Privacy Policy

Introduction

The Trust is a registered charity (1126600) that is organised around our 4 main themes; Sport, Education, Inclusion and Health. Throughout all these we have one clear message;

To inspire all participants to achieve their goals by delivering a quality innovative programmes through the power of football and sport.

The Trust collects and processes personal information, or personal data, relating to its participants/students. This personal information may be held by the Trust on paper or in electronic format.

The Trust is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information both during and after your relationship with the Trust ends. We are required under the GDPR to notify you of the information contained in this privacy notice and take the processing of your personal data very seriously. This privacy notice applies to all current participants/students and former participants/students. Information about the Trust is also available on Carlisle United Football Club website, to view their policy on how they use your data when using the website go to: www.carlisleunited.co.uk/privacypolicy.

The Trust has appointed a data protection manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or about how we handle your personal information, please contact John Halpin details can be found at the end of the policy.

Data protection principles

Under the GDPR, there are six data protection principles that the Trust must comply with. These provide that the personal information we hold about you must be:

Processed lawfully, fairly and in a transparent manner.
Collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
Adequate, relevant and limited to what is necessary in relation to those purposes.
Accurate and, where necessary, kept up to date.
Kept in a form which permits your identification for no longer than is necessary for those purposes.
Processed in a way that ensures appropriate security of the data.

The Trust is responsible for, and must be able to demonstrate compliance with, these principles. This is called accountability.

What types of personal information do we collect about you?

Personal information is any information about an individual from which that person can be directly or indirectly identified. It doesn’t include anonymised data, i.e. where all identifying particulars have been removed. There are also “special categories” of personal information, and personal information on criminal convictions and offences, which requires a higher level of protection because it is of a more sensitive nature. The special categories of personal information comprise information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.

The Trust is involved in a variety of projects, not limited to NCS, Walking Football, Mental Health Football, children’s weekly football sessions, Holiday Soccer Schools, Football Development Scholarship, USW degree, Wildcats and work in schools (NCC, After School Clubs, Girls and Premier League Primary Stars) and this policy covers all projects including any new projects between the date of this policy and it being reviewed. The Trust collects, uses and processes a range of personal information about you. This includes (as applicable):

your contact details, including your name, address, telephone number and personal e-mail address (1, 2, 3 & 4)
emergency contact details (1, 2 & 3)
parent/guardian contact details (1, 2 & 3)
your date of birth (1 & 4)
gender (1, 2 & 4)
attendance (2 & 3)
photograph and/or videos (1)
bank details (2 & 4)
students academic, disciplinary and attendance records (2 & 3)
CCTV images (4)

The Trust may also collect, use and process the following special categories of your personal information (as applicable):

information about health, including any medical condition, whether you have a disability in respect of which the Trust needs to make reasonable adjustments (S1 & S2)
information about race or ethnic origin, nationality or religious beliefs (S2)
information about criminal convictions and offences as per DBS checks for students doing work experience (S1 & S2)

How do we collect your personal information?

The Trust may collect personal information about participants/students (both adult and children) in a variety of ways. It is normally collected during the registration process, either directly from the participants/students or the participants/students parent/guardian. We also collect information about you when you enquire about using any of our services. We may also collect personal information from other external third parties including but not limited to, Carlisle United Football Club, partner schools, funders and criminal record checks from the Disclosure and Barring Service (DBS).

Your personal information may be stored in different places, including in locked cabinets in a secure office or secure password protected files and in other IT systems, such as the e-mail system and other password protected systems including Salesforce, Substance Views, Mail Chimp and Text Marketer.

Why and how do we use your personal information?

We will only use your personal information when the law allows us to. These are known as the legal bases for processing. We will use your personal information in one or more of the following circumstances:

where we have the consent of a data subject or parent/guardian consent (1)
we need to do so to perform the contract for services we have entered into with you (2)
where we need to comply with a legal obligation (3)
where it is necessary for our legitimate interests (or those of a third party), and your interests or your fundamental rights and freedoms do not override our interests (4).

