Privacy & Data Policy – May 2018

INTRODUCTION

This privacy notice provides you with details of how Berkhamsted Golf Club collect and process personal, employee, customer and member data through its business and your use of its website, www.berkhamstedgolfclub.co.uk 

Including any information, you may provide when you purchase a product or service, sign up to our email communications or take part in a prize draw or competition.

Berkhamsted Golf Club is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of company:    Berkhamsted Golf Club 

Email address:        howard@berkhamstedgc.co.uk

Postal address:        Berkhamsted Golf Club, The Common, Berkhamsted, HP4 2QB

Telephone number:        01442 865832

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at howard@berkhamstedgc.co.uk

1. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process certain types of personal data about you as follows:

Identity Data may include your first name, last name, username, title, date of birth and gender.

Contact Data may include your billing address, work address, email address and telephone numbers.

Transaction Data may include details about payments between us and other details of purchases made by you.

Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.

Profile Data may include your preferences, feedback and survey responses.

Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences. This data may be used to contact you under “Legitimate Interests”, this is described in section 4 of the Berkhamsted Golf Club Privacy & Data Policy. 

The data that is collected applies to all types of contact that has been made with the Club or information that has been collected. Those details are primarily, but not necessarily limited, to the following-

• Full name.

• Address

• Telephone contact details

• Email address.

• Date of birth.

• Joining date (Berkhamsted Golf Club members & employees)

• Leaving date (Berkhamsted Golf Club members & employees)

Berkhamsted Golf Club are committed to complying with the Data Protection Act Principles which are:

• Personal data shall be processed fairly.

• Personal data shall only be obtained for specified lawful purposes and shall not be further

processed in any manner incompatible with that purpose or those purposes.

• Personal Data must be adequate, relevant and not excessive.

• Data is accurate and kept up to date.

• Data is not kept longer than is necessary and contact details will be removed after 6 years

from the date the person resigned membership or left their employment from Walmley Golf

Club.

• Data shall be processed in accordance with the individual’s rights.

• Data will be secure.

• Data will not be shared or transmitted abroad.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out how applicable the Berkhamsted Golf Club services are to you as an individual. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods, such as a Membership bag tag or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

2. HOW WE COLLECT YOUR PERSONAL DATA

We collect data through many sources, these mostly being in connection to Golf Club membership or the services that Berkhamsted Golf Club offer.

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms at Berkhamsted Golf Club or on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

order our products or services;

to start up a business relationship and business development enquiry

subscribe to our service or publications;

request resources or marketing be sent to you;

enter a competition, prize draw, promotion or survey; or

give us feedback.

Automated technologies or interactions: As you use our website, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see the appendix 1 “Cookie Policy” at the end of this document. 

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

analytics providers such as Google based outside the EU;

search information providers [such as [Linked In, Google] based [inside OR outside] the EU].

Various golfing industry bodies and regulators.

Identity and Contact Data from data brokers or aggregators [such as Electrical marketing based [inside OR outside] the EU].

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

3. HOW WE USE YOUR PERSONAL DATA

Berkhamsted Golf Club will only use your personal data when legally permitted.

So that we can provide a Golf Club and course suited to the best interests of its visitors, members and other course users, the Club has to collect information. That information may include details of members, reguests, visitors, current, past and prospective employees and suppliers.

The Club is committed to the correct treatment of personal data. We fully appreciate the underlying principles of the Data Protection Act (May 2018) and support and adhere to its provisions. The Act uses the term “Personal Data” which essentially means any recorded information held by us and from which a living individual can be identified.

The most common uses of your personal data are:

Where we need to perform the contract between us.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at howard@berkhamstedgc.co.uk

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at howard@berkhamstedgc.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing communications

Regarding the Marketing Communications, this is where we deem a product, service or a newsworthy item to be of interest to you. This will vary from individual to individual but may include the following services, function & events promotions, open events, open days, lessons, casual dining, membership enquires, green fee & golf day promotions. 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at howard@berkhamstedgc.co.uk at any time

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Member Communications

In relation to Member communications we are obligated to contact members for the following-

• AGM or EGM notification

• Annual subscription notices.

• Administration of competitions//handicaps.

• Any legal notices/information required by law.

• Health & Safety notices/information appertaining to member’s wellbeing.

• Rule changes that affect a member’s future membership.

• Requirement to attend disciplinary proceedings.

Employee Communications.

Should you be an employee of Berkhamsted Golf Club, we are obligated to contact employees for the following-

• Changes to Tax, NI or Pension rights.

• Issuing P45 or/and P60 documents.

• Requirement to attend disciplinary proceedings.

• Health & Safety notices/information appertaining to an employee’s wellbeing.

• Notice of changes to contracts or/and Job description.

• Information that affects their working practices or times of work.

For non-essential information i.e. sales & marketing material, members or/and employees have the right to forego receiving all of that information and Berkhamsted Golf Club will endeavour to comply fully with that wish.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at howard@berkhamstedgc.co.uk.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

4. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above:

Service providers who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Please see appendix 2 “Storage of Data” for a list of where and why a third party may be holding your data. 

5. DATA SECURITY

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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

It regards to the specific storage of data, please refer to appendix 2 “Storage of Data”.

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at howard@berkhamstedgc.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

It regards to the specific storage of data, please refer to appendix 2 “Storage of Data”.

9. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Berkhamsted Golf Club has a specific Cookie policy. Please refer to appendix 1 “Cookie Policy”

10. CONTACT DETAILS 

Please get in touch if you have any questions about any aspect of this privacy policy and in particular if you wish to object to any processing of your personal information that we carry out for our legitimate interests. We would prefer that you contact us by email.

Our full details are:

Full name of company:    Berkhamsted Golf Club 

Email address:        howard@berkhamstedgc.co.uk

Postal address:        Berkhamsted Golf Club, The Common, Berkhamsted, HP4 2QB

Telephone number:        01865 582365

Berkhamsted Golf Club is an unincorporated association trading from Berkhamsted Golf Club, The Common, Berkhamsted, HP4 2QB. 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. 

appendix 1 “Cookie Policy”

COOKIE PRIVACY

This Website is provided by Intelligent Golf on behalf of Berkhamsted Golf Club. Berkhamsted Golf Club uses this website to provide online information and services, competition management and CONGU ratified handicap maintenance, for Playing members of its Golf Clubs. 

Access to this website is via Berkhamsted Golf Club's Membership ID and a User managed PIN number and is limited to Golf Club Members and selected staff who need access for the purpose of supplying and maintaining information relative to the primary functions of the website, as stated above. 

Berkhamsted Golf Club will transfer from its own membership system only those personal details relevant to Golf Club membership such that a Golf Club Member may utilise this website effectively. 

Users of the website are able to specify additional personal details by accessing the 'Preferences' area under the 'My Details' menu option. The details specified here will be used solely for the following purposes:-

1) Communication between members to facilitate the management of matches and competitions

2) Communication between Golf Club Members and Golf Club Committee Members and Officers to promote accessibility and enable the effective and smooth running of the club.

3) Contact information may be passed to Berkhamsted Golf Club to enable them to maintain up to date contact information.

Cookies are used throughout this website for tracking session data, and this data is discarded after you leave the website automatically. Persistent cookies may also be used to remember your club selection preference.

appendix 2 “Storage of Data”

Type of Data Held

Length of Time Held

How Data is Held

Members

Name and contact information.

Emergency contact details.

Information and documents relating to the membership we are providing, including. communications with you.

Billing and payment information and bank details.

Member’s handicap

Under 18’s medical conditions requiring treatment.

We will retain information about you for the duration of your membership relationship with us, then for an additional 6 years.  

We retain financial records for 6 years, following the end of the current financial year.

Handicap details are retained indefinitely

Data is stored in Intelligent Golf which is hosted in secure servers within the EEA https://www.intelligentgolf.co.uk/privacy

Data is stored in Mail Chimp which is hosted in the United States 

https://mailchimp.com/legal/privacy/

Prospective Members

Name and contact information

Information and documents relating to the services we are providing, including communications with you.

We will retain information about you for the duration of the enquiry, then a further three years.

Data is also stored with Text Anywhere which is hosted within the EEA 

http://www.textanywhere.net/privacy-policy.aspx

Job Applicants

Name and contact information

CV and application form.

We will retain information about you for the duration of the recruitment campaign, then one year.

The holding of information with the Indeed website is controlled by them and would be subject to their own privacy policy.

Data is stored in manual records in locked filing cabinets and computer held records are password controlled. 

Data is also stored within the Indeed database.  For more information go to: https://www.indeed.co.uk/legal#privacy

Current and Former Employees

Name, date of birth, and contact information

National insurance number and Unique Tax Reference (UTR)

Information relating to your qualifications and experience

Information relating to performance reviews.

Copies of passports or EU ID

We will retain information about you for the duration of our contractual relationship with you, then for an additional 6 years.  

Data is stored on secure EEA-based servers. 

Data is also stored using Sage Payroll.   https://www.sage.co.uk/uk/hrpayrollhero/privacy-policy.

Data is stored using NEST pension.
https://www.nestpensions.org.uk/schemeweb/nest/nestcorporation/privacy-policy.html

Suppliers

Contact details

Bank details

Description of the services bought

We retain financial records for 6 years, following the end of the current financial year.

Data is stored on secure UK-based servers.  https://www.sage.co.uk/uk/hrpayrollhero/privacy-policy.

Open Competition Entrants

Contact Details

Dates of previous visits

We retain open competition details indefinitely

Data is stored in Intelligent Golf which is hosted in secure servers within the EEA 

https://www.intelligentgolf.co.uk/privacy

Green Fee Visitors

Contact Details

Payment details

We retain information about you for 3 years after your last visit.

We retain financial records for 6 years, following the end of the current financial year.

Data is stored on secure UK-based servers and also in Intelligent Golf which is hosted in secure servers within the EEA

https://www.intelligentgolf.co.uk/privacy

Golf Day or Event Bookings

Contact Details

Dates of previous bookings

Description of the products and services purchase/used

We will retain information about you for the duration of the enquiry and/or booking, then a further three years.

Data is stored on secure UK-based servers and also in Intelligent Golf which is hosted in secure servers within the EEA

https://www.intelligentgolf.co.uk/privacy

Social Media 

Variable 

The Club has social media platforms the data is held by those sources. Please refer to the individual social media platforms for their data policy

The Club has social media platforms the data is held by those sources. Please refer to the individual social media platforms for their data policy