Privacy Notice : Bromborough Golf Club in the Wirral

Bromborough Golf Club Privacy Notice

This Privacy Notice explains what we do with your personal information. This includes what you tell us about yourself, what we learn by having you as a visitor, customer, member, guest, employee, contractor, supplier of services and so forth, and the choices you make about the marketing you ask us to send to you. It also explains how we do this, how the law protects you and outlines your privacy rights. This notice is part of our suite of privacy notices; detailed notices are made available as appropriate. We update this notice regularly in accordance with changes in privacy law and when our activities or practices change (updated May 2018).

Who We are

Bromborough Golf Club is an unincorporated organisation. The General Manager is the Data Controller. Certain employed members of staff and their team(s) such as the Professional, House Manager and Office/admin may be data processors as part of their role. For the avoidance of doubt, any volunteer is not automatically deemed a Data Processor, except in circumstances such as the Chief Golf Officer (and team) regarding the administration of handicaps/competition data and the Chief Membership Officer regarding joiners/leavers, health related matters and any disciplinary process or such like.

Questions, Concerns & Rights

In the first instance, questions about how we collect, store and use personal data or concerns about how it is managed should be directed to the General Manager, who is also our Data Protection Manager.Contact the General Manager to:

Update or rectify inaccurate/incomplete personal data
Change your marketing & contact preferences
Object to us using your personal data
There may be legal or other official reasons why we need to keep or use your data but tell us if you think that we should not be using it.
You would like us to transfer a copy of your data to another company.
We are working with our software providers to ensure personal data you give under contract can be made portable.

If your initial contact at the club cannot resolve the issue or you require a copy of your personal data please contact the Data Protection Manager:

phone: 01513342155
email: gm@bromboroughgolfclub.org.uk
letter: Data Protection Manager, Bromborough Golf Club, Raby Hall Road, Bromborough, Cheshire CH630NW

If we are still not able to resolve the matter you have the right to lodge a complaint with the Information Commissioner’s Office: https://ico.org.uk/ - they will always direct you to us in the first instance.

Types of Personal Information and where we collect it from

We use different kinds of personal information, here are examples of how we group them together.

Type of personal information	Description
Contact	Where you live & how to contact you.
Transactional	Details about payments to your account with us.
Financial	Financial position, status & history.
Communications	What we learn about you from letters, emails, conversations between us and social media posts.
Contractual	Details about products or services we provide to you or are provided to us.
Usage Data	Data about how you use our products and services.
Socio-demongraphic	Details about your work or profession, nationality & education.
Documentary data	Details about you that are stored in documents in different formats, or copies of them. This could be things like your passport,drivers license or birth certificate.
Social Relationships	Your family, friends & other relationships (an example of when we collect this data is when we ask you for next of kin information).
Open Data and Public Records	Details about you that are in public records, such as the Electoral Register, and information about you that is openly available on the internet.
Locational, Behavioural & Technical	The address where you connect a computer to the internet; details about how you use our products and services; details on the devices and technology you use.
Consents	Your marketing preferences and the ways in which you are happy for us to contact you. If you have agreed that we can contact you for marketing purposes we may send you emails and other communications relating to products and services which we think will be of interest and relevance to you as an individual. We do this by monitoring the browsing and online shopping habits of customers and providing them with information on products they have viewed and related products.

Examples of where we collect your data from
From you	When you use our services	From third parties
When you apply to be a tenant, golf club member, annual pass holder etc. When you talk to use on the phone or in our business offices. In correspondences. In insurance claims or other documents. In financial reviews and interviews In tenant surveys If you take part in our events. When you ask us to send you marketing communications. In social media posts	Payment & transaction data. When you use our websites or portals (eg. tenants). Profile and usage data, including the profile you create to identify yourself when you connect to our internet, mobile and telephone services & data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phone, using cookies and other internet tracking software.	Agents working on our behalf including property professionals our properties. such as estate agents, chartered surveyors,planning consultants, land agents, building contractors, solicitors, managing agents for our properties. Utilities companies. Credit reference agencies. Debt collection agencies Insurers. Local authorities. Solicitors working on your behalf to extend leasehold tenures. Public information. sources such as Companies House.

Why we collect personal data

As well as our internal policies and procedures, your privacy is protected by law. We are permitted only to use personal information if we have an acceptable reason to do so. This includes sharing it outside of Bromborough Golf Club.
Below is a summary of the potential reasons we collect personal data, of course, it is much more complicated and further information is available to you in our specific Privacy Notices. We only keep the minimum amount of personal data and regularly dispose of data not required. We also take steps to anonymise data.

Examples of our legitimate interests:
Complying with regulations that apply to us.
Being efficient about how we fulfil our legal and contractual duties.
Managing our facilities.
Making decisions about continued memberships and tenancies, arranging termination and exercising our rights set out in agreements or contracts and dealing with complaints.
Efficient and proper estate and business management, planning, communications, keeping records up to date, benchmarking, accounting and auditing.
Responding to communications sent to us, incl. social media posts; informing you of important changes to our business or policies; reviewing and improving the performance of our systems, processes & employees (including training).
Obtaining legal advice.
To monitor and protect people and property.
Effective resource management.
Delivering staff benefits.
Notify/invite our community to events.
To determine whether you can provide goods or services to Bromborough Golf Club and participate in hosted events, and to enable the same.
Administering competition entries.
To support the local community.

Collection & Use of Personal Data

We only use your data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. Your personal data may be used without your knowledge or consent, where this is allowable by law.

Archiving

Bromborough Golf Club has a rich archival heritage. For future research purposes which are in the public interest we store a limited amount of personal details permanently but please bear in mind that these records remain confidential for a period of 100 years. Here are some examples of what we keep forever.

