Marketing Preferences
Privacy Policy and Member Terms and Conditions
Privacy Policy
General Data Protection Regulation (GDPR) Privacy Policy
Version: Final Version
Date: November 2018
Table of Contents
1.1 PURPOSE OF THE GENERAL DATA PROTECTION AND REGULATION DOCUMENT (GDPR) 2
1.2 OVERVIEW OF LEGISLATION 2
1.2.1 DEFINITIONS 2
1.2.2 Personal Data 2
1.3Type of Information that may be collected by FGC 2
1.3.1 Information may be collected by FGC relating to Visitors 3
1.4 WHAT IS DONE WITH THE INFORMATION THAT IS GATHERED 3
1.5 INDIVIDUALS RIGHTS 3
1.6 SHARING YOUR DATA 4
1.61What constitutes a breach? 4
1.7 CHANGES AND UPDATES TO GDPR PRIVACY POLICY 4
Members personal Data and GDPR Consent Form 5
Appendix-1-Club V1- INFORMATION PROCESSING AGREEMENT 7
1.1 PURPOSE OF THE GENERAL DATA PROTECTION AND REGULATION DOCUMENT (GDPR)
General Data Governance
This GDPR policy sets out how Faithlegg Golf Club (FGC) use and protect any information that is given to them by a visitor, a prospective member or an existing member.
The GDPR policy is a statement of FGC duty to protect the privacy and rights of individual members in accordance with legislation. In this regard FGC endeavours to comply with ‘General Data Protection and Regulation (GDPR, 2018).
1.2 OVERVIEW OF LEGISLATION
Data Protection is fundamentally about an individual’s right to privacy and the Data Protection Acts of 1988 & 2003 and the EC Electronic Communications Regulations (2011) have enshrined this right in Irish law. The Acts set out the general principle that individuals should be in a position to control how data relating to them is used (CGI,2018).
Data Protection applies to all businesses, companies, charities and organisations, it is not just relevant for Golf Clubs, but it is important that Golf Clubs comply with the legislation. Data Protection legislation applies where an individual or organisation collects, stores or processes any data about living people, often referred to as personal data, on any type of computer or in a structured filing system (CGI,2018).
1.2.1 DEFINITIONS
1.2.2 Personal Data
Data that relates to a living individual who can be identified directly from that data or whose identity can be derived from that data in conjunction with other data that may be available (CGI, 2018).
1.3 TYPE OF INFORMATION THAT MAY BE COLLECTED BY FGC
If you become a member FGC the following information may be collected about you:
o Name and surname;
o Home Address;
o Email Address;
o Mobile/Landline Telephone Number;
o Emergency contact number
o Gender;
o Date of Birth (only if necessary);
o Handicap;
o Membership Category
o Bank Details
o FGC Swipe Card Balances
Other personal data that is collected and held about you may include: Data collected through, Club V1, BRS, HowDidiDo, application forms and other hardcopy forms for the purposes of membership proposals.
1.3.1 Information may be collected by FGC relating to Visitors
o Visitors who use FGC facilities and/or enquire about services
o Book a tee time, play as a non-member or use the services of FGC
This information is used in order that contractual obligations can be fulfilled for members and visitors in line with FGC Constitution/Policies.
1.4 WHAT IS DONE WITH THE INFORMATION THAT IS GATHERED
Your personal data is administered internally by the Ladies and Men’s club committees, who adhere to the FGC internal data protection policies and procedures as outlined in this documentation.
1.5 INDIVIDUALS RIGHTS
You have the right to request a copy of the information that is held about you. If you would like a copy of this information please email/write to the Club Data Controller.
