KENT FA PRIVACY POLICY

Kent County Football Association Limited ("we", "our", "us") takes your privacy very seriously.

This Privacy Notice sets out how we use and look after the personal information we collect from you. As the organisation that is responsible for, and controls the processing of your personal data, we are the data controller, and sometimes also the data processor, and will take reasonable care to keep your information secure and to prevent any unauthorised access or use of it. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

We may update this Privacy Notice from time to time and will inform you of any changes in how we handle your personal data as soon as reasonably practicable.

It is important that you read and retain this Privacy Notice, together with any other Privacy Notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data Protection Principles 

We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
 
Information We May Collect From You
 
Personal data means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer personal data of our participants, their parents or guardians, and other members. The data we collect from participants may include:

- Name, date of birth and gender; and
- Contact information, such as home address, email address, qualifications, parent/carer contact details and telephone numbers.
- Role in football, for example, player, volunteer, coach, match official etc.

Certain types of more sensitive personal data require a higher level of protection, such as information about a person's health, race, region or beliefs, disability or sexual orientation (“special category data”). We may collect and store some special category data for the purposes of the health, well-being, welfare, and safeguarding of our participants and members. Where we hold this data, it will be with the explicit consent of the participant or, if applicable, the participant’s parent or guardian. 

Where we need to collect personal data to fulfil our responsibilities and a participant fails to provide that data, we may not be able honour or administer their participation in football. 
 
How Is Your Personal Data Collected?
 
A participant may give us their personal data by filling in forms (online and paper-based) or by corresponding with us by post, phone, email, in person, via our website or otherwise. This includes the information being provided by a participant or a participant’s club by inputting participant details into The FA’s Whole Game System, The FA’s Competition Portal, The FA’s Player Registration, The FA’s Club Portal and The FA’s Full Time.

At the Kent FA, we may also use one or more of the following third-party platforms to collect information from people so they can provide feedback and opinions via a survey, attend an event, workshop, or course, subscribe to a newsletter, or enter a prize draw or competition. The platforms that we, as a County FA use are:

- Fanbase (www.fanbaseclub.com)– typically so people can attend a County Cup Final, Kent FA coaches' course or CPD course.

- Smartsheet (www.smartsheet.com) – forms and registrations for events.

- Survey Monkey (https://uk.surveymonkey.com) – to seek the opinions of our Kent football community (coaches, match officials, volunteers, players, parents and carers) through surveys.

- JotForm (www.jotform.com)—details so members can enter competitions and prize draws, apply for funding applications, upload videos and photos for the Kent Football Show or similar campaign, enrol in events and activities, and provide feedback via forms and surveys.

- Microsoft Forms – as above re JotForm excluding video and photo uploads.

- MailChimp (www.mailchimp.com)– email addresses so members can receive regular Kent football newsletters (legitimate interest) and marketing emails from Kent FA-approved suppliers and partners (opted-in email address only). 

- Disclosure & Barring Service (www.fadv.onlinedisclosures.co.uk) - this allows the County FA to fulfil its safeguarding duty to check that those in a position of trust in grassroots football (coach, manager, volunteer, match official, etc) are appropriate to safeguard vulnerable adults and children by eliminating potential risks in the applicant process.  
 
How The FA And Kent FA Uses Personal Data
 
We will use personal information only for the purposes for which we have been provided with such information. We need participants’ and members’ personal data for the following reasons:
 
- to manage the County FA.
- to administer leagues.
- to support football clubs. 
- to administer memberships.
- to deal with sanctions. 
- to ensure safeguarding compliance.
- to support and develop referees.
- to administer courses, workshops and events
- to provide updates about Kent football to our members.

Our lawful basis for processing personal data is that we have a contractual obligation to individuals as participants or members to provide the services of a County Football Association.

 

Below, we have a description of all the ways we plan to use your data and the legal bases on which we rely. We have also identified our legitimate interests where appropriate.

 

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis for doing so.

Please note that we may process your personal information without your knowledge or consent in compliance with the relevant laws where this is required or permitted by law.

