General Data Protection Regulation BCG Policy

September 2022

Data protection

Awareness

We will make sure that decision makers and key people in our organisation are aware of the requirements of GDPR.

Information we hold;

We will annually audit information we hold and access.

We require email, telephone and address information for all our Clubs and County Officers, participants and players.

Our business requires this information to enable our business to operate.

We will seek authority from all concerned to maintain this information.

Access to databases is limited to; County Secretary, Competitions Mgr, Junior Mgr.

Information in limited form may be passed as relevant to team managers.

Individuals’ rights

We will remove information from our database of any person who requests.

Communicating privacy information

The prime means of communication will be email using the IG system.

Our policy will be to BCC group mailings and we will state in each communication.

Lawful basis for processing personal data

We will not process personal data and the basis for maintaining personal data will be limited to our constitutional activity in organising and promoting golf activity.

Subject access requests

Any request must be made in writing to the County Secretary and will be acted upon with 14 days.

Consent

From May 2018 all future competition entry forms that request participants and organisers personal contact and or email information will require a positive opt-in.

All County Officers, Managers and volunteers will be annually reviewed and will require a formal positive opt-in.

All County players under the age of 18 will require parental consent documented annually.

Data breaches

The County utilises IG systems to maintain Handicap and Player information which is limited to golfing activity.

Children

The Junior Manager will obtain parental or guardian consent for Junior players included within County squads.

Data Protection by Design and Data Protection Impact Assessments

Data Protection Officers; We are advised that DPO is not required for the small scale data we maintain.

22 Golf Clubs,
Circa 80 Squad players
30 Officers, Managers and Past Presidents

International

We do not operate Internationally