Club”) collects a limited amount of personal data about members and people who have regular contact with the Tennis Club, such as parents of junior members or people attending club functions.

When submitting personal information to us, individuals give consent for the Tennis Club to use the information provided in the manner described in this document. If we amend this Data Protection Policy, it will be published on the Club’s web site

Church Broughton Tennis Club is a not-for-profit organisation. Officers, team captains and other members of the Club only process personal data in order to manage tennis services to members, such as coaching, court booking, match organisation and organisation or advertisement of these and other Club functions. As a result, the Club is not required to register as a Data Controller with the Information Commissioner’s Office. However, the Club is committed to protecting the rights and privacy of individuals and will aim to adhere to the principles of the Data Protection Act and the EU General Data Protection Regulations (“GDPR”) at all times.

This means that the Tennis Club will:

• Only obtain, store and use (“process”) information that is required to establish or maintain membership or support; 
• Only process information necessary to provide or administer activities for people who are members of the Club or have regular contact with it;
• Use personal data in an adequate and relevant manner, which is not excessive or outside the scope of the requirements of managing Club activities.
• Aim to keep all personal information held up-to date and accurate and make it accessible to the individual upon request
• Ensure that everyone within the Club that has access to or handles personal data does so in line with individual’s data protection rights and is fully aware of and abides by their duties under the Data Protection Act or GDPR.
• Take appropriate technical measures against unauthorised or unlawful processing of personal data to prevent accidental loss, destruction of, or damage to, personal data.
• Only share the information with people and organisations necessary to carry out the Club’s activities.
• Only keep the information while the individual is a member or engaged with the Club, or as long as necessary for member/supporter administration.

How we collect your information

We may collect your personal data in a few limited ways, namely:

• Directly from you, when you fill in an application for membership, attend coaching, make enquiries on our website, provide information via our club management software or court booking system, or when you interact with us during your time as a member in various other ways (for example, where you attend an event or competition, renew your membership, sign up for a course or lessons);
• From someone else who has applied for membership on your behalf (for example a family member or tennis coach who has provided us with your contact details for that purpose);
• From the LTA (for example, where the LTA passes on your details to us in connection with the Wimbledon Ballot or a complaint or query you have raised about our Club).

Types of Information Held

Whilst you are in contact with the Club, we may collect the following types of personal information, which for the purposes of this Policy, are split into four categories:

• Contact, Communication and Identification information – such as name, date of birth, gender, address, telephone numbers, email address, British Tennis Number and emergency contact details.
• Financial information, including Direct Debit details for you to pay us, or for us to refund you for any overpayments or expenses incurred on our behalf.
• Sensitive personal information that you volunteer – such as medical conditions, dietary or access needs or religious practices that the Club might need to know in order to provide safe and appropriate tennis services
• Consents – relating to specific authorisations that you give for us to carry out certain functions, such as process your data according to this policy, take photographs or authorise medical procedures in the event of an emergency.

How we use Personal data

Personal data provided to us will be used for the purposes set out at the time of collection and, where relevant, in accordance with any preferences you express.

More generally, we will use your personal data for the following purposes:

• Administration of your Club membership, including:

1. informing you about court / facilities opening hours and Club events;
2. taking payment of membership fees;
3. contacting you about renewals

• Fulfilment of orders for goods and services, such as management of coaching provision or organising external matches;
• Administration of the Wimbledon ballot;

      where this is necessary for the performance of a contract (including any written terms and conditions relating to your membership) with you;

• Research and statistical analysis about who is playing tennis at our Club;
• Communication about our Club activities that we think may be of interest to you;
• Storing your details on the software platform we use for our Club member management database / court booking system. Please note that your own use of the software or system is subject to the Terms and Conditions and Privacy Policy published on that site;
• Making your details accessible to you or making parts of the Club website easier to use, so you do not have to enter your personal information every time you use our services;

      where this is necessary for our legitimate interests (for example in increasing use of our Club’s facilities and participation in the game generally);

• Promoting our Club and promoting goods and services of third parties (for example, equipment suppliers, operators of coaching courses, and organisers of tennis events) where we think this will be of interest to you;

      where this is necessary and reasonable for our legitimate interests (or the legitimate interests of a third party), and/or where we have your consent, as applicable.

