Football Development Programme Privacy Notice

 

What is the purpose of this document?

 

We are committed to protecting the privacy and security of your personal information.  In this notice, "Wolves", "we", "us" or "our" refers to Wolverhampton Wanderers Football Club (1986) Limited (company number 01989823), whose registered address is at Molineux Stadium, Waterloo Road, Wolverhampton, WV1 4QR.  We are registered with the Information Commissioner under registration number Z530954X. This privacy notice applies to all participants / prospective participants in our Football Development programme and their parents / legal guardians. In this notice "you" refers to any individual whose personal data we hold or process. This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 and other applicable data protection laws in the UK (the "Data Protection Law").

 

Please read this notice carefully so that you are aware of and understand the ways in which we collect and use your personal data. If you are the parent / legal guardian of a participant / prospective participant, it is important that you read and understand this notice on behalf of the participant / prospective participant.

 

Should you have any queries about anything in this privacy notice, please contact our Data Protection Officer, Matt Wild, by email at DPO@wolves.co.uk, in writing to DPO, Wolverhampton Wanderers Football Club, 67 Waterloo Rd, Wolverhampton WV1 4QR or by calling 0371 222 1877.

 

We keep our privacy procedures and practices under review and may update this notice at any time, so you should check this page regularly for any updates. Changes to this privacy notice are effective when they are posted on this page. This version is dated 21^st June 2023.

 

The kind of information we hold about you

 

We will collect, store, and use the following categories of personal information about participants / prospective participants in Wolves’ Football Development programme:

·        personal details such as name, date of birth and age, gender, emergency contact information;

·        school attended;

·        preferred playing position;

·        preferred foot (for playing football);

·        technical performance data (e.g. dribbling, shooting, passing, etc);

·        attendance information;

·        behavioural information;

·        still and moving images and audio; and

·        details of incidents and/or allegations of suspected abuse of or unsuitable behaviour towards a child or adult at risk in accordance with our safeguarding policy (which can be found at https://www.wolves.co.uk/club/policies/safeguarding/).

 

We may also collect, store and use the following more sensitive types of (or special category) personal information about participants / prospective participants in Wolves’ Football Development programme:

·        information about your race or ethnicity;

·        information about any disability; and

·        health information, including (without limitation) medical conditions, doctors’ information, medication, allergies, dietary requirements.

 

We will collect, store, and use the following categories of personal information about the parents / legal guardians of participants / prospective participants in Wolves’ Football Development programme:

·        personal details such as name;

·        contact details such as address(es), telephone number(s), and personal email address(es); and

·        financial information, such as billing and banking information.

 

How is your personal information collected?

 

We typically collect personal information about you directly, including when you create (or in the case of participants / prospective participants, when your parent / legal guardian creates) an account on our app and from your Wolves single sign-on profile (in the case of parents / legal guardians).   

 

We may also collect personal information about you from Wolves employees and other personnel (including reports, assessments, opinions and assumptions made about you by our employees and other personnel) (e.g. in relation to the performance / progress of a participant at a ‘Soccer School’).

 

How we will use information about you

 

We will only use your personal data where we are permitted to do so by applicable law. Most commonly, we will use your personal data in the following circumstances:

 

·        Where we need to perform the contract we are about to enter into or have entered into with you;

·        Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/ or

·        Where we need to comply with a legal or regulatory obligation.

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the DPO if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

We may also use your personal data when you have consented to our use of your information (by providing explicit written consent).

 

Purpose/Activity	Lawful basis for processing
To enable us to properly manage and administer your registration and profile with us, including to monitor and report on your progress and to support your development	·        Necessary for our legitimate interests (to enable us to perform our obligations and provide our services to you) ·        Performance of a contract with you
For record keeping and regulatory compliance purposes and where otherwise required by law	·        Necessary for our legitimate interests (to cooperate with law enforcement and regulatory authorities) ·        Necessary to comply with a legal or regulatory obligation
To assess the quality of our services	·        Necessary for our legitimate interests (to allow us to improve our services)
To administer, deliver and support our Football Development programme	·        Necessary for our legitimate interests (to enable us to perform our obligations and provide our services to you) ·        Performance of a contract with you
To share your data (as explained in the "Data sharing" section below)	·        Necessary for our legitimate interests (to enable us to perform our obligations and provide our services to you)
To protect your interests (or someone else’s interests), including to keep you safe (such as food allergies, or emergency contact details) and to provide appropriate pastoral care	·        Necessary for our legitimate interests (by ensuring we can protect your interests, and other people’s interests) ·        Necessary to comply with a legal or regulatory obligation
To assess and monitor demographic data about users of our Football Development programme, to help us to reach more communities	·        Necessary for our legitimate interests (to allow us to improve our services) ·        Consent

 

The lawful bases we rely on in relation to our use of any "special category" data are:

·        In limited circumstances, with your explicit written consent.

·        Where we need to carry out our legal obligations.

 

Data sharing

 

We will not share your personal information with any third parties, except where strictly necessary to do so to protect your vital interests (e.g. if there is a medical emergency and we need to share your personal information with paramedics).

 

Data security

 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

 

Data retention

 

We will only keep your data for as long as necessary, including for meeting legal needs. To determine the appropriate length of time to hold your data, we consider the amount, nature, and sensitivity of it, as well as the potential risk of harm from unauthorised use or disclosure.

 

Your rights

 

You have the right to request access to the personal data we hold about you. To make a request for your personal information, please contact our Data Protection Officer (using the contact details above).

 

You also have the right to:

·        be told how your personal data is being used;

·        be provided with a copy of all personal data we hold on you;

·        correct some of the personal data we hold if it is not correct or out of date;

·        delete all of the personal data we hold on you;

·        stop us using your personal data in a certain way; and/or

·        make us send your personal data to you or another organisation.

 

Some of the rights may not always apply to the personal data we hold for you, as there are sometimes requirements and exemptions attached to such rights which mean we need to hold on to certain information. At other times, the rights may not apply at all.

 

If you have any questions about this privacy notice, please contact our Data Protection Officer (see contact details above). 

 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) with respect to data protection issues but we would prefer the opportunity to try and allay any concerns ourselves in the first instance.