Winchester City Flyers Club Privacy Notice

Winchester City Flyers (Club) ("we", "our", "us") take your privacy very seriously.
This Privacy Notice sets out how we use and look after the personal information we collect from you.
We are the data controller, responsible for the processing of any personal data you give us. We take
reasonable care to keep your information secure and to prevent any unauthorised access to or use of
it.

What personal data we hold on you
Personal data means any information about an individual from which that individual can be identified.
We collect, use, store and transfer some personal data of our participants [and their parents or
guardians], and other Club members.

You provide information about yourself when you register with the Club, and by filling in forms at an
event or online, or by corresponding with us by phone, e-mail or otherwise.

The information you give us may include your name, date of birth, address, e-mail address, phone
number, gender, and the contact details of a third party in the case of emergency. We may also ask
for relevant health information, which is classed as special category personal data, for the purposes of
your health, wellbeing, welfare and safeguarding. Where we hold this data it will be with the explicit
consent of the participant or, if applicable, the participant’s parent or guardian.
Where we need to collect personal data to fulfil Club responsibilities and you do not provide that data,
we may not be able honour or administer your membership.

Why we need your personal data
We will only use personal data for any purpose for which it has been specifically provided.
The reason we need participants’ and members’ personal data is to be able to run the football club
and arrange matches; to administer memberships, and provide the membership services you are
signing up to when you register with the club. Our lawful basis for processing your personal data is
that we have a contractual obligation to you as a participant or member to provide the services you
are registering for.

We have set out below, in a table format, a description of all the ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.

Who we share your personal data with
When you become a member of the Club, your information, if you are a coach or volunteer will be or if
you are another participant may be (depending upon which league(s) your team plays in) entered
onto the Whole Game System database, which is administered by the FA. We also pass your
information to the County FA and to leagues to register participants and the team for matches,
tournaments or other events, and for affiliation purposes.

We may share your personal data with selected third parties, suppliers and sub-contractors such as
referees, coaches or match organisers. Third-party service providers will only process your personal
data for specified purposes and in accordance with our instructions.
We may disclose your personal information to third parties to comply with a legal obligation; or to
protect the rights, property, or safety of our participants, members or affiliates, or others.
The Club’s data processing may require your personal data to be transferred outside of the UK.
Where the Club does transfer your personal data overseas it is with the sufficient appropriate
safeguards in place to ensure the security of that personal data.

Protection of your personal data
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

How long we hold your personal data
We keep personal data on our participants and members while they continue to be a participant or
member or are otherwise actively involved with the Club. We will delete this data within 3 months after
a participant or member has left or otherwise ended their membership or affiliation, or sooner if
specifically requested and we are able to do so. We may need to retain some personal data for longer
for legal or regulatory purposes. The personal data that is stored on Whole Game System is subject
to their privacy policy so we advise you review that policy together with this notice. If you would like
your personal data to be deleted from Whole Game System then please contact them.

Your rights regarding your personal data
As a data subject you may have the right at any time to request access to, rectification or erasure of
your personal data; to restrict or object to certain kinds of processing of your personal data, including
direct marketing; to the portability of your personal data and to complain to the UK’s data protection
supervisory authority, the Information Commissioner’s Office about the processing of your personal
data.

As a data subject you are not obliged to share your personal data with the Club. If you choose not to
share your personal data with us we may not be able to register or administer your membership.
We may update this Privacy Notice from time to time, and will inform you to any changes in how we
handle your personal data.