 

To keep Kent football stakeholders up to date on various opportunities, including competitions, prize draws, discounts and special offers from Kent FA Partners, stakeholders can opt-in via a Microsoft form to receive the marketing newsletters (sent quarterly via MailChimp) or through their FA Player Registration profile under communication preferences. 

This includes The FA and Kent FA Partners, as shown on the www.KentFA.com website, who occasionally would like us to share their marketing information by e-mail or SMS. We will only do this if you have consented to using your data in this way. 

Individuals can opt out of receiving direct marketing communications by pressing “Unsubscribe” at the bottom of the Mailchimp newsletter, updating their communications references within Player Registration or by emailing Preferences@KentFA.com

 

 

Please see above for the process by which personal data is collected. Once collected, we will only share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so (e.g., it is necessary to protect the rights, property, or safety of our participants, members or affiliates, or others). We pass information to the FA for affiliation and other reporting purposes. 

We may share your data with our affiliates to fulfil a purpose (for example, sending email databases to Mailchimp in order to send a newsletter). We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third parties to process your personal data for specified purposes, i.e., to execute our newsletters in accordance with our instructions.

We will share the referee’s information with local Referee Associations.

We will never share your personal details with partners, suppliers or commercial third parties unless for the reasons already explained above. 

Some of our suppliers or third parties, such as our website and email providers, may process our personal data outside the European Economic Area (EEA). We review the data protection terms of these suppliers to ensure that your personal data will only be transferred out of the EEA if sufficient appropriate safeguards are in place.

 

We are committed to protecting your privacy and have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. Details of these measures are available upon request. Third parties will only process your personal information according to our instructions and where they have agreed to treat the information confidentially and keep it secure.

However, the nature of the Internet means that data may, in some circumstances, flow over networks without full security measures and could be accessible to unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. We keep personal data on our participants, members, and other website users while they are signed up to the County FA or any of our website services. We will delete this data 24 months after an individual has ended their membership or affiliation, or sooner if specifically requested and we are able to do so. 

We use FA sites to store personal data, and the FA processes this data for as long as the individual is an active user of the sites and for five seasons after this. The data will then be held as inactive for a further 3 months before being deleted. For further information on the FA sites, please see the FA’s Privacy Notice at http://www.thefa.com/public/privacy  

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). 

Where we process personal data in connection with performing a contract or for a competition, we keep the data for seven years from your last interaction with us or from when the contract ends. 

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

 

When you visit our website, we may collect, process and use information about you which may not personally identify you, but which may be helpful for improving the operation of the website. Such information may be collected through "traffic data" and may entail the use of "cookies", "IP Addresses" or other numeric codes used to identify your computer. You can delete cookies or configure your computer to reject them, although this may disable the website’s ability to manage individual sessions.

 

 

This website may contain links to other sites. Please be aware that we are not responsible for the privacy practices of these sites. We encourage our users to be aware when they leave this website and to read the privacy statements applicable to those sites. This privacy policy does not apply to information collected on third parties’ sites.

 

 

All data subjects have the right to:

1. Request access to your personal data.
2. Request rectification of any of your personal data that is inaccurate or incomplete.
3. Request erasure of your personal data where there is no good reason for us continuing to process it. 
4. Object to processing of your personal data for direct marketing, or where we are processing on the grounds of a legitimate interest and that interest is overridden by your rights and freedoms.
5. Request restriction of processing of your personal data while we establish the data's accuracy, verify an overriding interest to object to processing, where our use of the data has been unlawful but you do not want us to erase it or where you need us to hold the data to establish, exercise or defend legal claims. 
6. Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. 
7. Withdraw consent at any time where we are relying on consent to process your personal data. 
8. Complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. 
 
Where you seek to assert any of your rights listed above, we will endeavour to respond to you without undue delay and in any event ordinarily within one month of receipt of the request. This period may be extended by two further months where necessary, considering the complexity and number of the requests. In this scenario, we will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

We will communicate any rectification, erasure, or restriction of processing of your personal data to each recipient to whom it has been disclosed unless this proves impossible or involves disproportionate effort.

 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.