Subject Access Request
1. BACKGROUND & APPLICATION
The Albion Foundation (“TAF”) and its subsidiary group companies (“we/us/our”) are committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the Data Protection Act (the “DPA”) and from 25th May 2018, the General Data Protection Regulation (“GDPR”).
We are both a "data controller" (this means that we are responsible for deciding how we hold and use personal information about you) and “data processor” (this means that we are responsible for processing data on behalf of data controllers, such as schools and colleges). We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is very important that you read this privacy notice, together with our data protection policy, so that you are aware of how and why we are using such information.
2. DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the information we hold about you must be:
(a) Used lawfully, fairly and in a transparent way.
(b) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
(c) Relevant to the purposes we have told you about and limited only to those purposes.
(d) Accurate and kept up to date.
(e) Kept only as long as necessary for the purposes we have told you about.
(f) Kept securely.
3. WHAT DATA WILL WE HOLD ABOUT YOU?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are "special categories" of more sensitive personal data which require a higher level of protection.
We may collect, store, and use the following categories of personal information about you:
(a) Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
(b) Date of birth;
(d) Marital status and dependants;
(e) Next of kin and emergency contact information;
We may also collect, store and use the following "special categories" of more sensitive personal information:
(a) Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
(b) Information about your health, including any medical condition, health and sickness records;
4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We may collect and process personal and sensitive data from electronic booking forms on our website. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may, for example, keep a record of your name, address, and email address, date of birth and telephone number.
We will take details of the purchases and other transactions you carry out through our website and of the fulfilment of your booking. We may also ask you for information when you enter a competition or promotion sponsored by us or if you contact us by telephone, email or otherwise in writing, we may keep a record of that correspondence.
5. HOW WILL WE USE INFORMATION ABOUT YOU?
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
(a) Where we need to perform the contract we have entered into with you.
(b) Where we need to comply with a legal obligation.
(c) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
(a) Where we need to protect your interests (or someone else's interests).
(b) Where it is needed in the public interest or for official purposes.
6. WHAT ARE THE SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION?
It is your choice to ‘opt in’ to allow us to contact you with information about goods and services which may be of interest to you, but you will be clearly notified this through our booking or registration process. Personal information will also be shared with West Bromwich Albion Football and stored on a shared database (between TAF and WBA FC).
If you choose not to ‘opt-in’ then your personal data will not be stored on the shared database and you will not be contacted with any information relating to either TAF or WBA FC.
We may also share your personal data with funders (such as the Premier League) as part of the requirements for certain funded projects/events.
We will use your financial information to enable payment authorisation and billing including any online or telephone purchases. When you purchase any products from us, your consent is given to provide your financial information and personal information to those third parties necessary to process your transactions with us, such as credit card companies, banks and companies that handle delivery and shipping on our behalf. This includes exchanging information with other companies and organisations for fraud protection and credit risk protection. We will not share your financial information with third parties without your consent for any other reason.
All financial information you provide to us is stored on our secure servers. Payment transactions and payment card data will be processed and stored in compliance with the Payment Card Industry Data Security Standard (PCI DSS). PCI DSS represents a common set of data security measures to help ensure the safe handling of sensitive information on a global basis.
7. CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. HOW WE WILL USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We are required by law to have appropriate safeguards in place when processing such data.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
9. DATA SECURITY
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
10. HOW LONG WILL YOU USE MY INFORMATION FOR?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
11. YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your working relationship with us.
12. YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION
Under certain circumstances, by law you have the right to:
(a) Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
(b) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
(c) Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
(d) Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes;
(e) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; and
(f) Request the transfer of your personal information to another party
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact TAF’s Head of Operations in writing.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
13. WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
14. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact TAF’s Head of Operations. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
15. DATA PRIVACY MANAGER
TAF’s Head of Operations is in charge of overseeing compliance with this staff privacy notice. If you have any questions about this staff privacy notice or how we handle your personal information, please contact TAF’s Head of Operations. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
16. CHANGES TO THIS STAFF PRIVACY NOTICE
We reserve the right to update this staff privacy notice at any time, and we will provide you with a new staff privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this staff privacy notice, please contact Marc Brady (Head of Operations) at email@example.com.