At the time of collecting data you have the right to object to the club holding certain information about you, for example,
o Member will be given the opportunity to ‘Opt-in’ before their details are included in any mailing lists for any communication, which is not related to club activity.
o In all cases, personal information relating to members will be kept safe and secure and will never be passed to third parties without the express permission of the member.
o Press Photos/Event photography and/or video shoots require the club to make members aware of the context in which it will be used.
o At point of capture (i.e. registration) members will be informed of the purpose or purposes that their information will be used for (Registration, club activities, fundraising, etc).
o When sending emails to a mailing list the Blind Copy address field will be used to ensure that email addresses are not inadvertently disclosed (CGI, 2018).
o Juveniles will not be directly corresponded with as Parents or Guardians contact details will be used.
o Members have to ‘Opt In’ to receive correspondence that is not directly related to club activities (not opt out).
o All members will be enabled to ‘Opt Out’ on correspondence issued (They will be removed from mailing lists as soon as possible, and at least within 40 days of notification).
o Individuals who have asked to ‘Opt Out’ will not be contacted by FGC.
o All Membership forms and related documentation, in hard copy, will be stored centrally in a secure location.
o Electronic records will be saved on an access-controlled device, preferably encrypted, logons will be updated annually and will not be shared.
o Data will be held only whilst there is a continued need for it – data will be reviewed and destroyed regularly. The “right to be forgotten” as it is now law in the EU. For golf clubs, this is the right for members to ensure that FGC erase their data, if they leave etc.
o FGC will anonymize, pseudononymize, encrypt, or delete specific data, where appropriate/warranted, for example, removing a member/visitor data when requested.
o FGC will account for, as far as is possible, shadow systems (unauthorised cloud services and indeed other software, referred to as Rogue systems).Data will be reviewed regularly for completeness and accuracy (at least yearly using 'GDPR Compliance Questionnaire'.
o A member can submit a Subject Access Request to request all the information held about them by FGC – this will be provided within 30-40 days.
1.6 SHARING YOUR DATA
Faithlegg Golf Club will not disclose your personal data to any third party outside the FGC, and the Company (FBD), save where required by law to do so under Directive 95/46EU.
1.6.1 What constitutes a breach?
Where an incident gives rise to a risk of unauthorised disclosure, loss, destruction or alteration of personal data, in manual or electronic form, the data controller must give immediate consideration to informing those affected. Such information permits data subjects to consider the consequences for each of them individually and to take appropriate measures (CGI, 2018).
1.7 CHANGES AND UPDATES TO GDPR PRIVACY POLICY
Contracts with external processors such as ClubV1, BRS and HowDidIDo will be reviewed annually in relation to GDPR.
The GDPR policy at Faithlegg Golf Club will be reviewed regularly. Review and any updates will be placed on the FGC Membership Administration System by the 1st January each year. Any modifications made to this document will be notified to you using the email address you supplied. If you need any further information or clarification regarding the GDPR policy, please write to the Data Controller at Faithlegg Golf Club.
Member Terms and Conditions
TERMS AND CONDITIONS:
These are the terms and conditions for booking tee times using our
online booking facility.
Payment
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To book a tee time online you will have to enter your credit or
debit card details using our secure on-line payment process.
Your card details will be held by us as insurance but we will not
process the transaction until you turn up to play.
When you turn up for your round of golf, you can choose
to pay by cash instead of credit card. You should report to the
pro shop before beginning your round. If the pro shop is closed,
you should call in after your round is complete.
Cancellation Policy
===================
You can cancel your booking on the web site by entering your unique
booking reference number.
If you cancel your booking more than 1 week before your date of play,
there will be no charge made to your credit/debit card.
If you cancel your booking less than 1 week in advance, there
will be a charge of 50% of the green fee made to your credit/debit card.
Failure To Cancel Your Booking
==============================
If you fail to cancel your booking, there will be a charge of 100% of
the green fee made to your credit/debit card.
Course Closed
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If you are unable to play your round of golf due to the course being
closed (e.g. bad weather), no charge will be made to your credit/debit
card.
Booking Transferable
====================
The Booking is completely transferable. Therefore, should you be unable
to make your tee time, you can offer the tee time to someone else such
as a family member or friend.
Handicaps
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This facility is only available to golfers who have a handicap of 28 or
less (men) or 36 or less (ladies). If you don't have a handicap, you
must be able to play to an equivalent standard.
Dress Code
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Normal golf dress code applies. The following are therefore not
permitted: denims, shorts, football/rugby tops, .....
Spikes
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Spikes may be worn.