Policies


Data policy
Spurley Hey GDPR Policy
April 2020
1
Spurley Hey F.C.
GDPR Policy
April 2020
Spurley Hey F.C. GDPR Policy
April 2020
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1. About this Policy
1.1 This Policy is to help clubs, County Football Associations and football leagues deal with data
protection matters internally. This should be kept with other club / County Football Association /
football league policies and a copy should be given (or made available) to all volunteers and others
who come into contact with personal data during the course of their involvement with the club.
1.2 The Club, Spurley Hey FC (“we”, “our”, “us”) handles personal data about current, former, and
on occasion prospective players [and their parents or guardians], volunteers and committee
members.
1.3 In your official capacity with the club you may process personal data on our behalf and we will
process personal data about you. We recognise the need to treat all personal data in an
appropriate and lawful manner, in accordance with the EU General Data Protection Regulation
2016/679 (GDPR).
1.4 Correct and lawful treatment of this data will maintain confidence in the club, and protect the
rights of players and any other individuals associated with the club. This Policy sets out our data
protection responsibilities and highlights the obligations of the club, which meansthe obligations
of our committee, volunteers, members, and any other contractor or legal or natural individual
or organisation acting for or on behalf of the club.
1.5 You (members and volunteers who come into contact with personal data) are obliged to comply
with this policy when processing personal data on behalf of the Club and this policy will help you
to understand how to handle personal data.
1.6 The Club Executive Committee will be responsible for ensuring compliance with this Policy. Any
questions about this Policy or data protection concerns should be referred to the committee.
1.7 We process volunteer, member, referee, coach, manager, contractor, committee, supplier and
third party personal data for administrative and Club management purposes. Our purpose for
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holding this personal data is to be able to contact relevant individuals on Club business and our
legal basis for processing your personal data in this way is the contractual relationship we have
with you. We may keep this data for 2 months after the end of the football season in which your
official relationship with the Club ends unless required otherwise by law and / or regulatory
requirements. If you do not provide your personal data for this purpose, you will not be able to
carry out your role or the obligations of your contract with the Club.
1.8 All the key definitions under GDPR can be found here.
2. What we need from you
2.1 To assist with our compliance with GDPR we will need you to comply with the terms of this policy.
We have set out the key guidance in this section but please read the full policy carefully.
2.2 Please help us to comply with the data protection principles (set out briefly in section 3 of this
policy and in further detail below):
2.2.1 please ensure that you only process data in accordance with our transparent processing as set
out in our Privacy notice;
2.2.2 please only process personal data for the purposes for which we have collected it (i.e. club related
activities);
2.2.3 please do not ask for further information about players, members or volunteers without first
checking with a member of the Club’s Executive committee;
2.2.4 if you are asked to correct an individual’s personal data, please make sure that you can identify
that individual and, where you have been able to identify them, make the relevant updates on
your records and systems and ask the member to update their records online;
2.2.5 please comply with our retention periods listed in our Privacy Notice and make sure that if you
still have information which falls outside of those dates, that you delete/destroy it securely
(paper data must be shredded, and online data deleted from any hard drives);
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2.2.6 please treat all personal data as confidential. If data is stored in electronic format then please
ensure that the documents themselves are password protected and that you limit the people
who have access to the information to those who need it to fulfil their role within the Club. Please
also consider the security levels of any cloud storage provider (and see below). If it is stored in
hard copy format then please make sure it is locked away safely and is not kept in a car overnight
or disposed of in a public place;
2.2.7 if you are looking at using a new electronic system for the storage of information, please talk to
a member of the Club’s Executive committee first so that we can decide whether such a system
is appropriately secure and complies with GDPR;
2.2.8 do not share personal data with anybody new or with a party outside the Club.
2.2.9 if you receive a subject access request (or you think somebody is making a subject access request
for access to the information we hold on them) then please tell a member of the Club’s Executive
committee as soon as possible because we have strict timelines in which to comply;
2.2.10 if you think there has been a data breach (for example you have lost personal data or a personal
device which contains personal data or you have been informed that a coach has done so, or you
have sent an email and open copied all contacts in) then please speak to a member of the Club’s
Executive committee who will be able to help you to respond.
