Privacy policy

Summary of how we, the RFU and for wheelchair rugby members GBWR, use your data:
• Crawley RFC uses your personal data to manage and administer your membership and your involvement with its teams and club, and to keep in contact with you for these purposes.
• Some data is shared with the RFU, who use your data to regulate, develop and manage the game.
• Where we or the RFU rely on your consent, such as any consent we seek for email marketing, you can withdraw this consent at any time.
• Amongst the data we collect from you may be medical (including injury) information. We will hold this where you (or your parent) have given consent, so that we can ensure we are aware of your condition and can that you are supported appropriately.
• Where you work in a particular role within the game, you may be required to undergo a Disclosure & Barring Service check using the RFU’s eDBS system. The result of this check will be input into your Game Management Service (GMS) record.

What does this policy cover?
This policy describes how Crawley RFC (also referred to as “the Club”, “we” or “us”) will make use of the data we handle in relation to our members and players, including our use of the Game Management System (“GMS”) provided by the Rugby Football Union (“RFU”). The policy also describes the RFU’s use of data on GMS. 
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

What information do we collect?
• We collect and process personal data from you or your parent when you join and when we carry out annual renewals of your membership. This includes:
• your name,
• your gender,
• your date of birth,
• your RFU ID (as assigned in GMS)
• your GBWR membership, start and end date (if applicable).
• your home address, email address and phone number;
• your type of membership and involvement in particular teams, or any key role you may have been allocated, such as Chair, Safeguarding Lead, Membership Secretary etc.;
• your payment and/or bank account details, where you provide these to pay for membership;
• your marketing preferences, including any consents you have given us;
• your medical conditions or disability, where you provide this to us with your consent (or your parent’s consent) to ensure we are aware of any support we may need to provide to you and
• details of next of kin, family members, coaches and emergency contacts

Some information will be generated as part of your involvement with us, in particular data about your performance, involvement in particular matches in match reports and details of any disciplinary issues or incidents you may be involved in on and off the pitch, such as within health and safety records.

What information do we receive from third parties?
Sometimes, we receive information about you from third parties. For example, if you are a child, we may be given information about you by your parents. 
We may receive information relating to your existing registrations with other clubs or rugby bodies or disciplinary history from the RFU through GMS. Additionally, for certain role holders or those working with children, we may receive information from the Disclosure and Barring Service and RFU on the status of any DBS check you have been required to take.

How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
• To fulfil a contract, or take steps linked to a contract: this is relevant where you make a payment for your membership and any merchandise, or enter a competition. 
This includes:
• taking payments;
• communicating with you;
• As required by the Club to conduct our business and pursue our legitimate interests, in particular we will use your information to manage and administer your membership and your involvement with its teams and club, and to keep in contact with you for these purposes;
• we will also use data to maintain records of our performances and history, including match reports, score lines and team sheets;
• we use CCTV cameras to maintain the security of our premises, and may use this video to investigate incidents at the Club or its premises
• we may choose to send you promotional materials and offers by post or by phone, or by email where we want to send you offers relating to similar products and services that you have already bought
• we use data of some individuals to invite them to take part in market research;
• where you give us consent we will send you promotional material by email;
• we may handle medical or disability information you or your parent provides to us, to ensure we support you appropriately;
• on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
• For purposes which are required by law:
• we maintain records such as health and safety records and accounting records in order to meet specific legal requirements;
• we ensure, where you will work with children, that you have undergone an appropriate DBS check – this is also carried out with your consent.
• where you hold a role at the Club requiring us to check your right to work, we may process information to meet our statutory duties;
• we may respond to requests by government or law enforcement authorities conducting an investigation.