We may also occasionally use your personal information where we need to protect your vital interests (or someone else’s vital interests).

We need all the types of personal information listed under “What types of personal information do we collect about you?” primarily to enable us to perform our contract with you (2) and to enable us to comply with our legal obligations (3). In some cases, we may also use your personal information where it is necessary to pursue our legitimate interests (or those of a third party), provided that your interests or your fundamental rights and freedoms do not override our interests (4). Our legitimate interests include: Meeting the aims and objectives of the Trust and the surrounding community covering the 4 main themes; Sport, Education, Inclusion and Health by inspiring all participants to achieve their goals by delivering a quality innovative programmes through the power of football and sport. Some examples of this would be direct marketing, data analysis, improving the services we provide, monitoring the services we provide and reporting on the progression of our projects. We have indicated, by using (1), (2), (3) or (4) next to each type of personal information listed above, what lawful basis we are relying on to process that particular type of personal information.

The purposes for which we are processing, or will process, your personal information are to:

respond to any enquiry you make,
send information to you for any activities/projects or competitions you enrol in,
fulfil any contract for provision of services to you,
fulfil statutory or regulatory record keeping requirements,
send you marketing information that may be of interest to you in the format you have consented to,
be able to provide education programmes and deliver projects/activities,
monitor and evaluate our work in the community and its impact,
monitor and evaluate our targets as required for any funding or grants received,
provide the best possible experience and care for anyone taking part in our activities,
support student/participant learning and assessments,
monitor and report on student/participant progress,
make use of photograph’s/video’s of students/participants for both educational and marketing purposes,
ensure premise security by the use of CCTV in accordance with Carlisle United Football Clubs CCTV policy,
issue invoices or receipts of payment,
use where reasonably necessary for the school’s purposes,
ensure adherence to Trust rules, policies and procedures
to prepare case studies/testimonials of our work.

Please note that we may process your personal information without your consent, in compliance with these rules, where this is required or permitted by law.

What if you fail to provide personal information?

If you fail to provide certain personal information when requested or required, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory or contractual rights.

Why and how do we use your sensitive personal information?

We will only collect and use your sensitive personal information, which includes special categories of personal information and information about criminal convictions and offences, when the law additionally allows us to or to protect the vital interests of participants (S1).

We may also process these special categories of personal information, and information about any criminal convictions and offences, where we have your explicit written consent. In this case, we will first provide you with full details of the personal information we would like and the reason we need it, so that you can properly consider whether you wish to consent or not. It is entirely your choice whether to consent. Your consent can be withdrawn at any time (S2).

The purposes for which we are processing, or will process, these special categories of your personal information, and information about any criminal convictions and offences, are to:

comply with regulatory requirements and obligations, e.g. carrying out criminal record checks for the USW Degree Students work experience (S1 & S2)
ensure the health and safety and take appropriate care/precautions of all participants/students (S1)
ensure adherence to Trust rules, policies and procedures (S1 & S2)

Where the Trust processes other special categories of personal information, i.e. information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation, this is done only for the purpose of equal opportunities monitoring and in line with our data protection policy. Personal information that the Trust uses for these purposes is either anonymised or is collected with your explicit written consent, which can be withdrawn at any time. It is entirely your choice whether to provide such personal information.

We may also occasionally use your special categories of personal information, and information about any criminal convictions and offences, where it is needed for the establishment, exercise or defence of legal claims.

Change of purpose

We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain the legal basis which allows us to process your personal information for the new purpose and we will provide you with any relevant further information. We may also issue a new privacy notice to you.

Who has access to your personal information?

Your personal information may be shared internally within the Trust, including with members of staff leading a project, other project staff, administration staff, the Trust Manager and IT staff if access to your personal information is necessary for the performance of their roles.