If you have any questions about this Privacy Notice then please contact Winchester City Flyers
through the contact us on our web page www.winchestercityflyers.co.uk

Winchester City Flyers Data Protection Policy
1. About this Policy
1.1 Winchester City Flyers FC ([Club), (“we”, “our”, “us”) handle personal data about current, former, and
on occasion prospective players [and their parents or guardians], volunteers, committee members,
coaches, managers, and any other individuals that we communicate with.
1.2 In your official capacity with the [Club], you may process personal data on our behalf and we will
process personal data about you. We recognise the need to treat all personal data in an appropriate
and lawful manner, in accordance with the EU General Data Protection Regulation 2016/679 (GDPR).
1.3 Correct and lawful treatment of this data will maintain confidence in the Club, and protect the rights of
players and any other individuals associated with the Club. This Policy sets out our data protection
responsibilities and highlights the obligations of the Club, which means the obligations of our committee,
volunteers, members, and any other contractor or legal or natural individual or organisation acting for or
on behalf of the Club.
1.4 You are obliged to comply with this policy when processing personal data on behalf of the Club, and this
policy will help you to understand how to handle personal data.
1.5 The Club will be responsible for ensuring compliance with this Policy. Any questions about this Policy or
data protection concerns should be referred to the committee.
1.6 We process volunteer, member, referee, coach, manager, contractor, committee, supplier and third
party personal data for administrative and Club management purposes. Our purpose for holding this
personal data is to be able to contact relevant individuals on Club business, and our legal basis for
processing your personal data in this way is the contractual relationship we have with you. We will keep
this data for 3 months after the end of your official relationship with the Club, unless required otherwise
by law and / or regulatory requirements. If you do not provide your personal data for this purpose, you
will not be able to carry out your role or the obligations of your contract with the Club.
1.7 All the key definitions under GDPR can be found here.

2. What we need from you
2.1 To assist with our compliance with GDPR we will need you to comply with the terms of this policy. We
have set out the key guidance in this section but please do read the full policy carefully.
2.2 Please help us to comply with the data protection principles (set out briefly in section 3 of this policy and
in further detail below):
2.2.1 please ensure that you only process data in accordance with our transparent processing as set
out in our Privacy notice;
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2.2.2 please only process personal data for the purposes for which we have collected it (i.e. if you
want to do something different with it then please speak to a committee first);
2.2.3 please do not ask for further information about players and / or members and / or staff and / or
volunteers without first checking with CWO;
2.2.4 if you are asked to correct an individual’s personal data, please make sure that you can identify
that individual and, where you have been able to identify them, make the relevant updates on
our records and systems;
2.2.5 please comply with our retention periods listed in our Privacy Notice and make sure that if you
still have information which falls outside of those dates, that you delete/destroy it securely;
2.2.6 please treat all personal data as confidential. If it is stored in electronic format then please
consider whether the documents themselves should be password protected or whether your
personal computer is password protected and whether you can limit the number of people who
have access to the information. Please also consider the security levels of any cloud storage
provider (and see below). If it is stored in hard copy format then please make sure it is locked
away safely and is not kept in a car overnight or disposed of in a public place;
2.2.7 if you are looking at using a new electronic system for the storage of information, please talk to
the committee first so that we can decide whether such a system is appropriately secure and
complies with GDPR;
2.2.8 if you are planning on sharing personal data with anybody new or with a party outside the FA
structure then please speak to the committee before doing so who will be able to check that the
correct contractual provisions are in place and that we have a lawful basis to share the
information;
2.2.9 if you receive a subject access request (or you think somebody is making a subject access
request for access to the information we hold on them) then please tell a member of the
committee as soon as possible because we have strict timelines in which to comply;
2.2.10 if you think there has been a data breach (for example you have lost personal data or a
personal device which contains personal data or you have been informed that a coach has
done so, or you have sent an email and open copied all contacts in) then please speak to a
member of the committee who will be able to help you to respond.
If you have any questions at any time then please just ask a member of the committee. We are here to
help.

