Data Privacy Notice
Introduction
This privacy notice describes how Croquet England processes the personal information ("the Data") it holds about you, or that you are about to share with it. Croquet England is committed to keeping your information safe and to meet its obligations under the General Data Protection Regulation ("GDPR") to process it fairly. This notice also outlines your rights if you feel it is not doing so.
Identity and Contact Details
The Controller of the Data is Croquet England, a charity registered in the UK (1202444). It operates directly through its Board of Trustees, Executive, Officers, Staff, those serving on its committees and in other roles (e.g. Tournament Managers, Handicappers, Coaches); and indirectly through its Affiliated Clubs, Federations and Coaching Academies when they are acting on its behalf. It can be contacted through its office: Croquet England, Old Bath Road, Cheltenham GL53 7DF, email: office@croquetengland.org.uk. Please identify any correspondence related to this policy with the subject "Data Protection: FAO Croquet England Operations Manager".
Croquet England is not required to appoint a Data Protection Officer as defined by GDPR: its Operations Manager and Secretary are jointly responsible for ensuring that data protection issues are dealt with by the organisation.
Purpose and Lawful Basis for Processing
Croquet England processes (or will process) Data about you in order to administer your subscription, sales to you from its online shop, or more generally support its activities, for example, the tournaments, coaching, development and related programmes that it runs.
The lawful basis for holding subscription and sales records is to fulfil the contract with you as a Subscriber or customer (or potential Subscriber or customer) of Croquet England. More generally, the lawful basis for the processing described above is that it is in the legitimate interests of Croquet England in pursuit of its aims as stated in its Constitution. This includes being able to comply and assess compliance with our Policies, Regulations and the Law.
Croquet England also processes personal data relating to current or potential contracts with staff, landlords, suppliers or service providers, under the lawful basis of fulfilling or entering into those contracts.
Categories of Personal Data
Croquet England may hold and process the following categories of structured Personal Data about its current or potential subscribers, customers, contacts and those engaging in activities run under its auspices:
- Name.
- Contact Details (e.g. postal, email and social media addresses and telephone numbers).
- Financial information relating to subscriptions, sales and other transactions such as tournament entry. No credit card or bank account details are held by Croquet England.
- Handicaps, rankings, eligibility criteria (including nationality, residency and date of birth), qualifications and awards.
- Club membership
- Demographic Data such as year of birth, gender and ethnicity in order to effectively manage and monitor compliance to our EDI (Equality, Diversity and Inclusion) and Welfare policies
- Committee membership or other service to Croquet England, including Conflict of Interest.
- Tournament entries, management and results, including selection for and participation in teams or squads
- Disabilities, such as colour vision deficiency, where to do so would facilitate your participation in the sport.
- Photographs and video.
It may also hold Data relating to contracts with staff and third parties, as noted above.
In addition, unstructured Personal Data relating to you may be held in e-mails sent to or from you, or between those acting on behalf of Croquet England, and in logs of requests you make to its website.
Information Sharing
Croquet England will not pass your Data to anyone without your consent, except where necessary to provide its services, as detailed below:
- It may share your contact details and information about goods you have ordered with suppliers of them to enable it and them to fulfil your order.
- It may share financial Data relating to you with its payment processor, banks and BACS processor, for the purpose of collecting payments or making refunds.
- It may share your Data with clubs to which you belong, for the purpose of maintaining accurate subscription records.
- It may share your postal address with the fulfilment house for delivery of the Croquet Gazette, Royal Mail and other couriers who deliver items to you on behalf of Croquet England.
- It publishes your name and Croquet England related attributes (such as handicaps, coaching and refereeing qualifications, roles and club membership(s)) in an online Directory that is accessible only to Croquet England Subscribers. With your consent and to facilitate contact between Subscribers we also publish your contact and additional information about you in the Directory, accessible to your fellow club members or to all Croquet England Subscribers as you allow.
- It may publish contact details for representatives of its affiliated clubs and federations, tournament and coaching officials, and those serving on Croquet England Committees.
- It may publish contact details and other information about those who wish to or have entered tournaments or coaching activities, on its website, available to those who can log in to it, and supply them and financial details relating to payment for entries to those running the events and officers of the clubs hosting them. This may include organisations based overseas if you participate in international tournaments or matches.
- It may publish news, including photographs, videos, tournament results and commentary on its website, sites publishing croquet results, or social media sites.
- It may provide results of ranking games to Ranking Officers working on behalf of Croquet England or World Croquet Federation.
- It may provide financial and contact information about staff and others paid by Croquet England to HMRC and pension providers.
- Its website may share information about your use of it with search engine providers, for the purpose of optimising it (and, whilst not the responsibility of Croquet England, software on devices you use to access it may harvest data relating to your use of it).
- It will give information about you when legally required to do so.
Location of Data Processing
The data is processed on computers (and backups of them) operated by Croquet England, on those operated by its service providers (e.g. for its website, email, online shop, payments, banking and distribution), and on paper records.
These are all normally located in the UK, European Union or countries which have equivalent data protection safeguards.
Retention Periods
Except where required for archiving purposes (e.g. results of tournaments and club competitions and records Croquet England activity, such as meeting minutes and membership lists), Personal Data about you will be deleted no later than six years after you were last a Subscriber of or had financial dealings with Croquet England.
Your Rights
You have the right to object to how Croquet England processes your Personal Data. In particular, you can request that your contact details are not shown in published membership lists. You also have the right to access, correct, and, in some cases, delete and restrict the use to which your Data is put, but your participation in events or fulfilment of your subscription rights may be restricted if you do so. In addition, you have the right to complain to Croquet England (see the first section for contact details) and to the Information Commissioner at http://ico.org.uk/global/contact-us.
Please contact Croquet England (using the contact details above) in the first instance if you have any queries or concerns.
Data Sources
The primary source for the Data held about you is the information:
- You previously provided to The Croquet Association that was transferred to Croquet England when it took over as the National Governing Body of croquet in England.
- You provided, or are about to provide, when joining Croquet England or subsequently updating it, either directly or through a club of which you are a member.
Those acting on behalf of Croquet England in running its activities are a secondary source of data for your results, handicaps, qualifications, etc.
Consequences of Failing to Provide Data
If you do not provide the Data required by Croquet England to become a subscriber or enter a tournament or coaching activity then you will be unable to do so. Croquet England requires at least a postal address to ensure that it can contact its Subscribers and those playing in tournaments run under its Regulations.
Automated Decision-Making
Software may be used to produce draws and orders of play for tournaments and to assist team and squad selection, but otherwise, no automated decision-making software is used by Croquet England.
Amendments
We may update this Data Privacy Notice from time to time by publishing a new version on our website: significant changes will be notified in a news item.
Change Log
- New version for Croquet England
Version 1.0, 30th December 2023