3. Data protection principles
3.1 Anyone processing personal data must comply with the enforceable principles of data protection.
Personal data must be:
3.1.1 processed lawfully, fairly and in a transparent manner;
3.1.2 collected for only specified, explicit and legitimate purposes;
3.1.3 adequate, relevant and limited to what is necessary for the purpose(s) for which it is processed;
3.1.4 accurate and, where necessary, kept up to date;
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3.1.5 kept in a form which permits identification of individuals for no longer than is necessary for the
purpose(s) for which it is processed;
3.1.6 processed in a manner that ensures its security by appropriate technical and organisational
measures to protect against unauthorised or unlawful processing and against accidental loss,
destruction or damage;
3.2 We are responsible for, and must be able to demonstrate compliance with, the data protection
principles listed above.
4. Fair and lawful processing
4.1 This Policy aims to ensure that our data processing is done fairly and without adversely affecting
the rights of the individual.
4.2 Lawful processing means data must be processed on one of the legal bases set out in the GDPR.
When special category personal data is being processed, additional conditions must be met.
5. Processing for limited purposes
5.1 The Club collects and processes personal data. This is data we receive directly from an individual
and data we may receive from other sources.
5.2 We will only process personal data for the purposes of the Club as instructed by the committee,
the County FA or The FA, or as specifically permitted by the GDPR, and as documented in the
Club’s Privacy Policy.
6. Consent
6.1 One of the lawful bases on which we may be processing data is the individual’s consent.
6.2 An individual consents to us processing their personal data when they complete the online
registration form.
6.3 Individuals must be easily able to withdraw their consent at any time and withdrawal must be
promptly honoured. Consents will be refreshed every season.
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6.4 Explicit consent is usually required for automated decision-making and for cross-border data
transfers, and for processing special category personal data. Where children are involved then
the consent must be in writing from parent/guardian
6.5 Where consent is our legal basis for processing, we will need to keep records of when and how
this consent was captured.
6.6 Our Privacy Notice sets out the lawful bases on which we process data of our players and
members.
7. Notifying individuals
7.1 Where we collect personal data directly from individuals, we will inform them in the Privacy
Notice about:
7.1.1 the purpose(s) for which we intend to process that personal data;
7.1.2 the legal/lawful basis on which we are processing that personal data;
7.1.3 where that legal/lawful basis is a legitimate interest, what that legitimate interest is;
7.1.4 where that legal/lawful basis is statutory or contractual, any possible consequences of failing to
provide that personal data;
7.1.5 the types of third parties, if any, with which we will share that personal data, including any
international data transfers;
7.1.6 their rights as data subjects, and how they can limit our use of their personal data;
7.1.7 the period for which data will be stored and how that period is determined;
7.1.8 any automated decision-making processing of that data and whether the data may be used for
any further processing, and what that further processing is.
7.2 If we receive personal data about an individual from other sources, we will provide the above
information as soon as possible and let them know the source we received their personal data
from;
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7.3 We will also inform those whose personal data we process that we, the Club are the data
controller in regard to that data, and which individual(s) in the Club are responsible for data
protection.
8. Adequate, relevant and non-excessive processing
8.1 We will only collect personal data that is required for the specific purpose notified to the
individual.
8.2 You may only process personal data if required to do so in your official capacity with the Club.
You cannot process personal data for any reason unrelated to your duties.
8.3 The Club must ensure that when personal data is no longer needed for specified purposes, it is
deleted or anonymised.
9. Accurate data
We will ensure that personal data we hold is accurate and kept up to date. We will check the
accuracy of any personal data at the point of collection and at the start of each season. We will
take all reasonable steps to destroy or amend inaccurate or out-of-date data.
10. Timely processing
We will not keep personal data longer than is necessary for the purpose(s) for which they were
collected. We will take all reasonable steps to destroy or delete data which is no longer required,
as per our Privacy Notice.