How does the RFU use any of my information?
• The RFU provides GMS, but make its own use of the following information:
• your name;
• your gender;
• your date of birth;
• your RFU ID (as assigned in GMS);
• your home address, email address and phone number; and
• your type of membership and involvement in particular teams at the Club, or any key role you may have been allocated, such as Chair, Safeguarding Lead, Membership Secretary etc.
• The RFU uses this information as follows:
• As required by the RFU to conduct its business and pursue its legitimate interests, in particular:
• communicating with you or about you where necessary to administer Rugby in England, including responding to any questions you send to the RFU about GMS;
• administering and ensuring the eligibility of players, match officials and others involved in English Rugby – this may involve the receipt of limited amounts of sensitive data in relation to disabled players, where they are registered for a disabled league or team, or in relation to anti-doping matters;
• maintaining records of the game as played in England, in particular maintaining details of discipline and misconduct;
• monitoring use of GMS, and using this to help it monitor, improve and protect its content and services and investigate any complaints received from you or from others about GMS;
• maintaining statistics and conducting analysis on the make-up of rugby’s participants;
• ensuring compliance with the current RFU Rules and Regulations including those on the affiliation of clubs, referee societies, constituent bodies and other rugby bodies, and registration of players; and
• communicating with you to ask for your opinion on RFU initiatives.
• For purposes which are required by law:
• The RFU will ensure, where you will work with children and where this is required, that you have undergone an appropriate DBS check – this is also carried out with your consent.
• The RFU may respond to requests by government or law enforcement authorities conducting an investigation.

Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below in the “How do I get in touch with you or the RFU?” section.

Who will we share this data with, where and when?
Apart from sharing data with the RFU and GBWR (for wheelchair members only), we will NOT share you data with any other 3rd party.
Some limited information may be shared with other stakeholders in rugby and wheelchair rugby, such as

other clubs, Constituent Bodies, referee societies, league organisers, so that they can maintain appropriate records and assist us in organising matches and administering the game.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our or the RFU’s or GBWR’s legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers, who will process it on our behalf for the purposes identified above. Such third parties include the RFU as the provider of GMS.

What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

You have the same rights for data held by the RFU for its own purposes on GMS and GBWR.
To exercise any of these rights, you can get in touch with us– or, as appropriate, the RFU or its data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to the Information Commissioner’s Office.

Much of the information listed above must be provided on a mandatory basis so that we can make the appropriate legal checks and register you as required by RFU Rules and Regulations. We will inform you which information is mandatory when it is collected. Some information is optional, particularly information such as your medical information. If this is not provided, we may not be able to provide you with appropriate assistance, services or support.

How do I get in touch with you or the RFU?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, you can contact the Club Honorary Secretary who acts as the Data Officer at the club.

If you have any concerns about how the RFU process your data, you can get in touch at legal@rfu.com or by writing to The Data Protection Officer, Rugby Football Union, Twickenham Stadium, 200 Whitton Road, Twickenham TW2 7BA.

How long will you retain my data?
We process the majority of your data for as long as you are an active member and for 2 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data for 2 years unless you ask us to stop, when we will only process the data for a short period after this (to allow us to

implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we process personal data in connection with performing a contract or for a competition, we keep the data for 2 years from your last interaction with us.

We will retain information held to maintain statutory records in line with appropriate statutory requirements or guidance.

The RFU will maintain records of individuals who have registered on GMS, records of DBS checks and the resulting outcomes and other disciplinary matters for such period as is set out in the RFU’s privacy notice to be set out on www.englandrugby.com.

Records of your involvement in a particular match, on team sheets, on results pages or in match reports may be held indefinitely both by us and the RFU in order to maintain a record of the game.

GBWR will retain details of members registered with them. They collect personal details from players and volunteers for different reasons and so might keep it for different lengths of time. For example, they might have to keep it for a long time for legal reasons, but most of the time, we will keep your details for 6 years after you last get in touch with them.

