This policy describes how BRUFC Supporters Group Ltd (also referred to as “the club ‘,“we” or “us”) will make use of the data we handle in relation to our employees and customers.

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.

Summary of how we use your

Where you are an employee

• BRUFC Supporters Group uses your personal data to manage and administer your employment and our payroll systems. Some data may be shared with HMRC or an Automatic Enrolled pension provider in order to comply with our statutory duties.

• Amongst the data we collect from you may be medical (including injury) information. We will hold this where you have given consent, so that we can ensure we are aware of your condition and can that you are supported appropriately.

What information do we collect?

• your name

• your gender

• your date of birth,

• your home address, email address and phone number;

• your passport and NI details, where we have to check your eligibility or ability to work for us

• your bank account details in order that we can pay your wages;

• some information will be generated as part of your involvement with us, in particular data about your performance, details of any disciplinary issues, or within health and safety records

• where you hold a role at with us requiring us to check your right to work, we may process information to meet our statutory duties;

What information do we receive from third parties?
We may also receive information from England Rugby, or their external checking service, in relation to a Disclosure and Barring Service (DBS) request; or, in the case of an application for employment, in the form of a reference from a previous employer.

Where you are a customer

• BRUFC Supporters Group uses your personal data to administer any involvement you may have in our business, eg; the booking of our premises for a function.

• Where we rely on your consent, such as any consent we seek for email marketing, you can withdraw this consent at any time.

What information do we collect?

• your name

• your home address, email address and phone number; so that we can contact you with regard top the services you are booking

• your payment and/or bank account details, where you provide these to pay for our services.

• your marketing preferences, including any consents you have given us;

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 our services and any merchandise. 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 us to conduct our business and pursue our legitimate interests, in particular:

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 promotional materials and offers by post or by phone, or by email where we want to send you offers relating to similar products and services that you have already bought [

• 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/guardian (if under 18)/guardian (if under 18) 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 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, 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 in the “How do I get in touch with you or the RFU?” section.

Who will we share this data with, where and when?
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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 legitimate interests in compliance with applicable laws.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request.

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 RFU for its own purposes on GMS.
To exercise any of these rights, you can get in touch with us– or, as appropriate, the RFU 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.

How do I get in touch with you or the RFU?

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 brufcdata@gmail.com or by writing to: Data controller, Braintree RUFC, Beckers Green Road, Braintree, CM7 3PR

How long will you retain my data?

Where you are an employee, we process the majority of your data for as long as you are employed and until the end of the tax year in which any such employment ceases
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Where you are a customer, we will process your data during any period of your involvement with our business commencing with the date of your original enquiry to a period not later than 5 years following the end of your involvement with us eg. The date of any function booked.

Where we process personal data for marketing purposes or with your consent, we process the data for 5 years 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 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 RFU will maintain records of employees where these relate to DBS checks and the resulting outcomes and other disciplinary matters for such period as is set out in the RFU’s privacy notice to be set out on www.englandrugby.com.