Gloucester Rugby Heritage CIO Data Protection Policy

Policy last updated 24 May 2018

In carrying out our activities in preserving and recording the history of Gloucester Rugby Club we collect and store personal information relating to individuals associated with the Club, and we are therefore required to adhere to the requirements of the General Data Protection Requirement (GDPR), May 2018.

We take our responsibilities under this act seriously and we ensure that the personal information we obtain is held, used, transferred and/or otherwise processed in accordance with that Act and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communications Regulations.

1. What is personal information?
Personal information is information that can be used to identify a living person. It can include for example their name, date and place of birth, email address, postal address, telephone number, mobile telephone number, and physical injuries sustained by playing sport.

2.  What is special personal information?
This information includes: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, some biometric data, data concerning health or data concerning a person’s sex life or sexual orientation.   In the previous regulations this was referred to as “Sensitive Personal Information”.

3. What personal information do we collect?
Individual cases may include some or all of the following data:

3.1 For players and officials directly related to Gloucester Rugby
3.1.1 Name, date & place of birth, playing record, photographs.
3.1.2 We may supplement the information we hold about an individual with further information that is available through other sources e.g., published newspapers, books and magazines, websites and public records and other material in the public domain.

3.2 Anyone interviewed by members of the CIO
3.2.1 Name, address, telephone number(s) and email address.
3.2.1 Information volunteered by the interviewee during an interview.

3.3 Anyone interacting with the GR Heritage CIO via our website
3.3.1 Name and email address.

3.4 Anyone gifting or loaning memorabilia to GR Heritage CIO
3.4.1 Name, address, telephone number(s), email address.
3.4.2 The handover form for loaned items will be destroyed once the loan is completed.

3.5 Special Personal Data
3.5.1 We do not collect or hold any Special Personal Data.

4. How do we use the information?
We may collect personal information for a number of reasons, such as:
4.1   Compiling and publishing Player Profiles on our website.
4.2    Compiling and publishing Gloucester Rugby Match Programme Articles.
4.3    Preparing for an interview with an individual which we subsequently publish as an audio or video file on our website or other public media such as Youtube.
4.4    Compiling and publishing our books and videos.
4.5    Communicating with individuals interacting with our website.
4.6    Based on the total amount of information we hold, we form and publish opinions on the playing careers of individuals. These are the opinions of our members and as such will appear in the public domain. For example, we may publish something along the lines: “Mr XYZ was widely regarded as one of the best wingers who ever played for Gloucester”.    This is our opinion.

5. Information sharing and disclosure
5.1 For players and officials directly related to Gloucester Rugby
We may publish and share the following information in the public domain: an individual’s name, date and place of birth, photographs and where appropriate playing record.

5.2 General disclosure
5.2.1    We may disclose an individual’s personal information to third parties if we are required to do so through a legal obligation (for example to the police or a government body); to enable us to enforce or apply our terms and conditions or rights under an agreement; or to protect us, for example, in the case of suspected fraud or defamation.
5.2.2    Other than for the purposes of 5.2.1 above we will not share with anyone an individual’s email address, postal address, telephone number, mobile telephone number other than with their prior permission.
5.2.3    We do not share an individual’s personal information for any other purposes.

6. The accuracy of the information
We aim to ensure that all information we hold about an individual is accurate and, where necessary, kept up to date. If any of the information we hold about an individual is inaccurate and either that individual advises us or we become otherwise aware, we will ensure it is amended and updated as soon as possible.