Privacy Notice - Westmanstown Golf Club
This privacy notice explains how Westmanstown Golf Club collects, processes and shares your personal data, and your rights in relation to the data held. Westmanstown Golf Club is the controller of your personal data and is subject to the Data Protection Acts 1988 to 2018 and the General Data Protection Regulation (GDPR).
The General Data Protection Regulation (GDPR) and the Data Protection Acts 1988 to 2018 confer rights on individuals regarding their personal data as well as responsibilities on persons processing data, in this case Westmanstown Golf Club.
This privacy notice outlines the policy of Westmanstown Golf Club concerning the personal data it collects and processes in relation to its members. This notice applies to those engaged in processing Personal Data relating to members for administrative, golfing matters or other purposes including;
- Persons employed by or engaged by the Club in such a role.
- Contractors and agents engaged by and acting on behalf of the Club in such a role.
- Members of the Club (which in this context includes member applicants, existing members and former members).
- Principles of the Data Protection Legislation
Westmanstown Golf Club will comply with its responsibilities under this legislation in accordance with the eight principles set out in the Acts as follows;
- It shall be obtained and processed lawfully and fairly.
- It shall be kept only for one or more specified and lawful purposes.
- It shall not be used or disclosed in any manner incompatible with these purposes.
- It shall be adequate, relevant and not excessive in relation to the purpose for which they are processed.
- It shall be kept in a form that permits the identification of the data subject and shall not be kept for longer than is necessary for the purposes for which the data are processed.
- It shall be accurate, complete and up- to-date.
- Appropriate security measures shall be taken against unauthorised access to or alteration, disclosure or destruction of the data or against their accidental loss or destruction.
- The Club has procedures in place to ensure that data subjects can exercise their rights under the Data Protection legislation.
- Personal Data
Personal data means any information relating to; - (a) an identified living individual or (b) a living individual who can be identified from the data, directly or indirectly, in particular by reference to (i) an identifier such as a name, an identification number, location data or an online identifier, or (ii) one or more factors specific to the physical, physiological, genetic, mental, economic cultural or social identity of the individual.
Special Categories of personal data means;
- Personal data revealing;
- The racial or ethnic origin of the data subject.
- The political opinions or the religious or philosophical beliefs of the data subject, or
- Whether the data subject is a member of a trade union,
- Genetic data.
- Biometric data for the purposes of uniquely identifying an individual.
- Data concerning health.
- Personal data concerning an individual’s sex life or sexual orientation.
- Collection of Members Personal Data
The Club collects personal data in a number of ways;
- Directly from you – such as information you provide when you interact with the Club on becoming a member. From online and hard copy information provided when you communicate with the Club by telephone, email or via our website to make enquiries or raise concerns and in various other ways as you interact with the Club during your time as a member.
- From third parties – such as information from other golf clubs (e.g. handicap certificates, information to administer the club and provide you with the services you require).
- Other ways – such as the use of CCTV operated to protect the interest of members and the Club and is used only for that purpose.
- Categories of Members Personal Data Collected
Club members personal data collected includes.
- First name, family name, date of birth and current addresses.
- Email contact details and telephone numbers.
- Identification numbers, where required for annual subscription payments.
- GUI/ILGU number.
- Handicap records. & Membership category.
- Medical Certificates where approval of Leave of Absence is sought/granted.
- In the case of Junior Golfers, details of their parent/guardian and declared medical ailments.
- Garda Vetting Forms in respect of members having responsibilities for Junior members.
- CCTV Images.
- Club Lotto competition records.
Personal data is collected and maintained by a limited number of Staff and is not shared across the Club’s membership. Details are disclosed either in line with the legal requirements of the Club (e.g. Garda Vetting forms are sent via the Confederation of Golf, to the Garda Vetting Office or upon the furnishing by a Member of their written consent to disclosure.
- Purposes and Legal Basis for Processing
The Club processes personal information to administer your membership and to provide the products and services you receive from us at the Club on request or mandatory (e.g. members golf insurance) and to provide a quality service in the following areas;
- Administration of the Club.
- Recording financial transactions to your account (e.g. annual subscription payment, competition fee payments).
- Promoting our services and providing you with relevant club correspondence.
- Maintaining a record of all competitions you play in.
- Maintaining a record of your handicap and Central Database Handicaps (CDH) number.
- Ensuring the security and safety of our members. The Club operates a CCTV security system which is used only for this purpose.
- Confirming your handicap to other golf clubs if they request confirmation of your handicap for any competition you have entered with them.
- Identifying and blocking disruptive use of the Website.