11. Processing in line with data subjects’ rights
11.1 As data subjects, all individuals have the right to:
11.1.1 be informed of what personal data is being processed;
11.1.2 request access to any data held about them by a data controller;
11.1.3 object to processing of their data for direct marketing purposes (including profiling);
11.1.4 ask to have inaccurate or incomplete data rectified;
11.1.5 be forgotten (deletion or removal of personal data);
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11.1.6 restrict processing;
11.1.7 data portability; and
11.1.8 not be subject to a decision which is based on automated processing.
11.2 The Club is aware that not all individuals’ rights are absolute, and any requests regarding the
above should be immediately reported to the committee, and if applicable escalated to the
County FA for guidance.
12. Data security
12.1 We will take appropriate security measures against unlawful or unauthorised processing of
personal data, and against the accidental loss of, or damage to, personal data.
12.2 We have proportionate procedures and technology to maintain the security of all personal data.
12.3 Personal data will only be transferred to another party to process on our behalf (a data
processor) where we have a GDPR-compliant written contract in place with that data processor.
12.4 We will maintain data security by protecting the confidentiality, integrity and availability of the
personal data.
12.5 Our security procedures include:
12.5.1 Entry controls. Any stranger seen in entry-controlled areas should be reported.
12.5.2 Secure desks, cabinets and cupboards. Desks and cupboards should be locked if they hold
personal data.
12.5.3 Methods of disposal. Paper documents should be shredded. Digital storage devices should be
physically destroyed.
12.5.4 Equipment. Screens and monitors must not show personal data to passers-by, and should be
locked when unattended. Excel spreadsheets will be password protected.
12.5.5 Personal Devices. Anyone accessing or processing Club’s personal data on their own device, must
have and operate a password only access or similar lock function, and should have appropriate
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anti-virus protection. These devices must have the Club’s personal data removed prior to being
replaced by a new device or prior to such individual ceasing to work with or support the Club.
13. Disclosure and sharing of personal information
13.1 We share personal data with Cheshire County FA and The FA, and with applicable leagues using
the Whole Game System.
13.2 We may share personal data with third parties or suppliers for the services they provide, and
instruct them to process our personal data on our behalf as data processors. Where we share
data with third parties, we will ensure we have a compliant written contract in place
incorporating the minimum data processer terms as set out in the GDPR, which may be in the
form of a supplier’s terms of service.
13.3 We may share personal data we hold if we are under a duty to disclose or share an individual’s
personal data in order to comply with any legal obligation, or in order to enforce or apply any
contract with the individual or other agreements; or to protect our rights, property, or safety of
our players, other individuals associated with the Club or others.
14. Transferring personal data to a country outside the EEA
We may transfer any personal data we hold to a country outside the European Economic Area
(EEA), provided that one of the appropriate safeguards applies.
15. Reporting a personal data breach
15.1 In the case of a breach of personal data, we may need to notify the applicable regulatory body
and the individual.
15.2 If you know or suspect that a personal data breach has occurred, inform a member of the
committee immediately, who may need to escalate to the County FA as appropriate. You should
preserve all evidence relating to a potential personal data breach.
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16. Dealing with subject access requests
16.1 Individuals may make a formal request for information we hold about them. Anyone who
receives such a request should forward it to the committee immediately, and where necessary
escalated to the County FA for guidance. Nobody should feel bullied or pressured into disclosing
personal information.
16.2 When receiving telephone enquiries, we will only disclose personal data if we have checked the
caller's identity to make sure they are entitled to it.
17. Accountability
17.1 The Club must implement appropriate technical and organisational measures to look after
personal data, and is responsible for, and must be able to demonstrate compliance with the data
protection principles.
17.2 The Club must have adequate resources and controls in place to ensure and to document GDPR
compliance, such as:
17.2.1 providing fair processing notice to individuals at all points of data capture;
17.2.2 training committee and volunteers on the GDPR, and this Data Protection Policy; and
17.2.3 reviewing the privacy measures implemented by the Club.
