Data Protection Policy

Our data protection policy sets out our commitment to protecting personal data and how we implement that commitment with regards to the collection and use of personal data.

We are committed to:

• Ensuring that we comply with the eight data protection principles, as listed below;
• Meeting our legal obligations as laid down by the Data Protection Act 1998;
• Ensuring that data is collected and used fairly and lawfully;
• Processing personal data only in order to meet our operational needs or fulfill legal requirements;
• Taking steps to ensure that personal data is up to date and accurate;
• Establishing appropriate retention periods for personal data;
• Ensuring that data subjects' rights can be appropriately exercised;
• Providing adequate security measures to protect personal data;
• Ensuring that a nominated officer is responsible for data protection compliance and provides a point of contact for all data protection issues;
• Ensuring that all club officers are made aware of good practice in data protection;
• Providing adequate training for all staff responsible for personal data;
• Ensuring that everyone handling personal data knows where to find further guidance;
• Ensuring that queries about data protection, internal and external to the organisation, are dealt with effectively and promptly.
• Regularly reviewing data protection procedures and guidelines within the club

Data protection principles

1. Personal data shall be processed fairly and lawfully;
2. Personal data shall be obtained for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes;
3. Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;
4. Personal data shall be accurate and, where necessary, kept up to date;
5. Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes;
6. Personal data shall be processed in accordance with the rights of data subjects under the Data Protection Act 1998;
7. Appropriate technical and organisational measures shall be taken against unauthorised and unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data;
8. Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Privacy Policy

For the purposes of the General Data Protection Regulation ("GDPR") and UK data protection laws, the controller is Cocks and Hens Cambridge Tennis (the “Club”) of Grantchester Road, Cambridge, CB3 9ED.  

About this document

This Privacy Policy sets out the way we process your personal data and we have created this policy to make sure you are aware of how we use your data as a member of the Club. It should be read in conjunction with the Club’s Data Protection Policy.

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

The types of information we collect

We may collect the following types of personal data about you:

• Contact and communications information, including your contact details (including email address(es), telephone numbers and postal address(es) and records of communications and interactions we have had with you);
• Financial information;
• Certain other information which you volunteer when making use of your membership benefits (e.g., when making court bookings or making use of other Club facilities);
• We may also collect data about your date of birth, health or medical conditions, where you have volunteered this (e.g. so that we can cater for you when you attend a Club social event or a course/camp).

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 informing you about court / facilities opening hours and taking payment of membership fees;
• Fulfilment of orders for goods and services, including court bookings;
• 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 in our Club;
• Communication about our Club activities that we think may be of interest to you;
• Storing your details on the Clubspark 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;
• for security purposes, including by operating security cameras in various locations at our premises;
• Where this is necessary for our legitimate interests (e.g. 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 (e.g., 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 for our legitimate interests (or the legitimate interests of a third party), and/or where we have your consent, as applicable.

Your marketing preferences

We will always 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 our Venue. 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 venue closures and holiday opening hours.

You are in control of how we communicate with you. You can update your choices and/or your contact details by contacting us at  cocksandhensmembers@gmail.com.

Sharing your information with others

We do not sell or share your personal data for other organisations to use other than as set out below.

Personal data collected and processed by us may be shared with the following third parties, where necessary:

• Our employees and volunteers, for the purposes of administering your membership and giving you access to the membership benefits to which you are entitled.
• Our contractors and suppliers, including coaches, any provider of membership management services and the Lawn Tennis Association and Cambridgeshire LTA.
• Local tennis clubs in order to provide contact details for matches. 

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 and for a period of six years after your last interaction with us (for accounting, tax reporting and record-keeping purposes). For members over the age of 65 we will retain the information for ten years in order to be able to check for eligibility for Senior membership.

Your rights

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

• Request access to your personal data. 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 should contact  cocksandhensmembers@gmail.com in the first instance.

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.

Approved 2 May 2018