Page 1of 616 September 2020England Golf –World Handicap System (WHS)Privacy NoticeThis privacy notice explains how England Golf collects and processes personal dataof its members. The organisation is committed to being transparent about how it collects and uses that data and in order to meet its data protection obligations. Where this notice refersto “we”, “our” or “us” this is a reference to the English Golf Union Limited(company no. 5564018)with registered office at The National Golf Centre, The Broadway, Woodhall Spa, Lincolnshire, LN10 6PU, trading as England Golf.For the purpose of data protection laws, we are the controller of the personal dataprocessed for the purposesset out below and we are responsible for looking after it.What information does England Golfcollect?If you are a member of England Golf, we collect the following information about you:•your name, date of birth, email address,phone number, membership number, membership type (18 or 9 hole), home club, gender and age;•information about the courses you play, dates you play, your scoresand information relating to your handicap;•information about competitions you play and your results from such competitions; •your England Golfmemberlogin details;and•we may also automatically collect information and personal data about your computer for system administration including, where available, your IP address, operating system and browser type. Wedo this to help us analyse how membersuse the member login area(including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account and improving your online experience.Please see our website privacy policyfor further information about what information may be collected when you visit ourwebsite.
Page 2of 616 September 2020How we collect personal data?We collect some of your information directly from you, either through information that you give to us or information that we collect through your communications with us. We also obtain some information from your golf club.Information that you give usYou may share personal data about yourself and your circumstances by: •registering to use our member’s login area via www.englandgolf.org, and continuing to use the member’s login area;•completing a form in relation to a competitionorganised by uswhether in person or online; and•making enquires or interacting with us directly whether in person, by telephone, or email.You are not obliged to provide your personal data to us. However, if you do not provide your personal data to us, we willnot be able to provide all services to you, respond to your queries, or allow you onto access the member’s login area.For example, if you do not provide us with your email address and date of birth we will not be able to provide you with a handicap.Information that we collect about youWe collect personal data about youwhen you:•submit scores; and•participate in competitions that we organise; and•visit our website. Please see our website privacy policyfor further information about what information may be collected when you visit our website.Information that we receive from other sources We receivepersonal data about you fromgolf clubswhich areaffiliated to us, from relevant county golf organisations, or via software providers acting on behalf of those clubsor counties.Why do we need yourpersonal data?The main purpose for which we use your information is to provide you withyour membership services.We use your information: •to provide you withyour membership services;
Page 3of 616 September 2020•to calculate your handicap;•to run golf competitions;•to provide you with information that you request from usor which may be of interest to you;•to notify you about changes to our services;•to provide member support;•for research about our members’ behaviour and our services generally, andto report to bodies such as Sport England;and•to develop and improve our services, website and platforms.Basis for using your personal dataLegitimate business interestsWe have a legitimate interest in processing personal data. As a member of a golf club affiliated to England Golf you are also a member of England Golfas the national governing body for the sport. We use your personal data as set out in this privacy policy for the legitimate interests of our business to enable us to: •provide you with and improveour membership services;•administrateand maintain the integrity of the handicapping system;•maintain appropriate membership records;•maintain records ofdisciplinary, anti-doping or safeguarding cases; and•operate a safe and lawful business.Where we rely on legitimate interests as the legal basis for processing your personal data, we have considered whether or not those interests are overridden by yourinterests, fundamental rights and freedoms. We won’t use your information if we believe your interests should override ours, unless we have other lawful grounds to do so (such as if we have a legal obligation to process your personal data). If you have any concerns about ourprocessing please refer to details of “Your rights” section below.As we outline in “Your rights” section below, you will have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objectionto this sort of processing willaffect our ability to carry out the tasks that we have set out above.Performance of a contractProcessing may also be necessary for the performance of ourcontract with you. In order for us to fulfil our obligations under such contract (e.g. to provide you with the benefits of being a member of England Golf), we will need to collect, process and share (as further detailed below) your personal data.
Page 4of 616 September 2020Compliance with a legal obligationProcessing of your personal data may be necessary for compliance with our legal obligations. Who do we share your personal data with?We may share your personal datawith:•your home club and the relevant county golf organisation, or contractors or suppliers acting on behalf of those organisations; •competition organisers and officials involved in competitions in which you take part, including contractors or suppliers acting on behalf of those organisations;•other organisations involved in the calculation of your handicap, for example where you play at a club other than your home clubwe mayprovide them with your current handicap;•carefully selected third parties which supply us with products and services, such as website and platform developersand cloud computing services. We will only share your information with these suppliers where it is necessary for them to provide us with the services we need; •our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us);•organisations with whom we have a legal obligation to share your data, which may includeregulators, fraud prevention agencies,police,thecourts or law enforcement agencies; and•HMRC or other tax bodies or agencies to complywith our legal and regulatory obligations.Where is your personal data stored?Your personal data will be stored and processed in the UK and / orthe European Economic Area. Your data may be transferred to our platform developerwhichis based in New Zealand, a country that the European Commission has deemed to provide an adequate level of data protection.How long will we keep your data?We will retain your data for as long as it is necessary to fulfil the purposes set out in”Why do we need your personal data?” inthis privacy notice. This means that we will keep your personal datafor the duration of your membershipwith us. We also keep your personal datafor a period of time following your membership ceasing. Once the data is nolonger required for the purposes set out above, the period of retention will be calculated in accordance with our Data Protection
Page 5of 616 September 2020Policy. When determining the relevant retention periods, we consider guidelines issued by relevant data protection authorities, as well as the time periods needed to comply with applicable regulations or laws, to meet regulatory and financial reporting obligations, for tax, accounting and audit purposes, and to fulfiland protect our contractual obligations and rights.SecurityWe place great importance on keeping your personal datasafe and secure. As such, we put in place appropriate technical and organisational measures / industry standard technology to protect it from unauthorised access and unlawful processing, accidental loss, destruction and damage.The security measures we use are designed to provide a level of protection security appropriate to the risk of processing your personal data.You are responsible for protecting your online membership account login details and must not share them with, or disclose them to anyone. Where you have chosen a password which allows you to login to the member’s login area, you are responsible for keeping this password confidential. We advise you not to share your password with anyone and to use a unique password. Your rights You have the right to •obtain access to, and copies of, the personal data that we hold about you;•require us to correct the personal data we hold about you if it is incorrect; •require us to erase your personal data in certain circumstances; •require us to restrict our data processing activities in certain circumstances; •receive from us the personaldata we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;•object to our processing of personal dataheld by us about you; and•withdraw your consent, in circumstances where we rely on it to use your personal data.We want to make sure that your personal datais accurate and up to date. You have the right to ask for inaccuracies in your data to be corrected, and in certain circumstances for us to stop processing your data or for your data to be erased. Some of these rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.
Page 6of 616 September 2020If you wish to access or amend your data please contact us atcompliance {at} englandgolf(.)orgIf you are not satisfied with how we are processing your personal data, you can complain to the Information Commissioner’s Office (ICO). You can also find out more about your rights under the GDPR (and other data protection legislation) from the Information Commissioner’s Office website available at: www.ico.org.uk.Contact usIf you have any queries about this privacy notice or how we process your personal data you may contact our data protection officer:•Compliance {at} englandgolf(.)org; •Data Protection Officer, England Golf, The National Golf Centre, The Broadway, Woodhall Spa, Lincolnshire, LN10 6PUChanges to our privacy noticeAny changes to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this policy.