LITHERLAND ATHLETIC JFC
PRIVACY POLICY
PRIVACY POLICY
This Privacy Policy explains how Litherland Athletic JFC collects, uses, protects and shares personal information relating to players, parents, guardians, staff, volunteers, supporters, customers, website visitors and other people who interact with the Club.
1. WHO WE ARE
Litherland Athletic JFC ("LAJFC", "the Club", "we", "us" or "our") is a grassroots football club based in the United Kingdom.
For the personal information described in this Policy, Litherland Athletic JFC will generally act as the data controller because the Club decides why and how that personal information is used.
Contact email:
info@lajfc.co.uk
Postal address:
[INSERT CLUB POSTAL ADDRESS]
Safeguarding contact:
[INSERT SAFEGUARDING EMAIL]
2. OUR COMMITMENT TO PRIVACY
We recognise that football clubs are trusted with personal information relating to children, parents, families, volunteers, staff, supporters and customers.
Children's information requires particular care.
We aim to handle personal information:
- lawfully;
- fairly;
- transparently;
- only for legitimate purposes;
- in a way that is proportionate to those purposes;
- with appropriate security; and
- for no longer than reasonably necessary.
We will not sell personal information to advertisers.
3. WHO THIS POLICY APPLIES TO
This Policy may apply to:
- players;
- prospective players;
- parents and guardians;
- coaches and managers;
- Club officials;
- volunteers;
- TeamCP users;
- sponsors and sponsor contacts;
- supporters;
- customers using our shop;
- people submitting enquiries;
- people submitting safeguarding or incident information;
- website visitors; and
- other people who interact with the Club.
4. A NOTE FOR CHILDREN AND YOUNG PEOPLE
If you are a young player, your personal information belongs to you.
We may need some information about you so that the Club can safely organise football activities, keep appropriate records and celebrate football achievements.
We should not collect more information than we reasonably need.
Some football information may appear publicly on the website, for example your name, player photograph, team, position and football statistics where appropriate.
Private information such as your home address, contact details, medical information, safeguarding information and full date of birth should not be displayed publicly.
If you are unsure about how your information is being used, you can speak to a parent, guardian, Club official or the Club.
5. INFORMATION WE MAY COLLECT
Depending on how you interact with the Club, we may process the following information.
Identity information
- first name;
- surname;
- display name;
- date of birth;
- age;
- nationality; and
- photograph.
Contact information
- email address;
- telephone number;
- postal address;
- parent or guardian contact details; and
- emergency contact information where appropriate.
Football information
- team;
- position;
- squad number;
- previous club information;
- experience level;
- registration-related information;
- fixtures and match participation;
- appearances;
- starts;
- goals;
- assists;
- Player Of The Match awards;
- clean sheets;
- yellow cards;
- red cards; and
- other legitimate sporting records.
Joining enquiry information
This may include:
- player name;
- age or date of birth;
- preferred playing position;
- experience level;
- previous clubs;
- parent/guardian details; and
- information provided in the enquiry.
Volunteer information
This may include:
- name and contact details;
- preferred role;
- football or volunteering experience;
- qualifications;
- availability; and
- other information relevant to volunteering.
Shop and transaction information
When our online shop is available, this may include:
- customer name;
- email address;
- telephone number where required;
- billing information;
- delivery address;
- products ordered;
- sizes and personalisation choices;
- order value;
- transaction reference;
- delivery status; and
- refund or customer-service records.
Payment information
Where Stripe is used for our shop, payment details may be entered directly into Stripe-provided payment technology embedded within our website.
The Club does not intend to store complete payment card numbers or card security codes in its own database.
Stripe will process payment-related information in accordance with its own responsibilities and privacy information.
Website and technical information
This may include:
- IP address;
- browser type;
- device type;
- requested pages;
- security logs;
- session information;
- cookie preferences; and
- similar technical information necessary to operate or secure the website.
Safeguarding and incident information
Where somebody reports a safeguarding, welfare or other serious concern, information may include sensitive details relating to:
- a child or adult at risk;
- health or welfare;
- alleged behaviour;
- injuries;
- witnesses;
- people involved;
- actions taken;
- supporting evidence; and
- other information necessary to understand and respond to the concern.
This information is subject to stricter confidentiality and access controls.
6. HOW WE RECEIVE INFORMATION
We may receive personal information:
- directly from you;
- from a parent or guardian;
- from a player;
- from a Club manager, coach or official;
- through website forms;
- through the Club's TeamCP system;
- through match and football records;
- from leagues, governing bodies or competition organisers where appropriate;
- from another football club where appropriate;
- from payment providers; or
- from another legitimate source connected with Club activities.
