We are THE SQUARE MILE GOLF SOCIETY (“THE SOCIETY”). Our website is https://squaremilegolf.co.uk
- Introduction
Under the Data Protection Act 2018 which incorporates the EU General Data Protection Regulation (“GDPR”) the Society is required to comply with GDPR and undertakes to do so.
- Definitions
Terms defined in GDPR have the same meaning in this Policy. For the avoidance of doubt :
2.1 A Data Subject is an identifiable individual person about whom the Society holds personal data and includes, inter alia, organisers, contacts, members, supporters and volunteers; and
2.2 Contact Information means and might include the full name and nicknames, postal address, landline and mobile telephone numbers, photographs, email address(es), social media IDs and/or user names.
- General GDPR Principles
The Society will ensure that all personal data that it collects, processes or holds will be :
3.1 processed lawfully, fairly and in a transparent manner ;
3.2 collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes and further processing for archiving purposes in the public interest, historical research purposes or statistical purposes is deemed to be compatible with the initial purposes;
3.3 adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ;
3.4 accurate and, where necessary, kept up to date involving the timely correction of inaccuracies ;
3.5 kept in a form which permits identification of data subjects for no longer than is necessary and stored under an appropriate technical framework to safeguard the rights and freedoms of data subjects ;
3.6 processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful access or processing as well as against accidental loss, destruction or damage, using appropriate technical or structural measures.
- Lawful Processing
The Society will obtain, hold and process all personal data in compliance with GDPR. In all cases the information collected, held and processed will include contact information (as defined in 2.2 above).
4.1 By Consent
4.1.1 People who are interested in and wish to be kept informed of the activities of the Society ;
4.1.2 Subject to consent, information selected by and forwarded to the Society on activities relevant to those of the Society by other organisations but this will not involve providing personal data to another organisation other than necessary personal data provided to a venue where a Society or golf event is to be held.
4.1.3 The information collected may additionally contain details of any particular areas of interest about which the person wishes to be kept informed.
4.2 By contract
People who sell goods and/or services to, and/or purchase goods and/or services from the Society or who make periodic or contracted donations to the Society. The information collected is likely to contains details of :
4.2.1 the nature, description and/or quantity of the goods or services bring sold to or purchased from the Society;
4.2.2 Bank and similar details necessary and relevant to the making or receiving of donations or payments for goods or services being sold to or purchased from the Society;
4.2.3 The information provided will be held and processed solely for the purpose of managing the contract between the Society and the purchaser or supplier of the goods or services.
4.3 By Legal Obligation
Where there is a legal obligation on the Society to collect, process and share information with a third party, e.g. HM Revenue and Customs. All such information will be held, processed and shared with others solely for the purpose of complying with the Society’s legal obligations.
4.4 By Vital Interest or by Public Task
The Society does not undertake any activities of vital interest nor any public task which require the collection, holding and/or processing of personal data.
4.5 By Legitimate Interest
The Society asserts that its collection, holding or processing of personal data when not falling within one of the above categories might still be lawful and within its legitimate interest and not unlawful with regard to the data subject. This may include personal data of individuals who make contact with the Society through the contact form on the website.
- Individual Rights
5.1 The right to be informed
When collecting personal data the Society will make the data subject aware of this Privacy Policy.
5.2. The right of access
The data subject has the right to obtain from the Society confirmation as to whether or not personal data of that individual are being processed and, where applicable, given access to such personal data and this Privacy Policy
5.3 The right to rectification
The data subject has the right at all times to require the Society to rectify in a timely fashion any inaccurate or incomplete personal data concerning that data subject.
5.4 The right to erase or be forgotten
Except where data are held by virtue of a legal obligation the data subject has the right to require the Society without undue delay to erase all or any personal data concerning that data subject. When making such a request the data subject needs to be conscious that complying with the request may render future relationship with the Society impractical or impossible.
5.5 The right to restrict processing
Where there is a dispute between the data subject and the Society about the accuracy, validity or legality of data held by the Society the data subject shall have the right to require the Society to cease processing the data for a reasonable period of time to allow the dispute to be resolved.
5.6 The right to data portability
The Society acknowledges the right of a data subject to portability of personal data held by the Society about that individual.
5.7 The right to object
5.7.1 The data subject has the right to object on grounds relating to the particular situation of that individual at any time to the processing of that person’s personal data whereupon the Society must cease processing the personal data unless the Charity demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
5.7.2 At the latest at the time of the first communication with the data subject originating from the Society the right referred to in paragraph 5.7.1 above shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
- Data Controller and Data Protection Officer
6.1 The Policy Team of the Society will act as the Data Controller and can be contacted at squaremilegolf@cityliveryclub.com
The data controller shall implement appropriate technical and organisational measures to ensure and be able to demonstrate that processing is performed in accordance with GDPR and this Privacy Policy. Such measures will be reviewed and updated periodically and in any event not less than once a year.
6.2 The scale and scope of the data collected and processed by the Society does not justify the appointment of a Data Protection Officer.
- Privacy Policy
The Society will always have a Privacy Policy which it will make available to everyone on whom it holds and processes personal data, and where the data are used to communicate with the data subject, at the latest, when the first communication originates from the Society.
- Miscellaneous Provisions
8.1 From time to time we may need to share personal data with the venues where events are to be held, IT consultants, web designers and possibly with professional advisers such as lawyers or accountants. The Society will not seek the permission of the data subject before sharing personal information in this way unless the data subject objects.
8.2 We may also need to share personal data with the Society’s bankers, the Police, public authorities, HM Revenue and Customs, the Courts and any other central or local government bodies, upon request, e.g. for the prevention and detection of crime as well as to comply with a Court Order.
8.3 Retention of Personal Data
Personal data held or processed by the Society are ordinarily retained for the prevailing statutory period of 6 years plus one further year.
8.4 The Society does not transfer personal data to third countries but high-end servers might be located outside the United Kingdom. The Society has no control over the latter situation.
8.5 The right to lodge a complaint with a supervisory authority.
Data subjects have the right to lodge a complaint with the Information Commissioner’s Office if the data subject is dissatisfied with the way the Society is collecting, holding, processing and/or using the personal data of that individual and the data subject feels that reasonable attempts to raise the issues and get them addressed have failed.
8.6 Information Security
The Society takes the security of your information very seriously. The Society uses every possible endeavour to have in place appropriate security measures at all times, especially where it becomes necessary to share information with others.
8.7 Updates
The Society will need to update this policy from time to time as its activities evolve and expand. The Society will post a notice on its website that a change has taken place and where the change is significant will identify the clauses which have changed.
8.8. For the avoidance of doubt information in the public domain is not personal data.
8.9 The Society does not process sensitive information.
8.10 The Society welcomes support from golfers of all ages but any individual under the age of 18 must formally identify themselves to the Data Controller.
- The Society
The Society is an initiative recognised as a panlivery initiative by the Livery Committee of the City of London and is administered by the golf section of The City Livery Club Limited, a company limited by guarantee, with registered office at Bell Wharf Lane, Upper Thames Street, London EC4R 3TB, under number 05367865.