Publicity and Print: your image, if you have agreed to appear in print.
Golf Club Membership: your name, dates of membership and reason for resignation.
Tenants: your name & length of agreement.
Employees: letters of thanks; gift presentation information.

In all other circumstances, we will not keep your personal data for any longer than is necessary in light of the reason for which it was first collected. Your personal data will therefore be kept for the following periods, unless you have requested a longer period:

Financial record – seven years.
Website enquiries – two years.
Email enquiries – two years.
Job applications – one year.
CCTV and audio recordings – 30 days.
All other personal data – A maximum of one year.

Sharing your Personal Data

Type	Who we share your personal information with	What you need to know
Within Bromborough Golf Club	We share your information with our employees where this is necessary, such as for internal administration purposes such as bar card ‘top up’ and for the purposes of estate management and governance	Your information will only be shared with such employees as reasonably necessary for these purposes.
With third parties	On our behalf We have a number of trusted partners with whom we share data to deliver our services & undertake services on our behalf. The following are examples of some activities carried out by third-party service providers: Property Lettings & Security Providing professional advice & support regarding estate management Undertaking compliance requirements Research for the purpose of planning applications Collection of debt (debt and tracing agencies) Hosting & facilitating the hosting of events. Undertaking satisfaction surveys Webhosting & delivery of marketing If you have a debit, credit or card charge with is, we will share transaction details with companies which help us to provide this service Payroll services	Providers of Live Assurance, PMI, Childcare vouchers, pensions, disclosure and barring service IT service providers for the purposes of operating our business, data maintenance & support services, site security Where we contract a company to undertake a task for us they are referred to as a third party and we have a contract with them with regards to how your personal data will be handled and to treat it in accordance with the law.
Obligation	We will share your personal information with third parties where we have a statutory obligation, for example: HMRC, regulators and other authorities Tenancy Deposit Scheme If you use direct debits, we will share your data with the Direct Debit Scheme If you make an insurance claim, information you give to us or the insurer may be put on a register of claims. This will be shared with other insurers.
At your request	To companies with whom you have asked us to share your data	This may include banks, mortgage lenders and prospective employers
Exceptional Circumstances	Where we assess the disclosure is: Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings and fraud prevention Necessary to protect the safety of our employer, employees, yourself, our property or the public Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction	Occasionally we disclose personal data to authorities such as the police and emergency services where it is needed in relation to legal claims or to protect your interests, or someone else’s, or where you are not capable of giving your consent or where you have already made the information public. If we do, we ensure we are proportionate in the amount of data disclosed an appropriate procedures are in place.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Website & Cookies

The consent of a parent or guardian is required for children under the age of 13 who wish to use the limited online services available to them.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why. We have tried to cover all cookies in the table that we or our technology partners use. Please be aware that there may sometimes be a delay in updating this list. If you do notice any discrepancies, please be sure to let us know.

How to control and delete cookies

Bromborough Golf Club will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by our website, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how. How to block or delete cookies, please visit; aboutcookies.org. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual. Please be aware that restricting cookies may impact on the functionality of the Bromborough Golf Club website.

Third Party Cookies

Bromborough Golf Club also use a number of suppliers who also set cookies on our website on its behalf in order to deliver the services that they are providing. If you would like more information about the cookies used by these suppliers, as well as information on how to opt-out, please see their individual privacy policies listed below.

Name	Purpose
Google Analytics _utma _utmb _utmc _utmz	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
ASP.NET_Sessionid	The ASP Session Cookie may be set as part of your online experience if using a site login to enable us to identify you. It only exists for the duration of the browsing session and is deleted afterwards.
notification	A cookie which simply remembers which site notication(s) have been shown to you.
Google/Google Maps/Google +1 NID PREF HSID APISID SID	These cookies are use by Google to store preferences relating to the use of Google maps, these are necessary for the functionality of the site.
_hjincludedinSample _hjUserid _hjMinimizedPolls	Hotjar helps us see which parts of our websites help users the most, and allow us to create more content like this to make your experience better.

Data Security

Special category data handling
Certain data requires special handling because if it disclosed accidently it could have a harmful effect on you. This includes sensitive data (race & ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health, sex life or sexual orientation), criminal data and children’s data. As such, we will only use this data with your consent unless it is in your vital interests (threat to your life), it is in our legitimate interests, where there is a legal obligation or a contractual commitment.

Some examples of where we use special category data:

Food requirements for catering (potential health data)
Medical information required for tournament participation hosted The Golf Club
To support your recovery at work after an absence (health data)
Race/ethnic origin (equal opportunities monitoring)
DBI checks (criminal checks)
Procedures are in place to handle this data appropriately.

Security of all Data

We use Internet standard encryption technology ("SSL" or "Secure Socket Layer" technology) to encode personal data that you send to us when placing an enquiry through the Website. To check that you are in a secure area of the Website before sending personal data to us, please check that your browser displays an image of a closed padlock or an unbroken key.
However, please note that whilst we take appropriate technical and organisational measures to safeguard the personal data that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal data that you transfer over the Internet to us.
We will take all steps reasonably necessary to ensure that all personal information is treated securely and in accordance with this notice. All information you provide to us is stored securely, including in a physically secure environment, on our secure servers. Access to your personal information will be restricted to such staff and other individuals as are necessary for the purposes for which the information was collected. Our staff are trained. All data is stored in the UK but should any data be transferred outside the EEA appropriate protections are in place.

Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on our website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our website following the alterations. We recommend you check this page regularly to keep up to date.