We at the Delamere Forest Golf Club (“we” or “our” or “us”) want to make sure all the personal information we have collected about you, is safe and secure whether we collect it through our website at www.delameregolf.co.uk (“Site”) or from other sources. This Policy set outs our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation. Contact details are set out in the "Contacting us" section at the end of this privacy notice.
- Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us or in providing services to our customers and members or just managing our relationship with you.
- When we hold or use your personal information as a data controller (see below for a description of what this is) we will provide you with a privacy notice which sets out in detail what information we hold about you (such as your contact details, address, etc.), how your personal information may be used and the reasons for these uses, together with details of your rights.
- Where we collect personal information from you directly, we will provide this privacy notice at the time we collect the personal information from you. Where we receive your personal information indirectly, we will provide this privacy notice when we first contact you, first pass the data to someone else or within a month, whichever is the earlier.
- We will only provide this privacy notice to you once, generally at the start of our relationship with you. However if the applicable privacy notice is updated substantially, then we may provide you with details of the updated version. You are encouraged to check back regularly for updates.
Copies of our current privacy notices can be found below:
Member privacy notice: available to members from the Member's Area of our Site.
CCTV privacy notice: under the new laws, the CCTV images recorded are considered ‘Personal Data’. Data is processed fairly and lawfully and images of people and the information which is derived from images (for example, vehicle registration numbers) are covered by the Data Protection Act.
- What images do we record? Our CCTV cameras are designed/sited so they procvide clear images of all aspects of our buildings (Clubhouse, Visitors' Block and Green Shed). We also have cameras covering the inside of the Professional's Shop, the Club Car Park, the Barrier and areas around the 1st and 10th Cameras are positioned to avoid capturing images of persons not visiting the premises/club property. Monitors are sited monitors in positions that provide staff with the security required whilst restricting as far as is practical the ability of the public to see them.
- Why do we record these images? We have installed a CCTV system which produces clear images which the law enforcement bodies can use to investigate crime and these can easily be taken from the system when required - the majority of the images we record are for the purpose of crime prevention. The cameras are used to identify and monitor unusual activities/unauthorised access for security purposes, particularly out of normal working hours. The cameras covering the 1st and 10th tees will also be used to monitor play from these tees to try to assist us in ensuring the flow of play on the course. The camera in the Professional's shop will also help prevent/monitor/track any possible incidents of aggression towards staff members who may be on their own.
- How do we store our data? In general terms, CCTV images should be retained for 30 days. If there has been an unusual occurrence/incident we may store images for longer but will delete them as soon as we are satisfied they are no longer required.
- Who has access to the information? A limited number of authorised persons that may access the recorded images from the CCTV system, which are securely stored/password protected. The recorded images are held for 30 days and, with the exception of law enforcement bodies, images will not be provided to third parties.
CCTV images are record externally for crime prevention – visible signs are in place highlighting CCTV is in use.
Rights: Any person whose image is recorded on a CCTV system has a right to seek and be supplied with a copy of their own personal data from the footage. Any person captured on our CCTV system has the right to request the footage as it is classed as their ‘Personal Data’ - if any other person is visible in the image, their identity will be blurred. The police may also request footage. As this is a legal request, the images must be provided following the relevant due diligence to ensure the request is authentic (for example, we will ask for the request in writing on letter headed paper, or from a valid police force email address).
Please note that it is possible for you to be covered by more than one privacy notice, for example you may be a member who comes onto our premises and is recorded on CCTV. In this example both our member privacy notice and our CCTV privacy notice would apply to you.
The difference between data controllers/processors
- A data controller is a person who controls how personal information is processed and used. A data processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller.
- This distinction is important. You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below to see what rights you have). These rights can generally only be exercised against a data controller of your information.
- In most cases we will be a data controller of your personal information. In any case where we are not a data controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the data controller (i.e. the person who controls how we process the personal information). In these cases we will endeavour to inform you who is the data controller of your personal information so that you can direct any such requests to them.
- Also it is only a data controller that will provide you with a privacy notice about your personal information, so where we process your personal information as a data controller we will provide you with a privacy notice. Where we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.
How do we use your personal information?
- We will use your personal information as described in the privacy notice provided to you, but, for example, we may use your personal information to administer any account(s) you have with us or to send you information we think you might find useful, provided you have indicated that you are happy to be contacted for these purposes. To see how we use your personal information, please see our current privacy notices (see 'Privacy Notices' section above for further details
Who do we share your personal information with?
- Details of how we disclose your personal information are set out in the relevant privacy notice provided to you, but generally it is where we need to do so in order to run our organisation (e.g. where other people process information for us). In such circumstances, we will put in place arrangements to protect your personal information. Outside of that we do not disclose your personal information unless we are required to do so by law.
- If we transfer personal information about you outside the European Economic Area (EEA), we will let you know and ensure that all reasonable security measures are taken and that any third party processers will be required to process the information in accordance with information protection laws and we will notify you in your privacy notice if we are the information controller.
- We do not sell, trade or rent your personal information to others.
How long do we hold on to your personal information?
- Further details of how long we hold onto your personal information for are set out in the relevant privacy notice provided to you, but we will only hold your information for as long as is necessary or where you ask us to delete records we may delete it earlier.
- The duration for which we retain your personal information will differ depending on the type of information and the reason why it was collected. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.
What are Your rights?
- Full details of your rights set out in the relevant privacy notice provided to you, but you are entitled by law to ask for a copy of your personal information at any time. You are also entitled to ask us to correct, delete or update your personal information, to send your personal information to you or another organisation and to object to automated decision making. Where you have given us your consent to use your personal information in a particular manner, you also have the right to withdraw this consent at any time.
- To exercise any of your rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contact" section below. You can also unsubscribe from any direct marketing by clicking on the unsubscribe link in the marketing messages we send to you.
- You should note that some of your rights may not apply as they have specific requirements and exemptions which apply to them and they may not also apply to personal information recorded and stored by us. However your right to withdraw consent or object to processing for direct marketing are absolute rights.
- If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner’s Office or your local data protection regulator. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/. However, we are here to help and would encourage you to contact us to resolve your complaint first.
Linking with third party sites
- Our Site may, from time to time, contain links to and from the websites of our commercial partners, other regional/national bodies, advertisers and clubs. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.
- In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
- We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information.
- Certain parts of our Site use "cookies" to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store on your computer's hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited. The only personal information a cookie contains is information that you have personally supplied.
- In common with most websites, our Site logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.
- We may use this information to analyse trends, administer the Site, track your movement around the Site and gather broad demographic information.
Changes to this policy
- Any changes we may make to this Policy in the future will be posted on our Site and, where appropriate, notified to you by e-mail. When we change this Policy in a material way, we will update the version date at the bottom of this page. Please check back frequently to see any updates or changes to this Policy and should you object to any alteration, please contact us as set out in the "Contact" section below.
- In the event of any query or complaint in connection with the information we hold about you, please email firstname.lastname@example.org or write to us at: The Secretary, Delamere Forest Golf Club, Station Road, Delamere, Northwich, Cheshire CW8 2JE.
- Our Data Protection Officer can be contacted at the above email/postal address.
Version Date: 17th May 2019