Privacy Policy

Background

Brocton Hall Golf Club (Cannock Chase Golf Club Estates Ltd) are committed to safeguarding the privacy of our members, employees and customers; this policy sets out how we will treat your personal information. Brocton Hall Golf Club is required to process relevant personal data regarding; members, employees, volunteers, applicants, visitors, guests and customers as part of its operation and shall take all reasonable steps to do so in accordance with this Policy.

Brocton Hall Golf Club is registered with the ICO. For Brocton Hall Golf Club the Data Controller is the Club Manager who will endeavour on behalf of the club to ensure that all personal data is processed in compliance with this Policy and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) adopted 27 April 2016, application date 25 May 2018.

The club shall so far as is reasonably practicable ensure all data is:

• Fairly and lawfully processed
• Processed for a lawful purpose
• Adequate, relevant and not excessive
• Accurate and up to date
• Not kept for longer than necessary
• Processed in accordance with the data subject's rights
• Secure
• Not transferred to other countries outside of the EU

What information do we collect about you?

We will collect only the information from you required to fulfil our contractual obligations.

We may collect and process the following information:

• Personal details – name, surname and address
• Email address
• Telephone Number
• Family and associate details
• Employment and education details
• Financial details
• Membership details
• Golf Handicap

From time to time, the club may be required to process sensitive personal data. Sensitive personal data includes data relating to medical information, gender, religion, race, sexual orientation, trade union membership and criminal records and proceedings. Sensitive personal data will only be processed when one or more of these pre-conditions are met:

• The individual has consented
• The information is required by law for employment purposes
• It is for the protection of the individual or another person
• It is required to be processed by operation of law

When you become a member of Brocton Hall Golf Club we collect only the information required from you to be able to fulfil our contractual obligations, which includes being able to contact you with notices of Annual and General Meetings and with annual subscription renewal invoices, and to administer competitions at the club as set out in our Articles of Association and Rules. We will only share this data with internal and external data processors. With your permission, we may also collect further information which allows us to contact you regarding events and offers at the club.

As an employee of Brocton Hall Golf Club, we collect only the information required to fulfil the contractual relationship between the employee and the club. We will only share this data with internal and external data processors.

As a visitor or customer of Brocton Hall Golf Club we collect only the information required from you to be able to fulfil our contractual obligations, which includes being able to contact you in relation to the specific event, booking or visit. We will only share this data with internal and external data processors. With your permission, we may also collect further information which allows us to contact you regarding events and offers at the club.

How the information about you will be used

Any information which falls under the definition of personal data and is not otherwise exempt, will remain confidential and will only be disclosed to third parties with appropriate consent.

The club may share your personal data with internal and external processors for the following reasons:

• Record keeping for membership purposes
• Employment purposes
• Provision of contracted products and services

With your permission the club may process some personal data for direct marketing and fund-raising purposes, or provision of other relevant information.

Your personal information is controlled internally by the Club’s Data Controller (Club Manager), who adheres to the internal and data protection policies and procedures of Brocton Hall Golf Club.

Data Security

We do not transfer personal information to International third parties. We do not share data with third parties.

Brocton Hall Golf Club maintains adequate technical and organisational security measures to protect personal information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. Brocton Hall Golf Club and therefore all employees and members are required to respect the personal data and privacy of others and must ensure that appropriate protection and security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to all personal data.

An appropriate level of data security must be deployed for the type of data and the data processing being performed. In most cases, personal data must be stored in appropriate systems and must not be transported offsite.

Access to club management software systems require individual passcode or password protected user login and verification, all access to personal data is logged in an audit trail in the security logs.

Hard copy data is stored securely and may only be accessed by appropriate persons and for the specific tasks for which the data was collected.

Other personal data may be for publication or limited publication within the club, therefore having a lower requirement for data security.

Internal Processors

Member, employee and customer data may be processed by internal processors, who will include; staff, competition and golf handicap administrators, team captains and committee or board members involved in specific administrative tasks or roles.

Brocton Hall Golf Club must ensure that internal processors have only sufficient access to personal data in order to perform their designated role and are compliant with this policy and the relevant legislation.

External Processors

Member and customer data may be processed by our data processor Intelligentgolf Ltd. Member data may be processed by the Club Professional solely when acting in his contracted role on behalf of the club in order to administer competitions (we do not share personal data with the Professional). Employee data may be processed by our payroll processor and HMRC.

Brocton Hall Golf Club must ensure that external processors, for example, service providers, cloud services including storage, web sites etc. are compliant with this policy and the relevant legislation.

Retention of Data

The club will retain personal information for only as long as is necessary for the purposes for which it was collected, to provide membership services, contracted products and services, and to conduct our legitimate business interests or where otherwise required by law. The club may store some data such as competition results, photographs, achievements, etc. indefinitely in its archive.

CCTV

Brocton Hall Golf Club employs the use of CCTV, in line with the CCTV Code of Practice as laid down by the Information Commissioner’s Office (ICO) and is registered with the ICO.

Credit and Debit Cards

In the use of debit and credit cards, Brocton Hall Golf Club maintains its compliance with PCI DSS (Payment Card Industry Data Security Standard) on an annual basis. No credit or debit card details are stored by Brocton Hall Golf Club.

Marketing

You may have opted in for us to be able to correspond with you regarding our activities, including events and competitions, by means of post, telephone, email and SMS. We do not share your data with external marketing companies. If you have consented to this correspondence you have the right to opt out at any time.