Privacy Policy
Privacy Notice
Introduction
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.
This privacy policy sets out how we use and protect any information that you give to us when you become a member of Edmondstown Golf Club EGC.
We are committed to ensuring that your privacy is protected, and we will never release your personal details to any third party without your express consent. When you complete an application to join the club certain personal information is collected from you (for example: your name, email address, gender, golf handicap, type of membership sought). You can be assured that it will only be used in accordance with this privacy statement.
What we collect
We may collect the following information:
Name and surname
Date of Birth
Current Address
Phone numbers
Email address
Gender
Occupation
Handicap ability
Membership Category
Bank details (If you wish to sign up for the subscription direct debit scheme)
What we do with the information we gather
We require this information to administer your membership and to provide the products and services you have requested from us and provide you with a better service for the following reasons:
Internal record keeping.
Sending subscription notices to you.
Recording financial transaction to your subscription account.
Contacting you with relevant club correspondence.
Send promotional emails about special offers, competitions, results or other information which we think you may find interesting using the email address which you have provided.
From time to time, we may also use your information to contact you for club research purposes.
We may use the information to customise the website according to your interests.
Maintaining a record of any competitions you play in.
Maintaining a record of your handicap and related GUI / ILGU Number.
Providing you with a Member’s Card for gaining access to the club, spending of the bar & restaurant levy & handicapping and competition entry.
Confirm your handicap to other Golf Clubs if they request confirmation of your handicap for any competitions you have entered with them.
Provide your contact details to other club members such as team managers for the sole use of club business
Your handicap details and membership number are displayed in the Locker Room area of the Clubhouse. Under the Data Protection Acts, you are entitled to write to the Golfing Union of Ireland or Irish Ladies Golf Union at their address or email
[email protected] /
[email protected] to request a copy of your personal data which GUI/ ILGU- Golfnet holds. Similarly with ‘BRS’ which operates the club reservation system.(www.brs.com). Further details are available on the ‘Help for Clubs’ section of the CGI website at www.cgigolf.org.
CCTV
EGC uses CCTV to capture images of individuals or information relating to individuals for Health and Safety and crime prevention.
Data is processed fairly and lawfully and Images of people and the information which is derived from images – for example, vehicle registration numbers, are covered by the Data Protection Act. Recorded material is password protected and stored for a maximum of 28 days. Advisory Signs are in use at the premises
CGI/GUI/ILGU:
The Club is affiliated to the Golfing Union of Ireland and the Irish Ladies Golf Union. The GUI and the ILGU operate and maintain the details of the handicap of members on the www.golfnet.ie system and for this purpose allocates each individual member of the Club a unique personal identifier number (your unique “Club Membership No.”). The system has been designed by GUI/ILGU to provide members of Clubs affiliated to GUI/ILGU, including Clontarf Golf Club, with enhanced membership services free of charge.
The purposes for which GUI/ILGU may use the data are as follows:
1. GUI/ILGU may use your details to communicate directly with the people who play the sport in Ireland, to provide them with information and other benefits relating to their membership; and
2. The provision of a handicap system for all individual members of affiliated Clubs and the wider golf community through the introduction of the Club Membership Number. You agree that the Club and other GUI/ILGU affiliated Clubs at which you may play in competition may provide your name, address, phone number, email address, membership no., gender, date of birth, your card number and your results history to the GUI/ILGU for the purposes of operating the data base system. The Club agrees to keep your data on the system securely and to only use it for the purposes set out in this notice.
Electronic payments
EGC complies with the security requirements of the credit card Payment Card Industry Data Security Standard (PCI DSS) Program and compliance is validated annually.
PCI requirements apply to all systems that store, process, or transmit cardholder data. Electronic storage of cardholder data is not conducted or permitted.
Changes to our Privacy Policy
We keep our privacy policy under regular review and will place any updates on the notice board.
This privacy policy was last updated in MAY 2018.
Personal Data
EGC uses the information collected from you to provide membership services, subscription billing, make telephone contact and to email you marketing information which EGC believes may be of interest to you. In you making initial contact you consent to EGC maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. EGC also acts on behalf of its members in the capacity of data processor.
Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. EGC may from time to time use such information to identify its visitors. EGC may also collect statistics about the behavior of visitors to its website.
EGC’s website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Clubview.co.uk uses cookies to help EGC identify and track visitors and their website access preferences. EGC website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using EGC’s website.
EGC will only collect the information needed so that it can provide you with membership & marketing services. EGC does not sell or broker your data.
Legal basis for processing any personal data
To meet EGC’s obligations to members and to also respond to marketing enquiries.
Legitimate interests pursued by EGC and/or its contractors
To promote the marketing and services offered by EGC and/or to market the services and/or products offered by EGC’s contractors such as the club professional and caterer.
Consent
Through agreeing to this privacy notice you are consenting to EGC processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing
[email protected] or writing to us, see last section for full contact details.
Disclosure
EGC may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. EGC requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.
EGC do not broker or pass on information gained from your engagement with the club without your consent. However, EGC may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Edmondstown Golf Club, its members, guests and/or the wider community.
Retention Policy
EGC will process personal data during the duration of any membership / contract and will continue to store only the personal data needed as outlined in the Data Retention Policy.
Data storage
Data is held in Ireland using different (multiple) servers. EGC does not store personal data outside the EEA.
Your rights as a data subject
At any point whilst EGC is in possession of or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that EGC refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
EGC at your request can confirm what information it holds about you and how it is processed
You can request the following information:
• Identity and the contact details of the person or organisation (Edmondstown) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of EGC or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required
EGC will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If EGC is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to
[email protected] or by phoning (01) 4931082 ext. 3 or writing to us at the address further below.
Complaints
In the event that you wish to make a compliant about how your personal data is being processed by EGC or its partners, you have the right to complain to EGC’s Board. If you do not get a response within 30 days you can complain to the Data Protection Regulator.
The details for each of these contacts are:
Chairperson of the Board
Edmondstown Golf Club
Edmondstown Road
Rathfarnham
Dublin 16
Telephone +353 (0)1 4931082 ext. 3 or email
[email protected]
Data Protection Regulator
Office of the Data Protection Commissioner
Canal House
Station Road
Portarlington
Co. Laois, R32 AP23
Telephone 1890 25 22 31 or email:
[email protected]