Privacy Policy

The Old Wimbledonians Association (“OWA”) are committed to respecting your privacy and protecting your personal data. We recognise that your personal data is your property and that you have loaned it to us for specific purposes.

Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.

1. This Privacy Policy

1.1 This policy explains how we collect, use, share and otherwise process your Personal Data in connection with your relationship with us as a member, associate member, supplier, or individual applying for or holding a position with us, or being generally interested in the OWA activities, services and our publications in accordance with applicable data privacy laws and the General Data Protection Regulations (GDPR) which become applicable on 25 May 2018 (Data Protection Laws).

1.2 By providing your personal data to us, and/or by visiting www.oldwimbledonians.com (the Website), you understand, accept and consent to the practices described in this policy.

1.3 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be
binding on you when you continue to use the Website or work with us after the date of the relevant change.

2. Who We Are

2.1 For the purposes of the Data Protection Laws, the data controller is the OWA. We are a limited company registered in England (02055368) and our registered office is at 143 Coombe Lane, West Wimbledon, London, SW20 0QX. We are registered with the ICO to process your personal data and our registration number is Z6092471.

2.2 Your personal data will be held and stored by us in our internal management information systems.

3. What Personal Information Do We Collect About You?

3.1 We may collect personal information, including images, from you or your child (as the playing party), in the course of your or your child’s membership or where you provide services to the OWA (and/or one of its sporting sections, Rugby Football and Cricket) or as a result of your relationship with one or more of our staff and members. For the remainder of this policy where “your personal data” is stated that will include yourchild’s personal data where relevant.

3.2 The personal information that we process includes:

  • 3.2.1 Basic information, such as your name (including name prefix or title), the name of the child or children for whom you are legally responsible (and who is/are engaged in a sporting activity at the OWA through a sporting section), or the company you work for, your title or position and your relationship to a person or member;
  • 3.2.2 Contact information, such as your postal address, email address and telephone number(s);
  • 3.2.3 Financial information, such as payment-related information;
  • 3.2.4 Technical information and communications we send to you electronically;
  • 3.2.5 Information you provide to us for the purpose of attending meetings and events;
  • 3.2.6 Identification and background information provided by you or collected as part of our membership or business acceptance processes;
  • 3.2.7 Personal information provided to us by or on behalf of our members or sporting sections (Rugby Football and Cricket) or generated by us in the course or providing services to them, which may include special categories of data; and
  • 3.2.8 Any other information relating to you which you may provide to us.

3.3 Where you are a potential employee or member of our staff, we may collect additional categories of your personal data from you for the purposes of our recruitment process.

4. How Do We Collect Your Personal Data?

4.1 The categories of data listed above are collected in the following ways:

  • 4.1.1 We collect information from you as part of our membership enrolment procedures and about you and others as necessary in the course of providing and arranging activities and related events and services.
  • 4.1.2 We gather information about you when you provide it to us, or communicate with us or our sporting sections directly.
  • 4.1.3 We may collect or receive information about you from other or publicly available sources in order to ensure that the contact details we already hold for you are
    accurate.
  • 4.1.4 Any personal data you give to us in meetings may also be retained by us.

4.2 When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings.

4.3 We also monitor email communications sent to and from us.

4.4 If you provide services to us, we will take administrative personal data (personal contact details of your personnel or representatives) to enable us to administer our relationship with you, and receive the necessary goods and services from you.

4.5 We use CCTV in the Bar and the Car Park outside the clubhouse.

5. What Do We Use Your Data For?

5.1 Your personal data primarily enables us to administer our relationship with you, and/or to supply you with the appropriate membership services, news, activities and events (social and sporting).

5.2 We also may use your personal information:

  • 5.2.1 To provide information requested by you;
  • 5.2.2 To publish, circulate or update: team sheets, match reports, honours boards in the clubhouse and inform, on a need to know basis, members’ disciplinary sanctions.
  • 5.2.3 To manage and administer our relationship with you including informing you of OWA or sports section specific news and events.
  • 5.2.4 To fulfil our legal, regulatory obligations including to comply with a sport’s governing body’s rules, health and safety regulations and establishing, exercising or defending legal claims; and
  • 5.2.5 For the purposes of recruitment.