3. Data protection principles
3.1 Anyone processing personal data must comply with the enforceable principles of data protection.
Personal data must be:
3.1.1 processed lawfully, fairly and in a transparent manner;
3.1.2 collected for only specified, explicit and legitimate purposes;
3.1.3 adequate, relevant and limited to what is necessary for the purpose(s) for which it is processed;
3.1.4 accurate and, where necessary, kept up to date;
3.1.5 kept in a form which permits identification of individuals for no longer than is necessary for the
purpose(s) for which it is processed;
3.1.6 processed in a manner that ensures its security by appropriate technical and organisational
measures to protect against unauthorised or unlawful processing and against accidental loss,
destruction or damage;
3.2 We are responsible for and must be able to demonstrate compliance with the data protection principles
listed above.

4. Fair and lawful processing
4.1 This Policy aims to ensure that our data processing is done fairly and without adversely affecting the
rights of the individual.
4.2 Lawful processing means data must be processed on one of the legal bases set out in the GDPR.
When special category personal data is being processed, additional conditions must be met.
5. Processing for limited purposes
5.1 The Club collects and processes personal data. This is data we receive directly from an individual and
data we may receive from other sources.
5.2 We will only process personal data for the purposes of the Club as instructed by the committee, the
County FA or The FA, or as specifically permitted by the GDPR. We will let individuals know what those
purposes are when we first collect the data or as soon as possible thereafter.
6. Consent
6.1 One of the lawful bases on which we may be processing data is the individual’s consent.
6.2 An individual consents to us processing their personal data if they clearly indicate specific and informed
agreement, either by a statement or positive action.
6.3 Individuals must be easily able to withdraw their consent at any time and withdrawal must be promptly
honoured. Consents should be refreshed every season.
6.4 Explicit consent is usually required for automated decision-making and for cross-border data transfers,
and for processing special category personal data. Where children are involved then the consent must
be in writing from parent/guardian
6.5 Where consent is our legal basis for processing, we will need to keep records of when and how this
consent was captured.
6.6 Our Privacy Notice sets out the lawful bases on which we process data of our players and members.

7. Notifying individuals
7.1 Where we collect personal data directly from individuals, we will inform them about:
7.1.1 the purpose(s) for which we intend to process that personal data;
7.1.2 the legal basis on which we are processing that personal data;
7.1.3 where that legal basis is a legitimate interest, what that legitimate interest is;
7.1.4 where that legal basis is statutory or contractual, any possible consequences of failing to
provide that personal data;
7.1.5 the types of third parties, if any, with which we will share that personal data, including any
international data transfers;
7.1.6 their rights as data subjects, and how they can limit our use of their personal data;
7.1.7 the period for which data will be stored and how that period is determined;
7.1.8 any automated decision-making processing of that data and whether the data may be used for
any further processing, and what that further processing is.
7.2 If we receive personal data about an individual from other sources, we will provide the above
information as soon as possible and let them know the source we received their personal data from;
7.3 We will also inform those whose personal data we process that we, the Club, are the data controller in
regard to that data, and which individual(s) in the Club are responsible for data protection.

8. Adequate, relevant and non-excessive processing
8.1 We will only collect personal data that is required for the specific purpose notified to the individual.
8.2 You may only process personal data if required to do so in your official capacity with the Club. You
cannot process personal data for any reason unrelated to your duties.
8.3 The Club must ensure that when personal data is no longer needed for specified purposes, it is deleted
or anonymised.
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9. Accurate data
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any
personal data at the point of collection and at the start of each season. We will take all reasonable steps to
destroy or amend inaccurate or out-of-date data.

10. Timely processing
We will not keep personal data longer than is necessary for the purpose(s) for which they were collected. We
will take all reasonable steps to destroy or delete data which is no longer required, as per our Privacy Notice.

11. Processing in line with data subjects’ rights
11.1 As data subjects, all individuals have the right to:
11.1.1 be informed of what personal data is being processed;
11.1.2 request access to any data held about them by a data controller;
11.1.3 object to processing of their data for direct-marketing purposes (including profiling);
11.1.4 ask to have inaccurate or incomplete data rectified;
11.1.5 be forgotten (deletion or removal of personal data);
11.1.6 restrict processing;
11.1.7 data portability; and
11.1.8 not be subject to a decision which is based on automated processing.
11.2 The Club is aware that not all individuals’ rights are absolute, and any requests regarding the above
should be immediately reported to the committee, and if applicable escalated to the County FA for
guidance.