7. WHY WE USE PERSONAL INFORMATION
We may use personal information to:
- administer Club teams;
- manage players and football activities;
- manage fixtures and results;
- maintain player statistics;
- communicate with parents, guardians, players and staff;
- respond to enquiries;
- consider requests to join a team;
- manage volunteers;
- manage Club staff and coaches;
- operate the website;
- publish appropriate football information;
- publish appropriate photographs and Club news;
- operate our online shop;
- process orders and refunds;
- prevent fraud and misuse;
- protect website security;
- manage sponsors;
- comply with football, legal and regulatory requirements;
- handle safeguarding and welfare matters;
- protect children and adults at risk; and
- establish, exercise or defend legal rights where necessary.
8. OUR LAWFUL BASES
We only process personal information where we have an appropriate lawful basis.
Depending on the activity, this may include:
Contract
Where processing is necessary to provide something a person has requested or to take steps before entering into an agreement.
Examples may include processing a shop order or responding to a request to purchase goods.
Legitimate Interests
We may rely on legitimate interests where processing is necessary for legitimate Club purposes and those interests are not overridden by the rights and interests of the person concerned.
Examples may include ordinary Club administration, security, maintaining appropriate football records and communicating about genuine Club activities.
Where children are involved, their interests and rights require particular weight.
Legal Obligation
We may process information where the Club must comply with a legal obligation.
Consent
We may rely on consent where a genuine choice can be provided.
Where consent is used, it can be withdrawn.
Withdrawal does not make earlier lawful processing unlawful.
Vital Interests
In rare circumstances, information may be processed where necessary to protect somebody's life or vital interests.
9. SPECIAL CATEGORY AND SAFEGUARDING INFORMATION
Some information requires additional legal protection.
This may include health information and certain other sensitive personal information.
Safeguarding reports may also contain special category information or information relating to alleged criminal conduct.
Where we process special category information, the Club must identify both:
- an appropriate UK GDPR Article 6 lawful basis; and
- an appropriate additional condition under Article 9 and, where required, the Data Protection Act 2018.
Where appropriate, the safeguarding of children and individuals at risk may form part of the applicable legal framework.
We will restrict access to safeguarding information to people who reasonably need it for legitimate safeguarding, legal or regulatory purposes.
Safeguarding information will not be made publicly available through player or team profiles.
10. PLAYER PROFILES AND PUBLIC FOOTBALL INFORMATION
The public website may display appropriate football-related information about Club players.
Depending on the player, age group and arrangements in place, this may include:
- name;
- photograph;
- team;
- position;
- squad number;
- nationality flag; and
- football statistics.
A player's full date of birth should not be displayed publicly simply because it is held in the Club database.
The website may use date-of-birth information internally to identify a player's birthday and calculate age.
Where appropriate, a birthday feature may display the player's name, photograph, team and age reached that day without publishing the full date of birth.
We will consider age, safeguarding, privacy and consent arrangements when deciding what information about children is appropriate to publish.
11. PHOTOGRAPHS AND VIDEO
Photographs and video may be used for legitimate Club purposes including:
- team profiles;
- player profiles;
- match coverage;
- Club news;
- celebrating achievements;
- community activity;
- Club promotion; and
- social media.
Where children are involved, we will seek to apply appropriate safeguarding and consent procedures.
A parent, guardian or player may raise concerns about publication by contacting the Club.
A request for removal will be considered taking account of safeguarding, legal obligations, legitimate interests and any applicable consent arrangements.
12. SHOP AND PAYMENT PROVIDERS
When our ecommerce shop is enabled, order information will be processed for purposes including:
- accepting orders;
- taking payment;
- fraud prevention;
- delivery;
- returns;
- refunds;
- customer service; and
- financial record-keeping.
Stripe may process payment and fraud-prevention information as part of providing payment services.
We may receive limited payment status and transaction information from Stripe but do not intend to store full payment card credentials ourselves.
13. WHO WE MAY SHARE INFORMATION WITH
Where necessary and lawful, personal information may be shared with:
- authorised Club officials;
- team managers and coaches;
- appropriate safeguarding personnel;
- relevant leagues or competition organisers;
- The Football Association or County FA where appropriate;
- other football organisations where necessary for legitimate football administration;
- website hosting and IT providers;
- email providers;
- payment providers such as Stripe;
- delivery or fulfilment providers;
- professional advisers;
- insurers;
- law enforcement;
- local authorities;
- regulators; or
- other organisations where disclosure is legally required or necessary to protect somebody from harm.
We do not share children's personal information simply because another organisation asks for it.
There must be a legitimate reason for disclosure.
14. INTERNATIONAL DATA TRANSFERS
Some technology providers may process information outside the United Kingdom.