- Monitoring use, including number of visits to our Website and location data. Technical details of your visit to our website are recorded for business reasons. None of this information can be used to ascertain your identity. The following technical details are recorded (a) IP address; (b) top-level domain names e.g. .ie, .com, .org, .net. (c) web search terms; (d) Browser-type used and operating system. This technical information will only be used for statistical and other administrative purposes.
- If you choose to contact us via email, your details will be used only for the purposes for which you intended. When your email has been actioned, the original message will be retained by the Club for a reasonable period of time.
- We do not record or store your Credit/Debit card details for any length of time following a payment in person or over the telephone. They are immediately destroyed when the payment goes through.
The legal bases on which the Club processes members personal data are;
- That it is necessary for compliance with a legal obligation that applies to us (e.g. Children First Act 2015, National Vetting Bureau (Children and Vulnerable Persons) Act 2012 to 2016).
- Recipients of Members Personal Data
- We disclose data to the GUI Golfnet system for purposes set down in the CONGU unified handicap system and to other service providers to the Club for these purposes.
- We disclose data to the GUI & ILGU who provide a handicap system for all individual members of affiliated Clubs through the introduction of the Club Membership Number.
- Unless you specifically request the Club Secretary to do otherwise, the Club’s office staff will provide your telephone numbers to other members for the purposes of arranging matches, changing playing times etc. Your address will not be provided directly to other members without your agreement. The Office will first contact you should such a request be made.
- Your name, golf category and exact handicap is shown on the “Monthly Handicap List” posted on the Notice Board at the Clubhouse.
- Where a parent/guardian has provided information about a Junior Member of the Club, they confirm that they are appointed to act for that Junior member in regard to the processing of their personal data and to receive on their behalf any data protection notices from the Club.
- In exceptional circumstances, (e.g. injury to a Junior member where urgent communication with a parent/guardian has been unsuccessful), contact may be made with the Juniors alternative adult nominee to be contacted in an emergency.
- Provide An Garda Siochana with downloads of CCTV footage when a formal written request is made stating that they are investigating a criminal matter.
- We disclose data to our Insurers to facilitate the provision of the mandatory Members Insurance cover.
In no circumstances will your personal information be used by us for direct or indirect marketing purposes.
- Where we Store Your Personal Data
Personal data relating to members is stored electronically on secure servers provided by external “data processors” with whom the Club has operating contracts in place to ensure your personal data is stored safely and securely. Some data is in manual form and stored safely and securely at our offices with access restricted to a limited number of personnel.
We do our best to protect your personal information but unfortunately the transmission of information via email is not a fully secure method of communication. If there are details which for any reason you do not wish to send via email, you should contact us by post or telephone. (See contact details at 13 below).
- Retention of Personal Data
The Club will retain your personal information on its Membership Data Base for the duration of your membership.
- Data Subject (Members) Rights
As a member in respect of whom the Club holds personal data, you have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data.
- The right to access the personal data we hold about you.
- The right to request the rectification or erasure of the personal data we hold about you in certain circumstances.
- The right to restrict the use of the personal data we hold about you in certain circumstances.
- The right to object to the processing of the personal data we hold about you in certain circumstances.
- The right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require the Club to transmit that data to another controller in certain circumstances.
- The right to withdraw your consent at any time, where the Club’s processing of your personal data is based on you having provided consent.
Club members can exercise their rights by contacting the Clubs Honorary Secretary (See contact details 13 below).
- The Club has overall responsibility for ensuring compliance with the Data Protection legislation.
- All employees and members of the Club who collect and/or control the contents and use of personal data are also responsible for compliance with the Data Protection legislation.
- Staff and Members must report any personal data security breaches to the Data Protection Officer i.e. the Clubs Honorary Secretary.
- The Clubs Data Protection Officer will assist the Club’s staff and members in complying with the Data Protection legislation by providing and facilitating, support, assistance, advice and training.
If you wish to make an access request or exercise your rights as outlined under data protection law or have any queries about this notice please contact the Clubs Data Protection Officer.
Postal Address; Westmanstown Golf Club, Westmanstown, Clonsilla, Dublin 15
If you are dissatisfied with the decision of the Data Protection Officer, you have the right to make a complaint to the Data Protection Commissioner
Lo Call Number 1890 252 231
Postal Address Data Protection Commissioner, Canal House, Station Road Portarlington
The Club may occasionally update this notice. We encourage you to periodically review this notice for the latest information on our privacy practices. We also encourage you to advise us of any changes to your personal data which we hold so that we can ensure that your personal data is accurate and up to date.
Data Protection Officer
Westmanstown Golf Club.
Dated 24th May 2018