1. About this Policy

1.1 This Policy is to help us deal with data protection matters internally. This should be kept with other club /
policies and a copy should be given (or made available) to all staff members, volunteers and others who come
into contact with personal data during the course of their involvement with the club / County Football
Association / football league.
1.2 The way Washington United FC (“we”, “our”, “us”) handle personal data about current, former, and on
occasion prospective players [and their parents or guardians], employees, volunteers, committee members,
other [Club/ County FA/League] members, referees, coaches, managers, contractors, third parties, suppliers,
and any other individuals that we communicate with.
1.3 In your official capacity with the FA and Leagues we participate in we may process personal data on our
behalf and we will process personal data about you. We recognise the need to treat all personal data in an
appropriate and lawful manner, in accordance with the EU General Data Protection Regulation 2016/679
(GDPR).
1.4 Correct and lawful treatment of this data will maintain confidence in the Club Washington United, and protect
the rights of players and any other individuals associated with Washington United. This Policy sets out our
data protection responsibilities and highlights the obligations of the club, which means the obligations of our
employees, committee, volunteers, members, and any other contractor or legal or natural individual or
organisation acting for or on behalf of the Club
1.5 You are obliged to comply with this policy when processing personal data on behalf of the club, and this policy
will help you to understand how to handle personal data.
1.6 The Club committee/board will be responsible for ensuring compliance with this Policy. Any questions about
this Policy or data protection concerns should be referred to the committee.
1.7 We process employee, volunteer, member, referee, coach, manager, contractor, committee, supplier and third
party personal data for administrative and Club management purposes. Our purpose for holding this personal
data is to be able to contact relevant individuals on Club business and our legal basis for processing your
personal data in this way is the contractual relationship we have with you. We will keep this data for until you
Washington United Football Club Data Protection Policy
are no longer a member with the Club unless required otherwise by law and / or regulatory requirements. If
you do not provide your personal data for this purpose, you will not be able to carry out your role or the
obligations of your contract with the club
1.8 All the key definitions under GDPR can be found here.

2. What we need from you

2.1 To assist with our compliance with GDPR we will need you to comply with the terms of this policy. We have
set out the key guidance in this section but please do read the full policy carefully.
2.2 Please help us to comply with the data protection principles (set out briefly in section 3 of this policy and in
further detail below):
2.2.1 please ensure that you only process data in accordance with our transparent processing as set out in
our Privacy notice;
2.2.2 please only process personal data for the purposes for which we have collected it (i.e. if you want to
do something different with it then please speak to the club secretary first;
2.2.3 please do not ask for further information about players and / or members and / or staff and / or
volunteers without first checking with the club secretary
2.2.4 if you are asked to correct an individual’s personal data, please make sure that you can identify that
individual and, where you have been able to identify them, make the relevant updates on our records
and systems;
2.2.5 please comply with our retention periods listed in our Privacy Notice and make sure that if you still
have information which falls outside of those dates, that you delete/destroy it securely;
2.2.6 Please treat all personal data as confidential. If it is stored in electronic format then please consider
whether the documents themselves should be password protected or whether your personal
computer is password protected and whether you can limit the number of people who have access to
the information. Please also consider the security levels of any cloud storage provider (and see
below). If it is stored in hard copy format then please make sure it is locked away safely and is not
kept in a car overnight or disposed of in a public place;

2.2.7 if you are looking at using a new electronic system for the storage of information, please talk to the
club secretary first so that we can decide whether such a system is appropriately secure and complies
with GDPR;
2.2.8 if you are planning on sharing personal data with anybody new or with a party outside the FA
structure then please speak to the club secretary first before doing so who will be able to check that
the correct contractual provisions are in place and that we have a lawful basis to share the
information;
2.2.9 if you receive a subject access request (or you think somebody is making a subject access request for
access to the information we hold on them) then please tell the club secretary as soon as possible
because we have strict timelines in which to comply;
2.2.10 if you think there has been a data breach (for example you have lost personal data or a personal
device which contains personal data or you have been informed that a coach has done so, or you
have sent an email and open copied all contacts in) then please speak to the club secretary who will
be able to help you to respond.
If you have any questions at any time then please just ask the club secretary we are here to help.

