WHS Privacy Notice FAQs - TOP 11
|1.||What about members who do not have an email address||Should members not have their own email address, the system will allow players to share an email address. This is in recognition of the fact that parents of junior members may wish to use their own email address, and many couples choose to share an email address. Players without an email address could ask to use the email of a friend or family member, alternatively help could be provided to the member to set up an email account for this purpose. Those members who do not have an email address associated with their record will not be able to access the handicap system under WHS.|
|2.||What should members who do not wish to have personal data transferred to you do?|
Members are not required to “opt in” to the data transfer to England Golf, because consent is not one of the grounds relied upon. If members do not wish England Golf to process their data they should contact our data protection officer via [email protected]
However, if a member does not wish us to process their data they will not be able to have access to a handicap under WHS.
|3.||How will you collect members’ personal information||The transfer of member data, will be done via the ISVs’ dedicated API link to the England Golf WHS Platform. This will happen on the 5th October, at which time we will begin a dual running period in preparation for launch.|
|4.||Do I need to ask for consent from my members to transfer the data to England Golf?|
England Golf is not asking for golf clubs to consent on behalf of their members. Consent is just one of the grounds open to data controllers to rely on for the processing of data, and as set out in the privacy notice England Golf is not relying on consent for its processing relating to handicaps.
Where one data controller (in this case England Golf) receives data from another data controller (in this case golf clubs) the law requires that individuals are provided with certain information about the reason for the transfer and what will happen with the data. The required information is set out in the England Golf WHS privacy notice that you will have received.
Your club will already share personal data with third parties, such as your existing software providers. As administrators of the handicap system under WHS England Golf will require personal data from your members in order to calculate and maintain their handicaps. This is set out in the England Golf WHS privacy notice, which should be shared with members.
|6.||your personal data” in bullet point 4 “To provide you with information that you request or which may be of interest to you”. What does that mean?|
Please note that we will not be sending marketing emails to any individuals who have not “opted in”, or consented, to receive such communications (and individuals will have the opportunity to opt in via the golfer portal, when it is launched). Any communications to members under the extract of the privacy notice that you quoted will be related to handicapping or some other benefit of being a member of England Golf. An example of such a benefit would be the personal liability insurance that was launched last year as a benefit to members of affiliated golf clubs.
|7.||Please explain what role Date of birth/email address plays in the handicap system. How does it help ensure the integrity of the system?||The move to the WHS in November 2020 means that in England we are moving from a system with some 1,800 calculation hubs to a central England Golf platform. In order to maintain the integrity of the handicapping system now and in 5 or 10 years’ time and beyond, we need to be able to say with confidence that a member of a particular golf club is the same as or a different person to a person who was previously a member at another golf club. Without that we cannot be certain that the handicap is a true reflection of a player’s ability. That is why we are asking for additional information from members, including date of birth.|
|8.||What about individuals who do not want to have a handicap or to be members of England Golf?|
The Rules of England Golf provide that membership includes Playing Members, who are those individuals who have a contract providing playing rights at an Affiliated Club, irrespective of membership category. The Rules of England Golf were adopted under Article 56 of England Golf’s Articles of Association, and the latest version of the Rules was adopted in 2018. Both the Rules of England Golf and the Articles of Association are available to download here.
Those members who choose not to engage with the handicap system will remain members of England Golf, and will retain the other benefits of membership such as personal liability insurance.
|9.||As a member of a golf club, do I need to sign up to England Golf to keep my handicap?|
You do not need to sign up to England Golf to keep a handicap under the new system. Your club should transfer your information to England Golf via the club’s current handicap software provider on 5 October 2020. If your club does not have your date of birth and up to date email address they should be provided before this date.
Signing up to England Golf, whether via the website or the app, will remain optional.
|11.||What if I cannot upload all of the required data by 5 October?|
The required fields for members under WHS are as follows:
v. Email Address
Clubs are asked to obtain this information from members and ensure their records are up to date in preparation for the data transfer (via ISVs) on 5 October 2020.
Any records which require updating after that date can be updated by logging in to the England Golf WHS Platform to which clubs will have access.