Fakenham RUFC Ltd
This document has been produced by Mike Wyatt, Data Officer, Fakenham RUFC Ltd.
Data protection policy
Context and overview
- Policy prepared by:Mike Wyatt
- Approved by
Management Committee on: 17.05.2018
- Policy became operational on:20.05.2018
- Next review date:Click here to 20.05.2019
Fakenham Rugby Union Football Club Ltd (also referred to as Fakenham RUFC Ltd, the Club or we) needs to gather and use certain information about individuals.
These can include players, members, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures Fakenham RUFC Ltd:
- Complies with data protection law and follow good practice
- Protects the rights of staff, players, members and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
Data protection law
The Data Protection Act 1998 describes how the organization— Fakenham RUFC Ltd— must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
- Fakenham RUFC Ltd
- All Committee, Directors, Members, Players, Staff and Volunteers of Fakenham RUFC Ltd
- All contractors, suppliers and other people working on behalf of Fakenham RUFC Ltd
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- …plus any other information relating to individuals
Data protection risks
This policy helps to protect Fakenham RUFC Ltd from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the Club uses data relating to them.
- Reputational damage. For instance, the Club could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with the Club has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
- The Board of Directors and the Management Committee are ultimately responsible for ensuring that the Club meets its legal obligations.
- The Data Officer, Michael Wyatt, is responsible for:
- Keeping the board and Committee updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data the Club holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- The Data Oficer is also responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, it can be requested it from the appropriate managers.
- Fakenham RUFC Ltd will provide training to all members, employees and Committee Members to help them understand their responsibilities when handling data.
- Members, employees and Committee Members should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared.
- Personal data should not be disclosed to unauthorised people, either within the Club or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of unless required to be stored for legal or business reasons.
- Members, Employees and Committee Members should request help from the data officer if they are unsure about any aspect of data protection.
- When quantities of personal subject data are sent via email it should preferably only be sent in an encrypted form.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the data officer.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- All users should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are never shared between users.
- If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
- Data should preferably only be stored on designated drives and servers (the RUFC’s GMS), and should only be uploaded to approved cloud computing services.
- Computers containing personal data should be sited in a secure location.
- Data, if not held centrally, should be backed up frequently. Those backups should be tested regularly, in line with the club’s standard backup procedures.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones, unless strong access controls are in place.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to the Club unless the Club can make use of it! However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, users should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by open email, as this form of communication is not secure.
- Data lists must be either encrypted before being transferred electronically or sent as end to end encrypted email. The Data Officer can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area.
- Employees should not save copies of personal data to their own computers. Always, where possible, access and update the central copy of any data.
The law requires Fakenham RUFC Ltd to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort the Club should put into ensuring its accuracy.
It is the responsibility of all users who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Users should not create any unnecessary additional data sets.
- Users should take every opportunity to ensure data is updated. For instance, by confirming a member’s details if they call.
- The Club will make it easy for data subjects to update the information held about them by writing in or emailing for instance.
- Data should be updated as and when inaccuracies are discovered. For instance, if a member can no longer be reached on their stored telephone number, it should be removed from the database.
Subject access requests
All individuals who are the subject of personal data held by Fakenham RUFC Ltd are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the Club is meeting its data protection obligations.
If an individual contacts the Club requesting this information, this is called a subject access request.
Individuals may be charged £10 per subject access request. The data officer will aim to provide the relevant data within 14 days.
The data officer will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Fakneham RUFC Ltd will disclose requested data. However, the data officer will ensure the request is legitimate, seeking assistance from the board and committee and from the Club’s legal advisers where necessary.
Fakenham RUFC Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
This is available on request or download from the Club website www.fakenhamrugby.com
Data Incident and Breach Notification
If at any time it is discovered that there has been a data breach which exposes Data subjects data to any possible risk, Articles 33 and 34 of the General Data Protection Regulation (GDPR) require datacontrollers to notify data protection authorities (DPA) in the event of a personal data breach within 72 hours of discovery. The GDPR requires data controllers to notify the supervisory authority about personal data breaches when a personal data breach is likely to result in a risk to the rights and freedoms of natural persons. Personal data breaches need to be communicated to individuals if there is a high risk to the rights and freedoms of natural persons.