5.3 Any technical information we collect about you when you our Website is used to enable us:

  • 5.3.1 To personalise and improve its functionality and security (to keep it safe and secure);
  • 5.3.2 To administer and monitor traffic and on our Website for analysis, research and survey purposes;
  • 5.3.3 To ensure that we can offer you the most effective and efficient browsing experience, and make improvements where necessary; and
  • 5.3.4 To improve and improve our range of member services.
  • 5.3.5 For health safety and security reasons.

5.4 We collect, create, hold and use personal information in the course of and in connection with the services we provide to our members. We will process identification and background information as part of our enrolment or membership renewal process, finance, administration and marketing procedures, including identification, anti-money laundering, conflict, source of funds and financial checks. We will also process personal information provided to us by or on behalf of our members for the purposes of the services, events and activities we supervise for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that activity (see Section 9 below).

5.5 The legal basis on which we use your information will be one or more of the following:

  • 5.5.1 To perform a contract, such as engaging with an individual to provide membership related or other services;
  • 5.5.2 For the establishment, exercise or defence of legal claims or proceedings;
  • 5.5.3 To comply with sporting governing body, legal and regulatory obligations; and
  • 5.5.4 For legitimate business purposes.

6. Retention of your personal data

6.1 Your personal data will be retained in accordance with our data retention policy which categorises all of the information held by us and specifies the appropriate retention period for each category of data. For a copy of our retention policy please address your request to the OWA secretary.

6.2 To determine the appropriate retention period for your personal data, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

6.3 We will also take into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good
practice and our business purposes.

6.4 In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

6.5 Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.

7. Your Consent

7.1 We do not ordinarily rely on your consent to process your personal data. All personal data we take is either to enable us to administer your membership or proposed arrangements with you, to inform you about the OWA, its sporting sections, matters which are relevant to social cohesion of the OWA community and/or to comply with our legal and regulatory obligations. We therefore consider that all personal data we obtain is reasonable and necessary for these purposes.

7.2 You may exercise your rights under section 10 at any time, which includes withdrawing your consent to our processing of your personal data. However, where
this withdrawal prevents us from performing our contract or providing services to you, we may not be able to provide our services to you.

8. Security

8.1 We have in place technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or
destruction consistent with applicable Data Protection Laws.

8.2 Members of sporting sections with access to your personal data have unique log-in details to access systems and have access to personal data only for the purposes of performing their roles and providing necessary advice.

9. Who Can We Share Your Personal Information With?

9.1 We may share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:

  • 9.1.1 Our professional advisers and auditors;
  • 9.1.2 Our IT service providers including our database storage providers;
  • 9.1.3 Third parties engaged in OWA events or in the course of the services we provide to members; and
  • 9.1.4 Third party search providers for identification and anti-money laundering checks.

9.2 Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.

9.3 We may use social media sites such as Facebook, LinkedIn and Twitter. If you use these services, you should review their privacy policy for more information on how they deal with your personal information.

9.4 We do not sell or otherwise make personal information commercially available to any third party.

9.5 Although unlikely, we may need to transfer your personal information to locations outside the jurisdiction in which you provide it. This may entail a transfer of your information from a location within the European Economic Area (the EEA) to outside the EEA, or from outside the EEA to a location within the EEA.

9.6 The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.

10. Your Rights

10.1 In relation to all of your personal data, you have the right (in addition to any rights you may have under Data Protection Laws) to request us:

  • 10.1.1 Not to process your personal data for marketing purposes;
  • 10.1.2 To clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
  • 10.1.3 To amend any inaccurate data we hold about you;
  • 10.1.4 To delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time); and
  • 10.1.5 To only process your personal data in limited circumstances, for limited purposes.

10.2 We must ensure your personal information is accurate and up to date. Therefore please advise us of any change to your information by emailing us.

10.3 We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way

10.4 If you wish to exercise any of your rights at any time, please contact us in the first instance at membership@oldwimbledonians.com.

10.5 We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.

10.6 We may refuse to comply with a request in such circumstances where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.

If you have any queries relating to this policy please contact us at membership@oldwimbledonians.com.

OWA Updated May 2018