Policy key definitions:
• “I”, “our”, “us”, or “we” refer to the Cardiff Junior Devils Ice Hockey Club.
• “you”, “the user” refer to the person(s) using the website or other club provided services.
• GDPR means General Data Protection Act.
• PECR means Privacy & Electronic Communications Regulation.
• ICO means Information Commissioner’s Office.
• Cookies mean small files stored on a user’s computer or device.
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.
• We are exempt from registration in the ICO Data Protection Register because we are not for profit organisation. However, our Data Protection Officer (DPO) is registered with the ICO.
• The Club is committed to keeping your personal information only for so long as is necessary or where we have a legitimate or legal interest to continue doing so. Where the club no longer requires information to be in a format where you can be identified personally, e.g. where we keep information for analytical and research purposes or transaction information, we will remove any personal details about you.
• Sharing your information: We do share your personal information with third parties and they include;
o Team App
o Fixtures Live
o English Ice Hockey Association
These bodies are regarded as Data Controllers for the purposes of GDPR
and will have their own Privacy Policies.
• Lawful basis: Legal obligation
The reason we use this basis: As a registered Charity and a fee based organisation we are required by law to retain some information.
We process your information in the following ways: HMRC require financial transaction data to be retained for tax compliance purposes.
Data retention period: Up to 6 years
Sharing your information: We may be required to share your personal information with HMRC or the Charities Commission
• Lawful basis: Criminal offence data
The reason we use this basis: To ensure the safety of our members we process your information in the following ways:
Personal data maybe retained in accordance with the Disbarring Service guidelines
Data retention period: As detailed by the DBS
Sharing your information: We may be required share your personal information with law enforcement and other Government agencies
• Lawful basis: Special Category data
The reason we use this basis: To ensure the health and wellbeing of all our players we process your information in the following ways: Data shared with us is only made available on a “need to know” basis. This may include medical or other sensitive data. Records will be retained to ensure correct procedures have been followed and to provide an evidential trail in support of additional external actions.
Data retention period: This data will be retained whilst the player remains a member of the club and could be retained up to 5 years following departure.
Sharing your information: We may share your personal information with third parties and they include;
o The English Ice Hockey Association and / or subsidiaries
o The club’s Insurers
o The club’s legal services
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant. Your individual rights under the GDPR your rights are as follows. You can read more about your rights in details here;
• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to data portability;
• the right to object; and
• the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Email, messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any messages we send are done so through an EMS, messaging service provider. An EMS is a third-party service provider of software / applications that allows them to send out email or messages to a list of users.
Such services may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
link included in the Resources section below.
Resources & further information
• Overview of the GDPR – General Data Protection Regulation
• Data Protection Act 1998
• Privacy and Electronic Communications Regulations 2003
• The Guide to the PECR 2003