Crawley Rugby Football Club (CRFC) Data Protection Policy
Policy Statement
Crawley Rugby Football Club (CRFC) is committed to protecting the privacy and security of personal data. This policy outlines our approach to data protection and compliance with applicable data protection laws, ensuring that all members and stakeholders understand their rights and responsibilities.
Purpose
This policy aims to ensure that CRFC processes personal data in a manner that respects individual privacy rights and complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Status of the Policy and Implications of Breach
This data protection policy is a formal document that outlines CRFC's commitment to data protection. Any breach of this policy, whether by individual members or the club as a whole, may lead to disciplinary action. Consequences may include:
• For individuals: Warnings, suspension, or termination of membership.
• For the club: Regulatory fines, reputational damage, and potential legal action.
2. Applicable Data Protection Laws
CRFC adheres to the following data protection laws:
• The UK General Data Protection Regulation (UK GDPR).
• The Data Protection Act 2018.
• Any relevant guidance issued by the Information Commissioner’s Office (ICO).
3. Lawful Basis for Processing
CRFC will only process personal data where there is a lawful basis to do so. The lawful bases include:
• Consent
• Contractual necessity
• Legal obligation
• Legitimate interests

4. Definition of Personal Data and Special Category Data
• Personal Data: Any information relating to an identified or identifiable individual, such as names, contact details, dates of birth, and addresses.
• Special Category Data: Sensitive personal data that requires additional protection, including information about racial or ethnic origin, political opinions, religious beliefs, health information, and sexual orientation.
5. Principles of Data Protection
CRFC adheres to the following data protection principles:
• Lawfulness, Fairness, and Transparency: Data will be processed lawfully and transparently.
• Purpose Limitation: Data will be collected for specified and legitimate purposes.
• Data Minimization: Only necessary data will be collected and processed.
• Accuracy: Data will be kept accurate and up to date.
• Storage Limitation: Data will not be retained longer than necessary.
• Integrity and Confidentiality: Data will be processed securely.
6. Data Subject Rights
Individuals have the following rights regarding their personal data:
• Right to Access: Request a copy of their personal data.
• Right to Rectification: Request correction of inaccurate data.
• Right to Erasure: Request deletion of their data under certain conditions.
• Right to Restrict Processing: Request restriction of data processing.
• Right to Data Portability: Request transfer of data to another service.
• Right to Object: Object to data processing for specific purposes.
To exercise these rights, individuals should contact the club using the details provided below.
7. Club Obligations in Relation to Data Protection
CRFC has the following obligations:
• To process personal data lawfully and transparently.
• To implement appropriate security measures to protect personal data.
• To notify individuals of any data breaches where there is a risk to their rights.
• To maintain accurate records of data processing activities.
8. Data Security
CRFC will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:
• Secure storage of personal data.
• Access controls to limit data access to authorized personnel only.
• Regular training for staff on data protection.
9. Data Sharing
CRFC may share personal data with:
• Governing bodies (e.g., England Rugby) for compliance purposes.
• Emergency services in the event of an incident involving club members.
• Third-party service providers (e.g., insurance providers) only when necessary and subject to appropriate safeguards.
10. Data Retention
Personal data will be retained only for as long as necessary to fulfil the purposes for which it was collected. Specific retention periods will be determined based on the type of data and the legal requirements.
11. Correct Procedure in Example Scenarios
• Scenario: Data Breach: In the event of a data breach, the club must report it to the ICO within 72 hours and inform affected individuals if there is a high risk to their rights.
• Scenario: Access Request: If an individual requests access to their data, the club must respond within one month and provide the requested information in a clear format.
12. Foreign Transfer of Personal Data
CRFC will not transfer personal data outside the UK unless:
• The destination country ensures an adequate level of data protection.
• Appropriate safeguards (such as Standard Contractual Clauses) are in place.
• The transfer is necessary for specific legal or contractual reasons.
13. Policy Review
This policy will be reviewed annually or in response to changes in legislation or club operations.
14. Contact Information
For questions or concerns regarding this policy or data protection practices, please contact:

Jack Chapman
Hon. Secretary, Crawley Rugby Football Club
secretary@crawleyrfc.com
01293 533995