Data Privacy Statement

This statement explains how Tunbridge Wells Rugby Football Club (TWRFC) handles and uses the personal details which it collects about its Members, Registered Players, Former Members, Vice Presidents, Staff, Individual Associates and Corporate Associates of TWRFC in any capacity (hereinafter collectively called Members).

Retention of this information regarding Members enables TWRFC to keep in touch with them in order to keep them advised of TWRFC activities, and to enable TWRFC to discharge its responsibilities and to pursue its legitimate interests as a Rugby Union Football sports club.

Some data may be shared with the Rugby Football Union (RFU), and our Country Governing Body Kent Country Rugby Football Union (KCRFU) which may use such data to regulate, develop and manage the game of Rugby Union Football (the Game). Further details of the use of data by RFU and KCRFU can be found in their respective privacy statements.

TWRFC is committed to protecting all personal information and being open about the nature of the information which it holds. In the event that TWRFC rely upon an individual’s consent for holding such data, such consent may be withdrawn at any time.

The extent of this Policy:

This policy describes how TWRFC will make use of the data which it handles in pursuit of its legitimate interests, including its use of the Game Management System (GMS) provided by RFU, and also describes the RFU’s use of data on GMS.

This policy also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

Personal Data Collected and Held:

The personal information held by TWRFC will primarily be that provided by Members and players (or, in the case of minors, by their parents) in correspondence from Members by post, telephone, email or otherwise. On occasion, details regarding Members and players may be received from rugby clubs within the County of Kent or RFU. The records may contain:

  • Contact details as supplied and periodically updated by Members and players.
  • The name, gender, and date of birth of individuals.
  • An individual’s RFU ID (as assigned in GMS).
  • Passport and/or NI details.
  • Club affiliations and details of membership, offices, and positions held within the Game.
  • Bank account details when provided for payment of membership or other fees or to enable TWRFC to make payments.
  • Personal data supplied by Members and players for specific purposes (e.g. injuries, medical conditions and disability requirements).
  • Any qualifications or work experience supplied by an individual.

Some information will be generated as part of an individual’s involvement with TWRFC, KCRFU including development, training, performance, involvement in particular matches, details of disciplinary issues, and health and safety records.

Information received from third parties:

TWRFC may receive information from third parties, e.g. information regarding a minor supplied by parents.

TWRFC may also receive information from RFU and/or KCRFU relating to:

  • Existing registrations with other clubs or rugby bodies (and individual data collected as a result of prior registration).
  • Data generated through participating in activities conducted by the RFU or its Consituent Bodies (for example training course attendance or qualifications).
  • Disciplinary history from RFU through GMS.
  • Especially in the case of those working with children, information from the Disclosure and Barring Service and RFU.

Use of Personal Data by TWRFC:

Members’ Personal Data is used by TWRFC for:

  • Sending to Members details of its activities, news and other information, and inviting them to attend events.
  • Coordinating and administering the rugby and club activities of TWRFC senior and youth teams.
  • Collecting subscriptions and other payments which may be due.
  • TWRFC may occasionally provide Members with information from, or regarding, our sponsors which we believe is relevant to and/or may interest our Members.  We will not send direct marketing, or use the data we hold to be used for the purpose of sending direct marketing.
  • Discharging its responsibilities as a member club of the RFU and KCRFU.
  • Internal record-keeping.
  • Administrative purposes.
  • Purposes required by law, e.g. maintenance of accounting and health an safety records, compliance with the requirements of government and law enforcement authorities.

Management of Data:

TWRFC manage Member’s data within GMS; Members have access to view and update the majority of their own data via GMS (https://gms.rfu.com/GMS).  Access controls within GMS are set such that individuals have the least access practical (as configurable within GMS secuirty model) to permit the effective and efficient exection of their responsibilities.

A limited number of paper artefacts are also collected (e.g. player registration forms).  These are held securely by the Team Manager for the team/age-group concerned.

Individual teams/age-groups may use other communication and collaboration services as are convenient for communication within their group. Participation in such communication services is at each member’s discretion and is further subject to the privacy statement of the relevant service:

Sharing of Data:

TWRFC may share some limited information with other stakeholders in the Game, such as other Constituent Bodies, clubs, schools, academies, recognised development organisations with whom TWRFC deals for legitimate purposes, referee societies, league organisers, in order that they may maintain appropriate records, and assist in organising matches, administering the Game and developing players. Personal data may be shared with government authorities and/or law enforcement agencies if mandated by law, or if required for the legal protection of the legitimate interests of TWRFC, KCRFU and RFU in compliance with applicable laws. Personal data may also be shared with third-party service providers who will process it on behalf of TWRFC.

The RFU provides GMS (and therefore has access to all Member data held by TWRFC). The RFU makes its own use of the following information as described within the RFU privacy statement: http://www.englandrugby.com/privacy ; KCRFU use the data as described within the KCRFU privacy statement: http://www.kent-rugby.org/wp-content/uploads/2018/04/Data-Protection-Policy-2.pdf.

TWRFC will not sell or share your data with any other organisations, except as described in the paragraphs above.

Members’ and players’ Rights:

Members and players have the right to:

  • Ask TWRFC, KCRFU or RFU for access to, or rectification or erasure of, their individual data Provided that TWRFC, KCRFU and RFU will not delete information which it is required to keep by law, or to comply with RFU Rules and Regulations.
  • Restrict the data provided, subject to the proviso above.
  • Object to the receipt of communications by any specific method.
  • Request the transfer of their individual data to a third party.
  • Members have the right to lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/concerns/

Retention of Data:

Members’ personal data will be processed for as long as they retain their membership or active involvement with TWRFC and for up to six years thereafter. TWRFC will retain information to maintain statutory records in line with appropriate statutory requirements or guidance. The RFU will maintain records of individuals registered on GMS, records of DBS checks, and the resulting outcomes and other disciplinary matters for such period as is set out in the RFU’s privacy notice on www.englandrugby.com Records of an individual’s involvement in a particular match, on team sheets, on results pages or in match reports may be held indefinitely by TWRFC, KCRFU and RFU in order to maintain a record of the game.

Further Information:

The legal basis for processing your personal data for the purposes set out above is that it is necessary for the pursuit of TWRFC’s legitimate interests. TWRFC always handles personal data securely and minimises its use, and there is no overriding prejudice to Members and players by using their personal information for these purposes. However, there is no statutory or contractual requirement for Members and players to provide TWRFC with any personal data.

Those who have concerns or questions about the information contained in this statement, or who do not want TWRFC to process their personal data for specific purposes, should contact the TWRFC data@twrfc.com

Where Members or players have specific requests relating to the management of their personal data, TWRFC will endeavour to resolve these but there may be circumstances where it is unable to comply with a specific request.