18. Changes to this policy
We reserve the right to change this policy at any time. Where appropriate, we will notify you by email.
April 2020.
Terms and Conditions
Club Constitution
Updated April 2020
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Spurley Hey F.C. Club Constitution
April 2020
1 Name of Club
The club will be called SPURLEY HEY FC (Hereinafter will be referred to as The Club). The
club will be affiliated to the CHESHIRE COUNTY FOOTBALL ASSOCIATION.
2 Vision, Mission, Aims and Objectives
The vision of the club will be:
“To create the most welcoming, safe, high quality football club for the residents of
Stockport. A club which is focused on the enjoyment and development of participants
of any age, ability, background or circumstance and is committed to getting people
active as well as developing those with talent”.
The mission of the club will be: MISSION 20 29”
“Our mission is to grow the number of teams we currently operate by a total of 20
teams by 2029. This means we will grow from a current base of 15 teams to 35 teams
over the next ten years, by an average of two teams per year. Achieving this growth is
expected to result in an additional 200 playing members”.
The aims of the club will be:
 To offer coaching and competitive opportunities in FOOTBALL.
 To promote the club within the local community and within FOOTBALL.
 To manage and develop the WARTH MEADOW facility as a community sports
hub improving facilities in line with local strategic need and needs of funders.
 To ensure a duty of care to all members of the club.
 To provide all its services in a way that is fair to everyone.
 Ensure the safety of children at all times and ensure compliance to all current and
future safeguarding legislation.
The objectives of the club will be:
 Increase the number of teams by 20 and players by 200.
 Increase the number of level 1 qualified coaches by 40.
 Increase the number of level 2 qualified coaches by 10.
 Increase the number of level 3 qualified coaches by 5.
 Increase the number of other volunteers (and roles such as parent liaison
officers) by 50.
3 Values
The values of the club will be:
 Teamwork – The only way to success is by acting together.
 Respect – Everybody in our team contributes.
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April 2020
 Enjoyment – Football is fun, being passionate and positive are the keys to great
performance.
 Discipline – It takes strength of character and discipline to deliver.
 Sportsmanship – We live the values with fairness and integrity.
4 Membership
(a) Membership of the club is open to anyone interested in promoting, coaching,
volunteering or participating in FOOTBALL, regardless of sex, age, disability,
ethnicity, nationality, sexual orientation, religion or other beliefs.
(b) The membership shall consist of the following categories:
 Full member (classed as an adult who undertakes volunteer work in an
official capacity for the club. Volunteer time is classed as the “fee payable”
for membership of the club).
 Junior member (those junior players who pay annual subscriptions as
players – junior members have no voting rights but are represented by a
parent representative at committee meetings).
 Life member (individual members who have been determined as giving a
lifelong contribution to the club – as decided upon by the Executive. No
fee is payable)
(c) All members will be subject to the regulations of the constitution and by joining the
club will be deemed to accept these regulations and codes of practice that the club
has adopted.
(d) Members in each category will pay membership fees, as determined at the Annual
General Meeting.
(e) Individuals shall not be eligible to take part in the business of the Club, vote at
general meetings or be eligible for selection of any Club team unless the applicable
subscription has been paid by the due date and/or membership has been agreed by
the Club committee.
4 Sports Equity
(a) This Club is committed to ensuring that equity is incorporated across all aspects of its
development. In doing so it acknowledges and adopts the following Sport England
definition of sports equity:
Sports equity is about fairness in sport, equality of access, recognising
inequalities and taking steps to address them. It is about changing the
culture and structure of sport to ensure it becomes equally accessible to
everyone in society.
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April 2020
(b) The Club respects the rights, dignity and worth of every person and will treat
everyone equally within the context of their sport, regardless of age, ability, gender,
race, ethnicity, religious belief, sexuality or social/economic status.
(c) The Club is committed to everyone having the right to enjoy their sport in an
environment free from threat of intimidation, harassment and abuse.
(d) All club members have a responsibility to oppose discriminatory behaviour and
promote equality of opportunity.
(e) The Club will deal with any incidence of discriminatory behaviour seriously, according
to club disciplinary procedures.
