Policies

Canterbury City ("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 6 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 Club Secretary, Martyn Sexton.

Data Protection Policy

1. About this Policy
1.1 This Policy is to help clubs, County Football Associations and football leagues deal with data protection matters internally. This should be kept with other club / County Football Association / football league policies and a copy should be given (or made available) to all staff members, volunteers and others who come into contact with personal data during the course of their involvement with the club / County Football Association / football league.
1.2 Canterbury City Football Club, (“we”, “our”, “us”) handle personal data about current, former, and on occasion prospective players [and their parents or guardians], employees, volunteers, committee members, other Clubs, County FA, League members, referees, coaches, managers, contractors, third parties, suppliers, and any other individuals that we communicate with.
1.3 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).
1.4 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 employees, committee, volunteers, members, and any other contractor or legal or natural individual or organisation acting for or on behalf of the Club.
1.5 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.
1.6 The Club committee/board will be responsible for ensuring compliance with this Policy. Any questions about this Policy or data protection concerns should be referred to the committee.
1.7 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 [ 6 ] 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.
1.8 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;
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 Martyn Sexton 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 Martyn Sexton.
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 Martyn Sexton 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 Martyn Sexton 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 Martyn Sexton 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 [insert name] who will be able to help you to respond.
If you have any questions at any time then please just ask Martyn Sexton. 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.
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.
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 / County FA / League] 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/ 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.

Frequently Asked Questions

What do I have to tell people when I collect their information?
Under GDPR there is now a fair amount of information that needs to be provided at the point of data capture in the spirit of transparency, which is detailed in our Privacy Notices Factsheet.
You have to ensure you are explaining clearly and fully exactly what is going to happen with their personal data, and why you process it. This means what you will do with their data, where will it be stored, when you will delete it.
You also have to tell them what rights they have in regards to their own personal data, which are:

• the right to access the data you hold on them;
• the right to correct any incorrect details;
• the right to have their personal data deleted (subject to exemptions);
• the right to have that data shared with another party in an electronic format (‘data portability’);
• the right to withdraw their consent to processing, where the legal basis for that processing is consent;
• and the right to complain to the ICO.

• For any individuals and players registering with a club and the FA, then the legal basis for processing this data will be necessary for the performance of a contract, for the administration of their registration, and membership to the FA. If they are signing up to play, then to enable the arrangement of games, it is likely you will need their contact details to fulfil your part of the agreement, as the organisers.
• For any emails about events or match updates you need to send, you will have the legitimate interest of keeping the members and players informed, which you will need to explain in your Privacy Notice.
• For any staff personal data, your legal basis is necessary for the performance of a contract, for administering their pay, other employment obligations. For volunteers, the legal basis for processing their contact information is also for performance of a contract.
• Any marketing emails you should have an active consent from each data subject you send marketing to. This includes passing details to third party marketers – you can only do this if you have active consent from each individual. (And if this consent is withdrawn, marketing must cease.)
• For any health records you need to hold, which are a special category of personal data under GDPR, you will need to explain why you hold this on file, whether for safeguarding or health and safety purposes, for example, and you will need to get the individual’s explicit consent to do so. This consent will need to be recorded, possibly at the top of any health information form, amongst the fair processing information.

If you have any types of data for any other purposes, then you will need to assess why you have this
data. If you don’t have a valid reason for processing it, then you should think about deleting it. Full
guidance on lawful bases is on the ICO website.

How long should I keep information for?
The official guidance is that data should be stored for as long as necessary for the processing. This
means that once a player leaves the club or otherwise ends his membership with the FA, then
personal data collected for the purposes of notifying them of matches or team news should be
deleted.
You should have a clear, and it can be very simple, retention policy that staff or volunteers who deal
with personal data are aware of. The guidance does not specify exactly how long this should be, but it
should be reasonable and proportionate.
There are exceptions to this to be aware of.
If any investigations are pending, then you may have a legitimate interest to store it for longer until
this is complete.
Staff payment data is generally kept for seven years for tax reasons.
Some bits of data may need to be kept for longer. For example, written contracts may need to be
stored for a certain amount of years after the contract ends, so while you may have one copy of a
player’s contract filed in a secure location, there is no reason to keep this contact information
elsewhere, i.e. on a database.
Insurers may also impose certain document retention periods, so you should check any existing or
potential policies for this when determining you retention procedures.