The Trust may also share your personal information with third-parties or individuals including when we use data processers (and their designated agents), including:

external funders and partners not limited to, Premier League, EFL Trust, LFE, NCS Trust/Inspira, University of South Wales, Children in Need, Cumberland FA, NHS and any future funding/project partners
MailChimp – E-mail Marketing
Text Marketer – Text Marketing
Fluxx
Salesforce
Substance Views
Paypal
Manor Adventure and University of Cumbria (NCS only)
Carlisle United FC
Schools
IT support
Accountancy software - Xero
External auditors
Professional advisers, such as lawyers and accountants

We may also need to share your personal information with a statutory body or regulator or to otherwise comply with the law.

We may share your personal information with third parties where we have obtained your consent, where it is necessary to administer the contract we have entered into with you, where we need to comply with a legal obligation, or where it is necessary for our legitimate interests (or those of a third party).

We would never sell your personal information to any other organisations.

How does the Trust protect your personal information?

The Trust has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities. You can obtain further information about these measures from our data compliance manager.

Where your personal information is shared with third-party service providers, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.

The Trust also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.

For how long does the Trust keep your personal information?

The Trust will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, tax, health and safety, reporting or accounting requirements.

We regularly review what information we hold and delete what is no longer required.

Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.

In some circumstances we may anonymise your personal information so that it no longer permits your identification. In this case, we may retain such information for a longer period.

Your rights in connection with your personal information

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes, e.g. your contact information so that our records can be updated. The Trust cannot be held responsible for any errors in your personal information in this regard unless you have notified the Trust of the relevant change.

As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:

request access to your personal information - this is usually known as making a data subject access request and it enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
request rectification of your personal information - this enables you to have any inaccurate or incomplete personal information we hold about you corrected
request the erasure of your personal information - this enables you to ask us to delete or remove your personal information where there’s no compelling reason for its continued processing, e.g. it’s no longer necessary in relation to the purpose for which it was originally collected
restrict the processing of your personal information - this enables you to ask us to suspend the processing of your personal information, e.g. if you contest its accuracy and so want us to verify its accuracy
object to the processing of your personal information - this enables you to ask us to stop processing your personal information where we are relying on the legitimate interests of the business as our legal basis for processing and there is something relating to your particular situation which makes you decide to object to processing on this ground
data portability - this gives you the right to request the transfer of your personal information to another party so that you can reuse it across different services for your own purposes.

If you wish to exercise any of these rights, please contact our data protection manager. We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our data compliance manager. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.

If you believe that the Trust has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at any time. The ICO is the UK supervisory authority for data protection issues. The ICO is the UK supervisory authority for data protection issues. Our ICO Registration number is Z2844277.

Information Commissioner's Office

Wycliffe House

Water Lane Telephone: 0303 123 1113 or 01625 545 745

Wilmslow www.ico.org.uk

Cheshire

SK9 5AF

Transferring personal information outside the European Economic Area

The Trust may transfer your personal information to countries outside the European Economic Area (EEA). Currently this is to United States of America for the Mail Chimp Marketing Service. There is an adequacy decision by the European Commission in respect of that country. This means that the country to which we transfer your personal information is deemed to provide an adequate level of protection for your personal information. However, to ensure that your personal information does receive an adequate level of protection, it is transferred outside the EEA on the basis of the following safeguard: certification under an approved certification mechanism as provided for in the GDPR. You can obtain further information about these measures from our data protection manager.

Automated decision making

Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you based solely on automated decision making, including profiling. However, we will notify you in writing if this position changes.

Changes to this privacy notice

The Trust reserves the right to update or amend this privacy notice at any time, including where the Trust intends to further process your personal information for a purpose other than that for which the personal information was collected or where we intend to process new types of personal information. We will issue a new privacy notice when we make significant updates or amendments. We may also notify you about the processing of your personal information in other ways.

Contact

If you have any questions about this privacy notice or how we handle your personal information, please contact our data protection manager John Halpin, Carlisle United FC Community Sports Trust, Brunton Park, Warwick Road, Carlisle, CA1 1LL, telephone 01228 554 169 or email [email protected].