Storage of Data

Sensitive personal information will be stored in an appropriately secure manner so that it can only be accessed by the Club Welfare Officer, coaches that might need to refer to this information in order to coach safely and any other Club personnel as deemed necessary by the Club Welfare Officer.

Some Contact and Identification information (such as home address for juniors) will also be treated as being sensitive for Safeguarding purposes and treated in the same way as sensitive information as far as possible.

Financial Information will only be kept in secure online software packages designed specifically for the purpose, such as Online Banking or Online Payment Processing applications.

Most Contact and Identification information will be held on a secure Club Management software server or Club database, accessible only by a few key Officers in the Club.

The Club may use external suppliers to provide online data storage and management software services but will always ensure that these external suppliers are registered with the ICO and adhere to the Data Protection Act or GDPR, with their own clear Terms and Conditions / Privacy Policy.

These systems will also be used to keep a record of any consents that you have provided, with the ability to opt in or out of these consents by contacting the Club or updating via the online software.

The Club will endeavour to ensure that all information held is accurate and will update data when we are made aware of changes.

Sharing your information with others

We will not sell or share your personal data with other organisations to use, other than as set out below.

It is important to note that Contact information such as name, telephone numbers and email address will be required by many third parties for a variety of purposes, in order to manage Club services and tennis provision or contact you about Club events, matches, tournaments, etc.

Thus, when you choose to provide us with Identification information, you agree that personal data collected and processed by us may be shared with the following third parties:

• Members, team captains and volunteers, for the purposes of administering your membership and giving you access to the tennis services offered by the Club, such as contacting you regarding matches
• Our coaches
• Any provider of membership management services used by the Club (eg Clubspark/Sportlabs)
• the Lawn Tennis Association

The Club will ensure that each party is provided with no more information than is necessary to fulfil their function.

If you believe that any of the above third parties has mis-used your information or is not using it for the agreed purpose, please contact the Club as outlined at the end of this policy. We will investigate and, if necessary, take appropriate action to prevent further data sharing with that party.

Your marketing preferences

We will respect your wishes in respect of what type of communications you want to receive from us and how you want to receive them. There are some communications, however, that we need to send you regardless of your marketing preferences in order for us to fulfil our contractual obligations to you as a member of, or participant at, our Club. Examples of these essential service communications are:

• Records of transactions, such as payment receipts or Direct Debit confirmations (as applicable).
• Membership related mailings such as your membership renewal reminder, notices of formal meetings and information about Club activities, schedules or closures.
• Contacting you to confirm that any data we hold is correct or accurate

You are in control of how we communicate with you. You can update your choices and/or your contact details by logging in to our online Club Management software or contacting as outlined at the end of this policy.

How long your information is kept

We keep your personal data only for as long as necessary for each purpose we use it. For most membership data, this means we retain it for so long as you have a valid Club membership, because we will need your data in order to fulfil the services required by membership.

We may also retain your information for a period of up to two years after your last interaction with us, in case you wish to return to the club after a temporary pause and so that we can continue to inform you about tennis activities at the Club which may be of interest to you. If, during this period, you no longer wish us to contact you or continue holding your information, then you may inform us using one of the methods below and we will erase your data.

Your rights

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.  You can also withdraw your consent, where this is the basis for our processing your data (without affecting the lawfulness of our previous processing based on consent).
• Request the transfer of your personal data to another party.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

Contact and complaints

If you have any queries about this privacy policy or how we process your personal data, or if you wish to exercise any of your legal rights, you may contact the Club:

by email:         chair.cbltc@gmail.com or treasurer.cbltc@gmail.com

by telephone: see website for contact details of current officers

or by post:       Church Broughton Lawn Tennis Club, c/o Broughton Heath Golf Club, Bent Lane, Church  Broughton, Derby, Derbyshire, DE65 5BA

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner. You can find out more about your rights under applicable data protection laws from the Information Commissioner’s Office website: www.ico.org.uk

Published 11 May 2018