ENGLAND SQUASH PRIVACY POLICY

Last update: April 2020

This policy sets out how England Squash Limited (registered number 02411107 whose registered office is at National Squash Centre, Rowsley Street, Manchester M11 3FF) (“England Squash”, “we”, “us” or “our”) collects and uses any personal data we collect or receive about you, why we collect and use your personal data, who we might share this information with and your rights in relation to your personal data.

We are committed to protecting and respecting your privacy complying with our obligations under the general data protection regulation (“GDPR”) and all other laws relevant to the handling of your personal data. We are the data controller for the purposes of GDPR (meaning that we are responsible for deciding how your personal data is used).

When we refer to “personal data”, we are referring to any information which can directly or indirectly identify you, as explained more fully below.

WHAT PERSONAL DATA WE COLLECT ABOUT YOU (OR RECEIVE FROM THIRD PARTIES)

• Information that you provide to us – this may include any of the following types of personal data which you provide to us when you sign-up to be an England Squash member, when you enter a tournament, enquire about a coaching or referee course or otherwise when you communicate or interact directly with us:
  • Identity Data - first name, last name, gender, images of you, username or other user identifier, date of birth, nationality;
  • Contact Data – your phone numbers, email address and postal address;
  • Financial Data – bank or payment card details and details of any purchases you make through England Squash; and
  • Profile Data – you may provide feedback to England Squash through surveys or feedback forms and indicate your preferences to receiving marketing (from us or third parties).
• Information that we collect about you – when you visit the England Squash website we automatically collect the following types of personal data, using cookies or other similar technologies:
  • Technical Data – this might include your IP address, account log-in information, browser information, location information, operating system and system configuration, network and software identification and device information; and
  • Usage Data – this includes information about how you use the England Squash website, such as click throughs, time spent on page, download errors.
    Please review our Cookies Policy for further information.
• Information that we receive about you from others – we may receive information about you when you use our connected platforms (such as the Club Locker platform referred to below) or from other relevant third parties, including your squash club or your county (provided in each case that the collection, transfer to, and use by, England Squash is lawful). The information which we collect from these third parties may include any or all of the above types of information. If we receive information from third parties we may combine this with information that we currently hold about you and process such combined information for the purposes set out below.

In addition to the above, please note that we may use and share aggregated data (such as demographic data). This may have originally generated from your personal data but is not treated as personal data under GDPR (as it doesn’t individually identify you). On such basis, we can use this data for any purpose. If this aggregated data is ever combined with other data in such a way that you can be personally identified, we will only use that data in accordance with this Privacy Policy.

It is important that the information we hold about you is accurate. Please keep us informed of any changes to your personal information.

Special category data - sometimes we may ask you to provide the following types of personal data, which are seen as more sensitive and are therefore afforded greater protection under GDPR. Prior to collecting and using any such data, we will obtain explicit consent from you (unless we have another legal basis for collecting and using this information) and will only use this data for the following purposes (or such other purposes as are explained to you at the time of collection):

• Ethnicity data - this will be used to identify and keep under review equality of opportunity within England Squash and (anonymously) for statistical and reporting purposes.
• Disability data - this will be used to identify and keep under review equality of opportunity within England Squash and (anonymously) for statistical and reporting purposes.
• Injuries and other medical data - this may be collected by us directly from you, your county or via your club e.g. through a tournament withdrawal form. It will be used to assist with tournament results and rankings information and (anonymously) for statistical and reporting purposes.
• Anti-doping related data - if you are an elite player who is required to participate in doping control procedures undertaken by a doping control officer appointed by UK Sport or England Squash, the results of such procedures may be used in results management, including associated disciplinary hearings, appeals and adjudications.
• Criminal records data - we are registered with the Disclosure and Barring Service (DBS) to assist it in ensuring that those who take up England Squash appointments do not pose a risk to the children in our care. We may therefore process criminal records data disclosed by the DBS. This will be processed in accordance with the DBS’s Code of Practice for Registered Persons.

WHY WE USE YOUR DATA

We have set out in the table below, the purposes for using your personal data and the legal basis for doing so:

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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

HOW LONG DO WE KEEP YOUR DATA FOR?

We will keep your data for as long as you are an England Squash member and/or where you are still happy to hear from us about our latest news, products and services. Once you no longer wish to be engaged with England Squash we may still need to keep hold of your data if there is a legal reason for doing so (such as for tax purposes or where we need to resolve any disputes with you). In such circumstances, we will only retain the minimum amount of data necessary for such reason.

THIRD PARTY WEBSITE LINKS

Please note that the England Squash website may include links to third party websites (including to Club Locker and Squash Levels websites). If you choose to click through to the relevant third party’s website, you will be subject to the terms and conditions of use and privacy policy of the relevant third party. England Squash does not accept any responsibility or liability for these policies of your use of such third-party websites. Please check the terms of these policies before using the relevant third party’s website.