12. Data security
12.1 We will take appropriate security measures against unlawful or unauthorised processing of personal
data, and against the accidental loss of, or damage to, personal data.
12.2 We have proportionate procedures and technology to maintain the security of all personal data.
12.3 Personal data will only be transferred to another party to process on our behalf (a data processor)
where we have a GDPR-compliant written contract in place with that data processor.
12.4 We will maintain data security by protecting the confidentiality, integrity and availability of the personal
data.
12.5 Our security procedures include:
12.5.1 Entry controls. Any stranger seen in entry-controlled areas should be reported.
12.5.2 Secure desks, cabinets and cupboards. Desks and cupboards should be locked if they hold
personal data.
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12.5.3 Methods of disposal. Paper documents should be shredded. Digital storage devices should be
physically destroyed.
12.5.4 Equipment. Screens and monitors must not show personal data to passers-by, and should be
locked when unattended. Excel spreadsheets will be password protected.
12.5.5 Personal Devices. Anyone accessing or processing the Club’s personal data on their own
device, must have and operate a password only access or similar lock function, and should
have appropriate anti-virus protection. These devices must have the Club’s personal data
removed prior to being replaced by a new device or prior to such individual ceasing to work with
or support the Club.

13. Disclosure and sharing of personal information
13.1 We share personal data with the County FA/ and The FA, and with applicable leagues using Whole
Game System.
13.2 We may share personal data with third parties or suppliers for the services they provide, and instruct
them to process our personal data on our behalf as data processors. Where we share data with third
parties, we will ensure we have a compliant written contract in place incorporating the minimum data
processer terms as set out in the GDPR, which may be in the form of a supplier’s terms of service.
13.3 We may share personal data we hold if we are under a duty to disclose or share an individual’s
personal data in order to comply with any legal obligation, or in order to enforce or apply any contract
with the individual or other agreements; or to protect our rights, property, or safety of our employees,
players, other individuals associated with the Club or others.

14. Transferring personal data to a country outside the EEA
We may transfer any personal data we hold to a country outside the European Economic Area (EEA), provided
that one of the appropriate safeguards applies.

15. Reporting a personal data breach
15.1 In the case of a breach of personal data, we may need to notify the applicable regulatory body and the
individual.
15.2 If you know or suspect that a personal data breach has occurred, inform a member of the committee
immediately, who may need to escalate to the County FA as appropriate. You should preserve all
evidence relating to a potential personal data breach.

16. Dealing with subject access requests
16.1 Individuals may make a formal request for information we hold about them. Anyone who receives such
a request should forward it to the board/committee immediately, and where necessary escalated to the
County FA for guidance. Nobody should feel bullied or pressured into disclosing personal information.
16.2 When receiving telephone enquiries, we will only disclose personal data if we have checked the caller's
identity to make sure they are entitled to it.

17. Accountability
17.1 The Club must implement appropriate technical and organisational measures to look after personal
data, and is responsible for, and must be able to demonstrate compliance with the data protection
principles.
17.2 The Club must have adequate resources and controls in place to ensure and to document GDPR
compliance, such as:
17.2.1 providing fair processing notice to individuals at all points of data capture;
17.2.2 training committee and volunteers on the GDPR, and this Data Protection Policy; and
17.2.3 reviewing the privacy measures implemented by the Club.

18. Changes to this policy
We reserve the right to change this policy at any time. Where appropriate, we will notify you by email

Winchester City Flyers Equality Policy
Winchester City Flyers Girls and Ladies Football Club:
• [list]

This policy is fully supported by the Club Officers who are responsible for the implementation of this policy.

Safe guarding Policy

Child Welfare Resources