Hamro Foundation Essex League - Data Policy

Data Policy

SNEL Data Protection Policy
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Definitions
League means The Shepherd Neame Essex League
GDPR means the General Data Protection Regulation.
Responsible Person means Andrew Kennedy
Register of Systems means a register of all systems or contexts in which personal data is processed by the League.

1. Data protection principles
The League is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions
a. This policy applies to all personal data processed by the League.

b. The Responsible Person shall take responsibility for the League’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. The League shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the League shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the League shall be dealt with in a timely manner.

4. Lawful purposes
a. All data processed by the League must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
b. The League shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the League’s systems.

5. Data minimisation
a. The League shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

6. Accuracy
a. The League shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.


7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the League shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security
a. The League shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the League shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
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Last updated June 2018

Privacy Policy

PRIVACY NOTICE

Since your club is a member of the league and you are a key contact for that club or a league official you are essentially authorising us to hold some personal details (this is termed legitimate interest) and below is what we hold for you in this regard, how we use it and what we will contact you about via our email database.

All of your contact information is displayed on our league website – www.essexcricket.com – and is in the public domain.

League official – We hold your full name, email address and telephone numbers. We will use this information to contact you regarding league cricket matters.

League panel umpire – We hold your full name, email address and telephone numbers. We will use this information to share with clubs and contact you regarding league cricket umpiring matters.

Captain – We hold your full name, email address and telephone numbers. We will use this information to share with clubs and contact you regarding league cricket playing matters.

League delegate / secretary / chairman – We hold your full name, email address and telephone numbers. We will use this information to share with clubs and contact you regarding league cricket matters.

Play cricket admin – We hold your full name, email address and telephone numbers. We will use this information to share with clubs and contact you regarding league play cricket and scoring matters

Treasurer – We hold your full name, email address and telephone numbers. We will use this information to contact you regarding league cricket financial matters.

Bar manager – We hold your full name, email address and telephone numbers. We will provide this information to our league sponsor who may contact you regarding stocking of your bar with their products.

Welfare officer – We hold your full name, email address and telephone numbers. We will use this information to contact you regarding league cricket welfare matters.

Fixture Secretary - We hold your full name, email address and telephone numbers. We will use this information to share with clubs and contact you regarding league cricket fixture and ground matters.

The league uses the ECB play cricket website to administer the results, fixtures and statistics for the league. Your personal details (including full name, email, telephone numbers, address, postcode and date of birth) are entered by your club administrator. These details are visible to all league play cricket admins for the purposes of running the league and approving registrations.

Any member of the league contact database can request at any time all data that we hold on them.

As a league we will always advise members of our database of any possible data breaches.

If anyone has any questions or concerns related to GDPR please do not hesitate to contact me.

Cliff Greenhill – Secretary of SNEL