INTERNATIONAL TRANSFERS OF YOUR DATA

Please be aware that the Club Locker platform (referred to above) is owned and operated in the United States and as such, personal data processed on the Club Locker platform will be transferred to, and processed on servers located in, the United States. England Squash will ensure that personal data processed through the Club Locker platform on its instructions is treated fairly and lawfully in all respects (including putting in place all necessary safeguards for such transfer).

In the future, England Squash may need to transfer your personal information to other countries outside of the European Economic Area ("EEA"). This may happen if any of our servers are from time to time located in a country outside of the EEA or if any of our service providers are located in a country outside of the EEA. Before we proceed with any such transfer, we will ensure that we have a legal ground for doing so and have made sure that all adequate protections are in place. These countries may not have similar data protection laws to the EEA. If we transfer your information outside of the EEA in this way, we will take the appropriate steps to ensure that your privacy rights continue to be protected and that we continue to process your data in a fair and lawful manner.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your personal information for the following purposes:

• We may disclose your personal information to our county associations, clubs, coaches, tournament organisers, agents, sub-contractors and consultants (including our consultant who manages referee appointments, marketing agencies, web developers, project consultants and finance agencies) as a data processor to England Squash who will process it strictly on our behalf for the purposes for which we originally collected from you.
• Where you have explicitly consented to us doing so, we will share your name, contact details and England Squash membership number with your local county squash association, so they can contact you about squash related matters in your county. We will only do this if you opt-in via your profile on the England Squash member portal. If you choose to opt in, your details will be shared with your county association as an independent controller and their use of this information and any further personal data you share directly with them will be subject their privacy policy, which we encourage you to read.
• If you use the Club Locker platform, the Global Squash Collaborative or ‘GSC’ (of which England Squash is a member) will have access to the personal data we hold about you as a member as a data processor to England Squash for the purposes of operating Club Locker. These include administering cross border rankings as directed by the GSC members, arranging and administering cross border tournaments and administering the use of Club Locker on behalf of England Squash (including the allocation of license fees). Any personal data you add directly to the Club Locker platform via their website will be collected and processed by Club Locker as an independent controller and their use of that personal data will be subject to their privacy policy, which we encourage you to review.
• If you are a member of the Squash Levels website, they will have access to information from England Squash membership profile as a data processor to England Squash for the purpose of publishing information about your squash ranking level on their public website. Any personal data you provide directly to Squash Levels via their website will be collected and processed by Squash Levels as an independent controller and their use of that personal data will be subject to their privacy policy, which we encourage you to read.
• Details of your performance in events, including images and/or video of you, may be published on our website and shared with certain third parties (as set out in this privacy policy) and be available to view by the general public. This information will include your name and age group because this is how rankings are presented. We will only share ranking information for Junior Members if they or their parent / guardian opt-in via their profile on the England Squash member portal.
• We may also be required to share your personal data with third parties if required by law or regulation. In such circumstances, we will make sure that the disclosure is only to the extent required by law or regulation.
• If you are an elite player, we may also be required to share your personal data with third party disciplinary panels, and anti-doping bodies.

If we share personal data with third parties who are data processors to England Squash, we will ensure that access is limited on a strictly need to know basis and is subject to suitable obligations relating to confidentiality and security.

WHERE WE STORE YOUR DATA

Save in circumstances where your data is being processed through the Club Locker platform (as referred to above), we will store your data on UK servers and will ensure that such data is held securely in accordance with good industry standards. Where we have given you a password to access a part of the England Squash website you are responsible for keeping this password secure and confidential. Please do not share this with anyone else.

Please be aware that the transmission of data via the internet is not completely secure. Although England Squash uses its best endeavours to keep your data secure, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.

CHANGES TO OUR PRIVACY POLICY

If we amend our Privacy Policy, it will be published on the England Squash website so please check the website regularly to see if there have been any changes. We may also email you to notify you of any substantial changes to this Privacy Policy.

YOUR RIGHTS

In certain situations, you are entitled to:

• access a copy of your personal data;
• correct your personal data;
• erase your personal data;
• object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table);
• restrict the processing of your personal data;
  
• request the transfer of your personal data to a third party; or
  
• where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).
  

If you wish to exercise any of these rights, please contact us using the details set out in the “Contact Us” section below. You will not have to pay a fee to exercise any of these rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances.

In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your personal data.

HOW TO OPT-OUT

You can opt-out of any third-party marketing that you have previously opted into (or any England Squash marketing) either by contacting us using the details set out below in the “Contact Us” section or by using the opt-out function detailed in the relevant marketing email.

CONTACT US

If at any time you wish to get in touch with us, whether that is to exercise your rights or otherwise, please contact:

Email: enquiries@englandsquash.com.

Telephone: 0161 231 4499

England Squash has designated a Data Protection Officer (‘DPO’). You can contact our DPO by emailing dpo@englandsquash.com or by writing to us at England Squash Limited, National Squash Centre, Rowsley Street, Manchester M11 3FF, marked for the attention of the DPO.