3. Data protection principles

3.1 Anyone processing personal data must comply with the enforceable principles of data protection. Personal
data must be:
3.1.1 processed lawfully, fairly and in a transparent manner;
3.1.2 collected for only specified, explicit and legitimate purposes;
3.1.3 adequate, relevant and limited to what is necessary for the purpose(s) for which it is processed;
3.1.4 accurate and, where necessary, kept up to date;
3.1.5 kept in a form which permits identification of individuals for no longer than is necessary for the
purpose(s) for which it is processed;
3.1.6 processed in a manner that ensures its security by appropriate technical and organisational measures
to protect against unauthorised or unlawful processing and against accidental loss, destruction or
damage;

3.2 We are responsible for and must be able to demonstrate compliance with the data protection principles listed
above.

4. Fair and lawful processing

This Policy aims to ensure that our data processing is done fairly and without adversely affecting the rights of
the individual.

4.1 Lawful processing means data must be processed on one of the legal bases set out in the GDPR. When
special category personal data is being processed, additional conditions must be met.

5. Processing for limited purposes

5.1 The Club collects and processes personal data. This is data we receive directly from an individual and data
we may receive from other sources.
5.2 We will only process personal data for the purposes of the club as instructed by the committee, the County
FA or The FA, or as specifically permitted by the GDPR. We will let individuals know what those purposes are
when we first collect the data or as soon as possible thereafter.
Consent
One of the lawful bases on which we may be processing data is the individual’s consent. An individual
consents to us processing their personal data if they clearly indicate specific and informed agreement, either
by a statement or positive action.
Individuals must be easily able to withdraw their consent at any time and withdrawal must be promptly
honoured.
Explicit consent is usually required for automated decision-making and for cross-border data transfers, and for
processing special category personal data. Where children are involved then the consent must be in writing
from parent/guardian
Where consent is our legal basis for processing, we will need to keep records of when and how this consent
was captured.
Our Privacy Notice sets out the lawful bases on which we process data of our players and members.

6. Notifying individuals

6.1 Where we collect personal data directly from individuals, we will inform them about:
6.1.1 the purpose(s) for which we intend to process that personal data;
6.1.2 the legal basis on which we are processing that personal data;
6.1.3 where that legal basis is a legitimate interest, what that legitimate interest is;
6.1.4 where that legal basis is statutory or contractual, any possible consequences of failing to provide that
personal data;
6.1.5 the types of third parties, if any, with which we will share that personal data, including any
international data transfers;
6.1.6 their rights as data subjects, and how they can limit our use of their personal data;
6.1.7 the period for which data will be stored and how that period is determined;
6.1.8 any automated decision-making processing of that data and whether the data may be used for any
further processing, and what that further processing is.
6.2 If we receive personal data about an individual from other sources, we will provide the above information as
soon as possible and let them know the source we received their personal data from;
6.3 We will also inform those whose personal data we process that we, the Club, are the data controller in regard
to that data, and which individual(s) in the Club are responsible for data protection.

7. Adequate, relevant and non-excessive processing

We will only collect personal data that is required for the specific purpose notified to the individual.
You may only process personal data if required to do so in your official capacity with the Club. You cannot
process personal data for any reason unrelated to your duties.
The Club must ensure that when personal data is no longer needed for specified purposes, it is deleted or
anonymised.

8. Accurate data

We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any
personal data at the point of collection and at the start of each season with team managers. We will take all
reasonable steps to destroy or amend inaccurate or out-of-date data.

9. Timely processing

We will not keep personal data longer than is necessary for the purpose(s) for which they were collected. We
will take all reasonable steps to destroy or delete data which is no longer required, as per our Privacy Notice.