5 Committee
(a) The affairs of the Club shall be conducted by a Committee, made up of an Executive
and a Management Group. The leadership of the club shall be conducted by the
Executive Committee and the day to day management of the club by a Management
Committee. The Executive is the decision making body and the Management group
oversees the day to day running of the club. The Management Committee makes
recommendations to the Executive for decisions.
(b) Current Elected Executive
Role Officer
President Dave Jameson
Chairman Lee Preston
Vice Chairman John Batty
Secretary John Batty
Welfare Officer Michelle Thomas
Treasurer Rob Marsh
(c ) Current appointed Management Group (appointed by the Executive)
Role Officer
Vice Treasurer Rick Bell
Assistant Welfare Officer Emma Wooley
Team Secretaries Dave Jameson (Seniors), Dave Tunnicliffe (under 13’s
to under 18’s), James Slate (under 6’s to under 12’s)
Marketing and
Communications Director
Alex Rimmer
Operations Director (Kit,
Equipment and Facilities)
Paul Jackson
Warth Meadow General
Manager
Alan Gee
Sponsorship and Fundraising
Director
John Batty
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Spurley Hey F.C. Club Constitution
April 2020
Tournament Director James Slate
Parent Representative Lead Emma Wooley
Team Managers Director Jake Scanlan
Football Development
Director
Alan Gee
Warth Meadow Development
Director
Lee Preston
(d) Only the posts of the Executive Committee listed above will have the right to vote at
committee meetings.
(e) In any vote, each member of the Executive has one vote. In the event of an equal
split vote, the Presidents has the deciding vote.
(f) All Executive and Management Group members must be members of the Club.
(g) The term of office shall be for one year, and members shall be eligible for reelection. Re- election of officers can occur on as many occasions as voting permits.
(h) No team manager can be a member of the Executive, except in the absence of
nominated individuals, however team managers can hold an officer role of the
Management Group or sub-committee advisor (see below)
(i) If the post of any officer or ordinary committee member should fall vacant after such
an election, the Executive Committee shall have the power to fill the vacancy until
the succeeding Annual General Meeting.
(j) Voting of officers to the executive committee (by club members) shall only occur
should more than one nomination of individuals for elected roles occur.
(k) The Executive will be responsible for adopting new policy, codes of practice and
rules that affect the organisation of the club.
(l) The Executive will have powers to appoint any officers to the Management
Committee as necessary to fulfil its business.
(m)The Executive will be responsible for disciplinary hearings of members who infringe
the club rules/regulations/constitution. The Executive Committee will be responsible
for taking any action of suspension or discipline following such hearings.
(n) The committee meetings will be convened by the Secretary of the Club and be held
no less than 6 times per year, but should aim to be held monthly.
(o) The quorum required for business to be agreed at Committee meetings will be 4 of
17 officers, two of which must be from the Executive Committee and one must be
either the Chair, Vice Chair or President.
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(p) Sub Committees
(a) The club will hold a number of sub committees to carry out club activities.
(b) Sub committees will be chaired by a member of the Management Committee and will
have an Executive Committee member as a committee sponsor – who’s role it is to
support the sub-committee chair. The sub-committee will be attended by relevant
people as appointed by the chair in agreement with the committee sponsor.
(c) Sub committees are able to progress the activities of the club as directed by subcommittee chairs, however Chair’s should make recommendations to the Executive if
activities require Executive decisions.
(d) Sub committees should meet between 6-12 times per year or as appropriate and are
required to regularly report on progress of activities as required by the Executive.
(e) Sub Committees will consist of the following:
No Sub Committee Exec
Sponsor
Chair (s) Description /
Responsibilities
1 Finance /
Fundraising
Treasurer Vice Treasurer Manage all aspects of the
club finances
2 Warth Meadow
Operations
Committee
Chairman General Manager
Warth Meadow
Lead the day to day
operations of Warth Meadow,
including usage and
maintenance of the facility.
