GDPR – NON-MEMBER DATA PRIVACY POLICY

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your visit to us. This notice applies to you if you have registered on our website to receive communication, visited the Club as a green fee or society member, visited our Club as a guest of a Member. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.

References to we, our or us in this privacy notice are to Burnham on Crouch Golf Club.

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Club Manager and Club Administrator have overall responsibility for data protection compliance in our organisation.  Contact details are set out in the "Contacting us" section at the end of this privacy notice.

What information we collect and why.

Depending on the type of membership you register for with us, you may initially provide us with or we may obtain personal information about you. The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose	Personal Information Used	Lawful Basis
To arrange and manage any contracts for the provision of any services or products	Contact details, transaction and payment information. Records of your interactions with us.	This is necessary to enable us to properly administer and perform any contract for the provision of any services and products you have purchased from us.
To send you information regarding your booking.	Contact details.	This is necessary to enable us to properly manage and administer your event or booking with us.
To send you other marketing information we think you might find useful or which you have requested from us, including our newsletters, information about membership, events, products and information	Contact details and marketing preferences.	Where you have given us your explicit consent to do so.
To answer your queries or complaints	Contact details and records of your interactions with us	We have a legitimate interest to provide complaint handling services to you in case there are any issues with your booking.
Retention of records	All the personal information we collect	We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your membership and run our club and in some cases we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to below
To conduct data analytics studies to better understand event attendance and trends within the sport	Records of your attendance at any events or competitions hosted by us.	We have a legitimate interest in doing so to ensure that our events are targeted and relevant.
For the purposes of promoting the club, our events and membership packages.	Images in video and/or photographic form.	Where you have given us your explicit consent to do so.
To comply with health and safety requirements	Records of attendance, CCTV footage.	We have a legal obligation and a legitimate interest to provide you and members of our organisation with a safe environment in which to participate in sport.
To administer your attendance at any courses or programmes you sign up to.	All contact and membership details, transaction and payment data. Details of any county membership and performance data.	This is necessary to enable us to register you on to and properly manage and administer your attendance on the course and/or programme.
Managing the operations of the Club.	Records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us.	Performing the Club’s contract with the visitor or guest. For the purposes of our legitimate interests in operating the Club.

For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you do not provide us with the requested personal information we may not be able to admit you as a member or we may not be able to properly perform our contract with you or comply with legal obligations and we may have to terminate your membership.  For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contacting us" section below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place.

Special Categories of Personal Information

We may also collect, store and use the “special categories” of more sensitive personal information regarding you:

• information about your health, including any medical condition, health and sickness records, medical records and health professional information; this would be in an emergency only.

We may not collect the above types of special category personal information about you. In relation to the special category personal data that we do process we do so on the basis that

• the processing is necessary for reasons of substantial public interest, on a lawful basis;
• it is necessary for the establishment, exercise or defence of legal claims;
• it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
• based on your explicit consent.

Where We Collect Your Information

We typically collect personal information about our visitors and guests when you make a booking at the club, when you purchase any services or products we offer, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.

Direct Marketing

We may contact you by email or post with information about products and services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages by emailing office@burnhamgolfclub.co.uk. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.

How we protect your personal data

We will not transfer your personal data outside the EU without your consent.

We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

Disclosure of Your Personal Information

We share personal information with the following parties:

• Any party approved by you.
• To any governing bodies or regional bodies relating to Golf: to allow them to properly administer the sport on a local, regional and national level.
• Other service providers: We may pass your personal data to third parties who are service providers to us for the purposes of completing tasks and providing services to you on your behalf (i.e to carry out surveys. We do this for the purpose of our legitimate interests in operating the Club and for performing our contract with you. However, we disclose only the personal data that is necessary for the third party to deliver the service.
• The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

Who else has access to the information you provide us?

We will never sell your personal data. We will not share your personal data with any third parties without your prior consent which you are free to withhold) except where required to do so by law or as set out in the table above.

How long will we keep your information?

We will hold your personal data on our systems for four year after your visit to the Club or for as long afterward as it is in the Club’s legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligation e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.

We will securely destroy all financial information once we have used it and no longer need it.

 

Your Rights

You have rights under the GDPR:

a) To access your personal data

b) To be provided with information about how your personal data is processed

c) To have your personal data corrected

d) To have your personal data erased in certain circumstances

e) To object to or restrict how your personal data is processed.

f) To have your personal data transferred to yourself or to another business in certain circumstance.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example, we do not use automated decision making in relation to your personal data.  However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

Changes To This Notice

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

Contacting Us

In the event of any query or complaint in connection with the information we hold about you, please email office@burnhamgolfclub.co.uk or write to us at Burnham on Crouch Golf Club, Ferry Road, Creeksea, Burnham on Crouch, Essex, CM0 8PQ

For more details, please address any questions, comments and requests regarding our data processing practices to our Club Administrator at office@burnhamgolfclub.co.uk