Warwickshire County Hockey Association

PRIVACY NOTICE

Updated 11th August 2020 to reflect England Hockey Covid19 Stage 4 RTP Guidelines


Brief Description of Warwickshire County Hockey Association (WCHA)

WCHA is an affiliated County Hockey Organisation. WCHA is the governing body for all hockey within Warwickshire subject to the powers of Midland Region Hockey Association Ltd (MRHA) in the Midlands and is subject to overriding powers of England Hockey Ltd, the controlling body for field hockey in England. The Committee of WCHA have delegated powers and obligations to Warwickshire Women’s Hockey League (WWHL) and Warwickshire Player Pathway to manage Hockey administration in Warwickshire collectively the “WCHA Committees”.


Introduction Privacy Notice

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your involvement with us. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.

This notice applies to you if you are either:

An individual who is a member of WCHA Committees and officials of WCHA Committees.

An individual who is a member of a Warwickshire Club and School who is a Club/School contact for the WCHA Council and WCHA Committees.

An individual who is a member of a Warwickshire Club who participates in Leagues organised by the WWHL Committee.

An individual who participates in Warwickshire Schools and Youth competitions.

An individual who is selected to participate in the Warwickshire Senior County activities.

An individual who is subject to the England Hockey disciplinary regulations the application of which has been delegated to WCHA.

References to services provided in this privacy notice the activities undertaken by WCHA Committees as defined by the constitution of WCHA to individuals in Warwickshire, Warwickshire Clubs and Warwickshire Schools.

References to we, our or us in this privacy notice are to the WCHA.


We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Compliance Officer has overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.

WCHA Player Pathway Committee

The WCHA Player Pathway Committee uploads player details for Midlands players from the England Hockey website and processes this data to carry out its activities this is subject to the England Hockey Data Protection rules and covered by the England Hockey Privacy Notice.


Personal Information we may collect from you

You may provide us with or we may obtain personal information about you, such as information regarding your:

personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers;

date of birth;

gender;

records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;

records of your attendance at any events and competitions delivered by us;

images in video and/or photographic form and voice recordings;

any payment or bank details you provide so that we can receive payments from you or you can receive payments from us and details of the financial transactions with you;


SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:

information about your health, including any medical condition, health and sickness records, medical records and health professional information; and

We may not collect all of the above types of special category personal information about you. In relation to special category personal data that we do process we do so on the basis that:

the processing is necessary for reasons of substantial public interest, on a lawful basis;

it is necessary for the establishment, exercise or defence of legal claims;

it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or

based on your explicit consent.

In the table below, we refer to these as the “special category reasons for processing of your personal data”.


WHERE WE COLLECT YOUR INFORMATION

We collect information as follows:-

1. an individual who is a member of WCHA Committees and officials of WCHA Committees will provide the their contact information to the Secretary of WCHA;

2. an individual who is a Warwickshire Club or School contact will provide their contact information to the relevant WCHA Committee;

3. members of Club and Schools teams competing in leagues and competitions organised by WCHA Committees will have their names entered on team sheets;

4. members of Club and Schools subject to disciplinary action under the England Hockey Disciplinary Regulations;

5. typically collect personal information when you make an application for funding, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.

6. Attendance records for events organised by Warwickshire Player Pathway will be shared with England Hockey and the NHS Track and Trace programme as required in line with the Stage 4 Return to Play guidance (August 2020).

Uses made of the information

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

PurposePersonal information usedLawful basis
For the purposes of administering Hockey in the Warwickshire as delegated by MRHA to Members of WCHA CommitteesContact details of the members of the WCHA Committees and officials of WCHA Committees, The contact details of Club and School contacts. The names of individuals, their club or school, the offence and penalty imposed who are have been disciplined under the England Hockey Discipline Regulations by the WCHA.We have a legitimate interest to hold and process this data for administering Hockey in Warwickshire.