Where personal information is transferred internationally, we will seek to ensure that an appropriate legal mechanism or safeguard applies where required.
Third-party providers may also have their own international data-processing arrangements, which should be described in their own privacy information.
15. HOW LONG WE KEEP INFORMATION
We do not aim to retain personal information indefinitely.
Retention depends on why the information is held.
As general guidance:
General enquiries
Normally retained only for as long as reasonably necessary to answer and manage the enquiry, together with an appropriate period for follow-up or record-keeping.
Team joining enquiries
Unsuccessful or inactive joining enquiries will normally be removed when no longer reasonably required, subject to safeguarding, dispute or legitimate record-keeping needs.
Player records
Football and registration-related records may be retained during the player's involvement and for an appropriate period afterwards for sporting history, administration, safeguarding, insurance, dispute or legal purposes.
Shop records
Order and financial records may be retained for periods required for accounting, tax, fraud-prevention, consumer-rights and legal purposes.
Safeguarding records
Safeguarding information may need to be retained for significantly longer periods where required by law, The FA/County FA guidance, insurers, statutory safeguarding arrangements or the nature of the concern.
Safeguarding records will not be deleted merely because somebody leaves the Club if there remains a legitimate or legal reason to retain them.
Where a fixed retention period is inappropriate, we use criteria such as:
- the purpose for which the information was obtained;
- the age of the person concerned;
- legal requirements;
- safeguarding requirements;
- insurance requirements;
- football governing-body requirements;
- possible legal claims; and
- whether continued retention remains necessary and proportionate.
16. SECURITY
We use reasonable technical and organisational measures designed to protect personal information against:
- unauthorised access;
- unauthorised alteration;
- loss;
- destruction;
- accidental disclosure; and
- misuse.
Measures may include:
- restricted TeamCP access;
- role-based permissions;
- password hashing;
- secure sessions;
- database access controls;
- prepared database queries;
- audit logging for authorised administrative actions;
- secure file handling;
- backup arrangements; and
- limiting sensitive information to people who need access.
No internet-connected system can be guaranteed to be completely secure.
17. CHILDREN'S PRIVACY
Children deserve particular protection when their personal information is used.
When handling children's information we aim to:
- use clear and understandable language;
- collect only information reasonably needed;
- consider the child's best interests;
- avoid unnecessary public disclosure;
- apply appropriate parent/guardian involvement;
- consider the child's own views where appropriate to age and understanding; and
- apply safeguarding protections to photographs, contact information and online communication.
Where consent is relied upon, we will consider whether the child can validly provide that consent or whether parental authorisation is required.
18. YOUR DATA PROTECTION RIGHTS
Depending on the circumstances and lawful basis, individuals may have rights including:
- the right to be informed about how information is used;
- the right to request access to personal information;
- the right to request correction of inaccurate information;
- the right to request deletion in certain circumstances;
- the right to request restriction of processing in certain circumstances;
- the right to object to certain processing;
- the right to data portability where applicable;
- rights relating to solely automated decision-making where applicable; and
- the right to withdraw consent where processing depends on consent.
RIGHT TO OBJECT
Where we rely on legitimate interests, you may have a right to object to that processing.
We will consider objections in accordance with applicable data-protection law.
To exercise a privacy right, contact:
info@lajfc.co.uk
We may need to verify identity before disclosing or changing personal information.
19. AUTOMATED DECISION-MAKING
We do not currently intend to make decisions that have legal or similarly significant effects on individuals solely through automated processing.
Website calculations such as player age, league-table display, statistics or automated birthday detection are administrative/display functions and are not intended to make significant decisions about a person's rights.
20. COOKIES AND SIMILAR TECHNOLOGIES
Our website may use cookies, browser storage and similar technologies.
Please read our separate Cookies Policy for further information.
21. DATA BREACHES
If a personal-data security incident occurs, we will assess:
- what happened;
- what information was affected;
- who may be affected;
- the potential risk;
- what containment action is required; and
- whether notification to affected people or the Information Commissioner's Office is legally required.
22. COMPLAINTS
If you have a concern about how Litherland Athletic JFC has used your personal information, please contact us first so we have an opportunity to investigate.
Email:
info@lajfc.co.uk
You also have the right to raise a concern with the UK's data protection regulator, the Information Commissioner's Office.
Information Commissioner's Office - Make a Complaint
23. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy when:
- our website changes;
- Club systems change;
- new services are introduced;
- our shop becomes operational or changes;
- our data practices change; or
- legal or regulatory requirements change.
The Last Edited date displayed with this Policy identifies the latest published revision.
Litherland Athletic JFC · Community Club. Est. 2019