WHAT DOES THIS POLICY COVER?
This policy describes how The Football Association Limited (“The FA”) will make use of your data when collected and processed on this website for England Football Participation Programmes.
WHAT INFORMATION DO WE COLLECT?
We may collect, use, and store different kinds of personal data about you when you register as a provider, or sign up to attend an event. This will typically be provided directly by you and may include information you provide on registration but may also involve data you have provided to The FA previously attached to your FAN.
Depending on your role and relationship with us, the personal data we may collect and/or process may include:
Identity Data such as your first and last name, FAN number, age, date of birth and gender.
Contact Data such as your email address, address, postcode and telephone number(s).
Profile Data such as your username and password.
Football Data such as your kit size.
Safeguarding Data such as your DBS status and suspension status.
Medical Data such as allergy information and accessibility information.
Finance Data such as your bank details.
Technical Data such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and information about how you use our website, products and services.
What information is provided by third parties?
Sometimes, we receive information about you from third parties. For example, where you are a player, your coach may submit information about you in relation to your booking or attendance.
We may also obtain information about you from third party service providers, such as analytics platforms that measure advertising, viewership and engagement, which we may use to help us better understand our users and send them appropriate information.
HOW DO WE USE YOUR PERSONAL DATA?
We will only use your personal data to the extent which is permitted by law. The table below shows some examples of how might use your personal data, and how we have a lawful basis for those uses:
- Administer and facilitate organising, booking, delivery, attendance and participation at England Football Participation Programmes sessions (Necessary to fulfil the contract entered into with us)
- Facilitating payments of your booking (Necessary to fulfil the contract entered into with us)
- To check your DBS and suspension status to ensure you are eligible to run these activities (Necessary for our legitimate interest to carry out our role as a governing body, discharge our safeguarding duties and protect individuals from harm)
- To send you marketing about goods and services you may be interested in (Consent)
- To investigate any wrongdoing, carry out our disciplinary role in enforcing The FA’s rules and regulations (Necessary for our legitimate interest to carry out our role as a governing body, protect individuals from harm)
- To process feedback and improve our services (Legitimate interest to develop and improve our services)
- Communicate with you about completing survey’s (Necessary for our legitimate interest to study how you use our service, to develop our service and this pilot programme)
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent.
You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
What cookies and/or tracking technologies does The FA use?
When you visit this website, we may also collect, process and use information about you and your use of the website, and how you arrived at this site. Such information may be collected through "traffic data" and may entail the use of "cookies" or other tracking technologies, IP addresses or other numeric codes used to identify your computer.
HOW DO WE SHARE YOUR INFORMATION?
Personal data will be shared directly by you with Stripe, a payment provider, for the purposes set out above, and with ClubSpark, for the purposes of setting up your account, checking your eligibility to run a course and running the website.
Personal data may also 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 legitimate interests in compliance with applicable laws.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
WHAT ABOUT INTERNATIONAL DATA TRANSFERS?
We may use third party providers to deliver our services, such as externally hosted software or cloud providers, and those providers may involve transfers of personal data outside of the UK. Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards. This may include specific contracts approved for use in the UK which give personal data the same protection it has in the UK or other equivalent measures as required.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
HOW LONG DO WE RETAIN YOUR DATA FOR?
If you have submitted a booking to take part in a recreational football session through an England Football Participation Programmes or you are a session organiser, we keep the data for 5 years from your last interaction with us or from when any relevant contract ends in relation to such recreational football session.
WHAT RIGHTS DO YOU HAVE IN RELATION TO YOUR PERSONAL DATA?
Under certain circumstances, you may have the following rights in relation to your personal data:
- A right to access personal data held by us about you (commonly known as a "data subject access request"). You can access the personal data we hold about you on The England Football Community by following the guidance here.
- A right to require us to rectify any inaccurate personal data held by us about you, though we may need to verify the accuracy of the new data you provide to us.
- A right to require us to erase personal data held by us about you where there is no good reason for us continuing to process it. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You can exercise this right by following the guidance here.
- A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims or due to having overriding legitimate grounds to use it.
- A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation.
- A right to object to our processing of personal data held by us about you where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- A right to withdraw your consent, where we are relying on it to use your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
- A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.
HOW CAN YOU CONTACT US?
If you have any questions about this policy or any other data protection queries you can contact The FA’s Data Protection Team using email@example.com or by writing to Data Protection Officer, Wembley Stadium, PO Box 1966, London, SW1P 9EQ. If you wish to make a data privacy request, you can do so via our online form, which can be found here.
You also have the right to lodge a formal complaint with the UK Information Commissioner's Office. Full details may be accessed on the complaints section of the ICO's website. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.