3 Tournament Vice Chair Tournament
Director
Lead and manage all aspects
of the summer tournament
4 Operations Welfare
Officer
Marketing and
Communications /
Assistant Welfare
Officer
Address all aspects of club
operations including; Welfare,
marketing and
communications, policies and
procedures
5 Team Managers Secretary Team Managers
Director / Parent
Lead
All team managers / parent
representatives to attend,
ensure positive
communication and deal with
all aspects of team
management.
(f) Other sub committees can be established as required, with the approval of the
Executive.
(q) Finances
(a)The club treasurer will be responsible for the finances of the club.
(b) The financial year of the club will run from 1
st June and end on 30th May
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(c)All club monies will be banked in an account held in the name of the club.
(d) An audited statement of annual accounts will be presented by the treasurer at the
Annual General Meeting.
(e) Any cheques drawn against club funds should hold the signatures of the treasurer
plus up to two other officers of the Executive.
(f) All members of the Club shall be jointly and severally responsible for the financial
liabilities of the Club.
(r) Annual General Meetings and Extraordinary General Meetings
(a) General Meetings are the means whereby the members of the Club exercise their
democratic rights in conducting the Club’s affairs.
(b) The Club shall hold the Annual General Meeting (AGM) in the month of
September to:
 Approve the minutes of the previous year’s AGM.
 Receive reports from the Chairman and Secretary.
 Receive a report from the Treasurer and approve the Annual Accounts.
 Receive a report from those responsible for certifying the Club’s accounts.
 Elect the officers on the committee.
 Agree the membership fees for the following year.
 Consider any proposed changes to the Constitution.
 Deal with other relevant business.
(c) Notice of the AGM will be given by the club secretary with at least 28 days’ notice to
be given to all members.
(d) Nominations for officers of the committee will be sent to the secretary prior to the
AGM.
(e) Proposed changes to the constitution shall be sent to the secretary prior to the AGM,
who shall circulate them at least 7 days before an AGM.
(f) All members have the right to vote at the AGM.
(g) The quorum for AGMs will be 25% OF THE MEMBERSHIP.
(h) The Chairman of the Club shall hold a deliberative as well as a casting vote at
general and committee meetings.
(i) An Extraordinary General Meeting (EGM) shall be called by an application in writing
to the Secretary supported by at least 10% of the members of the Club. The
committee shall also have the power to call an EGM by decision of a simple majority
of the committee members.
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Spurley Hey F.C. Club Constitution
April 2020
(j) All procedures shall follow those outlined above for AGMs.
(s) Amendments to the constitution
The constitution will only be changed through agreement by majority vote at an AGM
or EGM.
(t) Discipline and appeals
(a) All concerns, allegations or reports of poor practice/abuse relating to the welfare of
children and young people will be recorded and responded to swiftly and
appropriately in accordance with the club’s child protection policy and procedures.
The Club Welfare Officer is the lead contact for all members in the event of any child
protection concerns.
(b) All complaints regarding the behaviour of members should be presented and
submitted in writing to the Secretary.
(c) The Executive will meet to hear complaints within 7 days of a complaint being
lodged. The committee has the power to take appropriate disciplinary action including
the termination of membership.
(d) The outcome of a disciplinary hearing should be notified in writing to the person who
lodged the complaint and the member against whom the complaint was made within
5 days of the hearing.
(e) There will be the right of appeal to the Executive following disciplinary action being
announced. The Executive should consider the appeal within 7 days of the Secretary
receiving the appeal.
(u) Dissolution
(a) A resolution to dissolve the club can only be passed at an AGM or EGM through
a majority vote of at least three quarters of the voting membership.
(b) The dissolution shall take effect from the date of the resolution and the members
of the club committee shall be responsible for the winding up of the assets and
liabilities of the club.
(c) Any surplus assets remaining after the discharge of the debts and liabilities of the
club shall be transferred to another club, a competition, any parent company
association or the FA for use by them for related community sports.
(v) Declaration - SPURLEY HEY FC hereby adopts and accepts this constitution as a
current operating guide regulating the actions of members as agreed by the Executive.