10. Processing in line with data subjects’ rights

10.1 As data subjects, all individuals have the right to:
10.1.1 be informed of what personal data is being processed;
10.1.2 request access to any data held about them by a data controller;
10.1.3 object to processing of their data for direct-marketing purposes (including profiling);
10.1.4 ask to have inaccurate or incomplete data rectified;
10.1.5 be forgotten (deletion or removal of personal data);
10.1.6 restrict processing;
10.1.7 data portability; and
10.1.8 not be subject to a decision which is based on automated processing.
10.2 The Club is aware that not all individuals’ rights are absolute, and any requests regarding the above should be
immediately reported to the committee, and if applicable escalated to the [County FA/ FA] for guidance.

11. Data security

11.1 We will take appropriate security measures against unlawful or unauthorised processing of personal data, and
against the accidental loss of, or damage to, personal data.
11.2 We have proportionate procedures and technology to maintain the security of all personal data.
11.3 Personal data will only be transferred to another party to process on our behalf (a data processor) where we
have a GDPR-compliant written contract in place with that data processor.
11.4 We will maintain data security by protecting the confidentiality, integrity and availability of the personal data.
11.5 Our security procedures include:
11.5.1 Entry controls. Any stranger seen in entry-controlled areas should be reported.
11.5.2 Secure desks, cabinets and cupboards. Desks and cupboards should be locked if they hold
personal data.

11.5.3 Methods of disposal. Paper documents should be shredded. Digital storage devices should be
physically destroyed.
11.5.4 Equipment. Screens and monitors must not show personal data to passers-by, and should be locked
when unattended. Excel spreadsheets will be password protected.
11.5.5 Personal Devices. Anyone accessing or processing the Clubs personal data on their own device,
must have and operate a password only access or similar lock function, and should have appropriate
anti-virus protection. These devices must have the Club personal data removed prior to being
replaced by a new device or prior to such individual ceasing to work with or support the Club.

12. Disclosure and sharing of personal information

12.1 We share personal data with [the County FA/ and The FA, and with applicable leagues using Whole Game
System.
12.2 We may share personal data with third parties or suppliers for the services they provide, and instruct them to
process our personal data on our behalf as data processors. Where we share data with third parties, we will
ensure we have a compliant written contract in place incorporating the minimum data processer terms as set
out in the GDPR, which may be in the form of a supplier’s terms of service.
12.3 We may share personal data we hold if we are under a duty to disclose or share an individual’s personal data
in order to comply with any legal obligation, or in order to enforce or apply any contract with the individual or
other agreements; or to protect our rights, property, or safety of our employees, players, other individuals
associated with the Club or others.

13. Transferring personal data to a country outside the EEA

We may transfer any personal data we hold to a country outside the European Economic Area (EEA),
provided that one of the appropriate safeguards applies.
Reporting a personal data breach
In the case of a breach of personal data, we may need to notify the applicable regulatory body and the
individual.

If you know or suspect that a personal data breach has occurred, inform a member of the committee
immediately, who may need to escalate to the County FA/ FA as appropriate. You should preserve all
evidence relating to a potential personal data breach.

14. Dealing with subject access requests

14.1 Individuals may make a formal request for information we hold about them. Anyone who receives such a
request should forward it to the board/committee immediately, and where necessary escalated to the County
FA/ FA for guidance. Nobody should feel bullied or pressured into disclosing personal information.
14.2 When receiving telephone enquiries, we will only disclose personal data if we have checked the caller's
identity to make sure they are entitled to it.
Accountability
The Club must implement appropriate technical and organisational measures to look after personal data, and
is responsible for, and must be able to demonstrate compliance with the data protection principles.
The club must have adequate resources and controls in place to ensure and to document GDPR compliance,
such as:
Providing fair processing notice to individuals at all points of data capture;
Training committee and volunteers on the GDPR, and this Data Protection Policy; and
Reviewing the privacy measures implemented by the club.

15. Changes to this policy

We reserve the right to change this policy at any time. Where appropriate, we will notify you by email.

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