Summary of how we and the IRFU use your data
• Cooke RFC uses your personal data to manage and administer your membership and your involvement with its teams and club, and to keep in contact with you for these purposes.
• Some data is shared with the IRFU, who use your data to regulate, develop and manage the game.
• Data is also shared with Access NI if you are a CWO, or involved with coaching youth or vulnerable adults.
• Where we or the IRFU rely on your consent, such as any consent we seek for email marketing, you can withdraw this consent at any time by contacting the Hon Secretary.
• Amongst the data we collect from you may be medical (including injury) information. We will hold this where you (or your parent) have given consent, so that we can ensure we are aware of your condition and can that you are supported appropriately.
• Where you work in a particular role within the game, you may be required to undergo a Access NI check. The result of this check will be processed by Access NI and the PSNI.
What does this policy cover?
This policy describes how Cooke RFC (also referred to as “the Club”, “we” or “us”) will make use of the data we handle in relation to our members and players, including our use of the Clubhouse system provided by the Irish Rugby Football Union (“IRFU”). The policy also describes the IRFU’s use of data on Clubhouse.
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
What information do we collect?
We collect and process personal data from you or your parent when you join and when we carry out annual renewals of your membership. This includes:
• your name
• your gender,
• your date of birth,
• your IRFU Pin (as assigned in Clubhouse)
• your home address, email address and phone number;
• your type of membership and involvement in particular teams, or any key role you may have been allocated, such as Coach, CWO, Hon Secretary etc.;
• your payment and/or bank account details, where you provide these to pay for membership;
• your marketing preferences, including any consents you have given us;
• your medical conditions or disability, where you provide this to us with your consent (or your parent’s consent) to ensure we are aware of any support we may need to provide to you.
What information do we receive from third parties?
Sometimes, we receive information about you from third parties. For example, if you are a child, we may be given information about you by your parents.
We may receive information relating to your existing registrations with other clubs or rugby bodies or disciplinary history from the IRFU Ulster Branch through Clubhouse. Additionally, for certain role holders or those working with children, we may receive information from Access NI and IRFU on the status of any Access NI check you have been required to take.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
• To fulfil a contract, or take steps linked to a contract: this is relevant where you make a payment for your membership and any merchandise, or enter a competition. This includes:
o taking payments;
o communicating with you;
o providing and arranging the delivery or other provision of products, prizes or services;
• As required by the Club to conduct our business and pursue our legitimate interests, in particular:
o we will use your information to manage and administer your membership and your involvement with its teams and club, and to keep in contact with you for these purposes;
o we will also use data to maintain records of our performances and history, including match reports, score lines and team sheets;
o [we use CCTV cameras to maintain the security of our premises, and may use this video to investigate incidents at the Club or its premises] o we may choose to send you information by post or by phone, or by email about club activities or events
• Where you give us consent:
o we will send you direct marketing or promotional material by email;
o we may handle medical or disability information you or your parent provides to us, to ensure we support you appropriately;
o on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
• For purposes which are required by law:
o we maintain records such as health and safety records and accounting records in order to meet specific legal requirements;
o we ensure, where you will work with children, that you have undergone an appropriate Access NI check – this is also carried out with your consent.
o where you hold a role at the Club requiring us to check your right to work, we may process information to meet our statutory duties;
o we may respond to requests by government or law enforcement authorities conducting an investigation.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing at any time. You can do this by contacting the Hon Secretary.
Who will we share this data with, where and when?
Some limited information may be shared with other stakeholders in rugby, such as other clubs, Constituent Bodies, referee societies, league organisers, so that they can maintain appropriate records and assist us in organising matches and administering the game.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our or the IRFU’s legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on our behalf for the purposes identified above. Such third parties include the IRFU as the provider of Clubhouse and providers of the Club Website.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
You have the same rights for data held by the IRFU for its own purposes on Clubhouse.
To exercise any of these rights, you can get in touch with us– or, as appropriate, the IRFU or its data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to the Information Commissioner’s Office.
Much of the information listed above must be provided on a mandatory basis so that we can make the appropriate legal checks and register you as required by IRFU Rules and Regulations. We will inform you which information is mandatory when it is collected. Some information is optional, particularly information such as your medical information. If this is not provided, we may not be able to provide you with appropriate assistance, services or support.
How do I get in touch with you or the IRFU?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org or by writing to Hon Secretary, Cooke RFC, Shaw’s Bridge Sports Association, 123 Milltown Road, Belfast, BT8 4XP
If you have any concerns about how the IRFU process your data, you can get in touch by writing to The Data Protection Officer, Irish Rugby Football Union of 10/12 Lansdowne Road, Dublin 4, Ireland.
How long will you retain my data?
We process the majority of your data for as long as you are an active member and for 1 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data unless you ask us to stop, when we will only process the data for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data in connection with performing a contract or for a competition, we keep the data for 5 years from your last interaction with us.
We will retain information held to maintain statutory records in line with appropriate statutory requirements or guidance.
The IRFU will maintain records of individuals who have registered on Clubhouse, records of Access NI checks and the resulting outcomes and other disciplinary matters for such period as is set out in the IRFU’s privacy notice to be set out on www.irishrugby.ie/legal.php
Records of your involvement in a particular match, on team sheets, on results pages or in match reports may be held indefinitely both by us and the IRFU in order to maintain a record of the game.