What about the information I put on Whole Game System – what do I need to tell individuals
about that?
As part of your fair processing or privacy notice at the point you collect the data, you should tell the
individuals you will be entering their data into Whole Game System, and that this means you will be
sharing it with the County FA and league. You should tell them why you’re doing this. If this is not
strictly necessary for their registration then they can object to you doing this. You should also point
them to the privacy policy for Whole Game System. You should advise players that their data will still
remain on Whole Game System and it is their responsibility to contact the County FA for further
information or deletion. Clubs cannot delete this data on behalf of the individual.

What sort of security do we need to have?
The security processes need to be appropriate to your organisation. That means if you have paper
records, they should be kept in a locked cabinet in a secure building, and only authorised staff or
volunteers should have access. If you do keep personal data on a computer, the computer needs to
be password protected, and ideally the data files themselves. This can be something as simple as
having a password on an Excel spreadsheet. Again, only authorised (and appropriate) staff or
volunteers should know what this password is. If you are processing data via a cloud hosting memory
service, or on the internet, then you need to have good quality and routinely updated anti-virus and
security software.
Authorised staff and volunteers with access to personal data should also be aware of their duty to
keep this information confidential, and you should train these staff and volunteers to be aware that
wherever they are collecting or processing personal data they must be taking care to keep it secure
and confidential.

How do I find out if any of the information we have is stored overseas?
This may only be relevant when thinking about the email, internet and website providers you use. You
should look into the terms and conditions you have with the likes of Microsoft, Google or Apple to find
out where they are storing or sending your data.

We use Microsoft outlook for our emails – can we still do that?
Yes. Microsoft outlook as your email provider are processors of some of your organisation’s personal
data, and you may also share player personal data via this platform. The GDPR does state that data
controllers (the clubs) must have written contracts with their processors. When you purchase a
Microsoft product, their standard terms and conditions form part of this written contract (even though
you may never have actually read them!) and they will have updated these terms and conditions to
ensure their data processing clause is GDPR compliant.
If you are using another organisation or individual’s Microsoft subscription then you should fix this so
that the club has their own purchase agreement with Microsoft.

Can I still post match information on the website?
You should be careful what information you post on a publically accessible platform. Information that
does not include personal data is fine, but players’ and referees’ names, strip numbers or contact
information shouldn’t be being posted publically without the players’ or referees’ consent. You could
consider posting this information behind a secure, login only members’ area, but you would still need
to carefully consider what data you were sharing there and why. You can only post publically anything
about children with the written consent of parent/guardian.

What do we do if there is a personal data breach?
Personal data breaches do happen, and it doesn’t automatically mean you’ll be in trouble with the
ICO. You do have to tell the ICO within 72 hours of someone in the club first becoming aware of the
breach, if the breach concerns a large amount of data, or is likely to cause harm or distress to the
data subjects affected. If in doubt, get legal advice or call the ICO directly.
All staff and volunteers should be trained on what a data breach in your club might look like (for
example a cyber attack, or a list of names and addresses being left in a public place) and know when
and who to report it to.

Can I share members’ contact information with volunteers?
Anyone who is processing personal data should be committed to an obligation of confidentiality and
should be given a copy of your data protection policy. This means you can share data with volunteers,
so long as they are aware of their responsibility to keep any data they access confidential; they use it
only for the purpose they’re given it; and, they follow procedures to keep it secure, and delete it when
they cease to be a volunteer with you.