For the purposes of administering Men’s Warwickshire Representational teamsContact details of WCHA Senior squad management team members, Warwickshire Club contacts, individuals organising the Representational teams and contact details of players who wish to be considered to be selected for the representational teams. Information on the team members on team sheets will be destroyed at the end of the competition for which they were completed.We have a legitimate interest in administering the Men’s Warwickshire Representational teams
For the purposes of administering Warwickshire Schools and Youth CompetitionsContact details of WCHA Committee involved in Schools and Youth competitions and individuals at Schools and Clubs who organise the teams to participate in Warwickshire Schools and Youth. Any information on the team members such as team sheets will be destroyed at the end of the competition which they were completed for.We have a legitimate interest in administering the Warwickshire Schools and Youth competitions
For the purposes of administering the Warwickshire Women’s League Contact details of the Warwickshire Women’s Hockey League Committee members and officials and club contacts. Any information on the team members such as team sheets will be destroyed at the end of the season or whenever is reasonable and practicable to do so. Bank account details of the Warwickshire Clubs.We have a legitimate interest in administering the Warwickshire Women’s League
For the purposes of administering the Warwickshire Player PathwayThe personal details of WCHA Player Pathway players which include contact details, gender, date of birth, bank details, record of activities undertaken, record of communications withWe have a legitimate interest in administering the WCHA Player Pathway in the Midlands.

WCHA Player Pathway Committee, contact details of guardians, bank details of guardians, playing records and disciplinary records of the WCHA Player Pathway Committee members, officials, coaches appointed by the WCHA Player Pathway Committee, players and players guardians.
For the purposes of administering the WCHA Player Pathway CommiteeSpecial Category Data of the individuals participating in the WCHA player pathway activities.The individuals participating in the WCHA Player Pathway activities or their guardians have given us your explicit consent to do so.
To deal with your queries or complaintsContact details and records of your interactions with us.
We have a legitimate interest to provide complaint handling services to you in case there are any issues with the service we provide.
Retention of recordsAll the personal information we collect.We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage any account you have with us and in some cases we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To comply with health and safety requirementsRecords of attendance and health and medical informationWe have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate in sport. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To use information about your physical or mental health (including any injuries) or disability status to ensure your health and safety and to assess your fitness to participate in any of the activities or events we hostHealth informationWe process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
For the purposes of equalName, title, date of birth,We have a legitimate interest to promote a

opportunities monitoringgender, information about your race or ethnicity, and health information.sports environment that is inclusive, fair and accessible. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To comply with legal obligations, for example, regarding people working with children or vulnerable adultsInformation about your criminal convictions and offences
For criminal records history we process it on the basis of legal obligations or based on your explicit consent.


Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.


Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain benefits to you.


DIRECT MARKETING

WCHA will not undertake email, post and SMS marketing.


Disclosure of your PERSONAL information

We share personal information with the following parties:

Any party approved by you;

To any governing bodies or regional bodies for the sports covered by us: to allow them to properly administer the sports on a local, regional and national level.

Other service providers and advisors: for example, email marketing specialists, payment processors, professional advisors, data analysis and IT services (including CRM, website, video- and teleconference services);

The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.

Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above.


TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect is not transferred to and stored in countries outside of the UK.


HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 6 years after your last contact with us. Exceptions to this rule are:

Information that may be relevant to personal injury claims, discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after the event.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address by contacting us by using the details set out in the “Contacting us” section below.


YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

the right to be informed about how your personal information is being used;

the right to access the personal information we hold about you;

the right to request the correction of inaccurate personal information we hold about you;

the right to request the erasure of your personal information in certain limited circumstances;

the right to restrict processing of your personal information where certain requirements are met;

the right to object to the processing of your personal information;

the right to request that we transfer elements of your data either to you or another service provider; and

the right to object to certain automated decision-making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making,

may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.


CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date in this paragraph. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

First version dated 06/04/2018.

Latest version dated 11/08/2020 – added use of data relating to EH Stage 4 RTP guidelines.


CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email [email protected] or write to us at Stephen Tabb – Data Compliance Officer – 30 Dorchester Avenue, Hampton Magna, Warwick CV35 8TB


Document dated 11th August 2020.