Privacy Policy

1. What is the purpose of this document?

The Players Foundation (TPF) is committed to protecting the privacy and security of personal data. In this notice, “we”, “us” or “our” refers to TPF, which operates the website at theplayersfoundation.org. We are a charity registered in England and Wales under charity number 1150458 and have our registered office at Brabners, Horton House, Exchange Flags, Liverpool, L2 3YL.

This privacy notice describes how we collect and use personal data about users of our services, in accordance with the UK General Data Protection Regulation (UK GDPR) and other applicable data protection laws in the UK. It is important that you read this policy so that you are aware of how we will deal with any personal data relating to you.

We are a “controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection law to notify you of the information contained in this privacy notice.

Should you have any queries about anything in this privacy notice, please contact by email at info@theplayersfoundation.org or in writing to TPF, PO Box 235, DENTON, M34 0EB.

1. Data protection principles

We are accountable for demonstrating compliance with the GDPR’s six principles of processing personal data. These provide that personal data we deal with must be:

1. processed fairly, lawfully and in a transparent manner;

2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;

3. adequate, relevant and limited to what is necessary;

4. accurate and, where necessary, kept up to date;

5. not kept for longer than necessary; and

6. processed securely, maintaining integrity and confidentiality.

1. The kind of information we hold about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). If we used anonymised data that cannot identify you, either directly or indirectly, such use will fall outside the scope of this policy.

There are certain types of more sensitive personal data (known as special category data) that require a higher level of protection. This means personal data revealing information about a person’s health, medical history, religious or philosophical beliefs, racial or ethnic origin, political opinions, trade union membership, sex life or sexual orientation and the processing of genetic or biometric data for the purpose of uniquely identifying someone. Information about criminal convictions also warrants this higher level of protection.

We will collect, store and use the following categories of personal data about you:

• Personal contact details you use to access our site or otherwise make contact with us, such as name, telephone number and personal email address

• Date of birth

• Gender

• Marital status and dependants

• Information you may make available via social media if you engage with us online

• IP addresses, device information and other online identifiers from your use of our website

• Any information you might provide in connection with an application for financial support, including details of existing debts or financial commitments.

We may also collect, store and use the following types of special category data:

• Details of any current or historic medical condition or treatment provided to us in connection with an application for support

• Acknowledgement of your membership of the Professional Footballers Association

1. How is your personal data collected?

We collect personal data from you directly when you use our website or enter into correspondence with us. In some cases, the Professional Footballers Association or persons acting on their behalf provide us with information that may relate to you in connection with any application for financial support. We may also verify information you provide, or obtain additional information, from publicly available sources such as the Land Registry, Companies House, Adult Social Services teams and occupational therapy professionals.

1. How we will use information about you

We will only use your personal data when the law allows us to do so. We will only collect personal data to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it – and we will keep it only as long as is necessary.

Situations in which we will use your personal data

The situations in which we will process your personal data are listed below.

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To communicate with you and to manage our relationship	Name, contact details, any information you choose to share with us in communications	Legitimate interest in managing our relationship and providing an efficient service
To advertise our services	Quotations, testimonials	Your consent for us to use such data for promotional purposes
To keep our supporters updated on our news and events	Contact details	Consent to receiving marketing communications
To ensure that content from our website is presented in the most effective manner for you and for your device	online identifiers, location data and other technical information	Legitimate interest in providing a user-friendly service
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.	IP addresses, device information and other online identifiers	Legitimate interest in providing secure online systems and protection of data
Assessment of applications for financial support and administration of successful applications	Name, contact details, any information you choose to share with us in communications	Legitimate interest in carrying out the charity’s objectives and supporting beneficiaries Consent in relation to any health or other special category data

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.

We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered “personal data” in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your website usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you provide us with any personal data relating to beneficiaries, partners or other individuals it is your duty to make such persons aware that their personal data may be shared with us and to provide them with appropriate information about how their personal data may be processed by us.

We do not knowingly solicit information from or market to children. We will only collect data relating to children if provided in connection with an application for support, for example if an applicant is seeking support with their child’s medical treatment. If you become aware of any other data we have collected relating to individuals under age 18, please contact us using the details provided above.

If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to provide certain services to you.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Relying on consent

In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:

• is specific consent for one or more specified purposes; and

• is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the relevant processing of personal data.

1. Situations in which we will use your special category data

In general, we will only process special category data when provided to us in connection with an application for financial support. There may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your special category data are listed below:

We will rely on your explicit consent to process any data you provide relating to health conditions or medical treatment.

By virtue of your having joined the Professional Footballers Association and having become involved with us, you have consented to revealing your trade union membership with the Professional Footballers Association.

We will not process any personal data relating to criminal offences or historic convictions.

We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.

1. Direct marketing

As indicated above, we may use your personal data to provide you with information about services or events that may be of interest to you and we may contact you about these by email, text message, post or telephone call. This is known as direct marketing.

Examples of direct marketing may include:

• sending promotional emails about events or other information which we think you may find useful or interesting using the email address which you have provided;

• contacting you for market research purposes (by email, text message, post or telephone call).

We will only process personal data for the above purposes as permitted by law, which usually means with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.

1. Automated decision-making

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

1. Data sharing

We may share your data with third parties, including external bodies that use personal data as controllers in their own right (such as The Professional Footballers’ Association) or third parties who have access to data in our systems in order to provide services to us (in which circumstances they act as our processor).

We require third parties to respect the security of your data and to treat it in accordance with the law.

Why might you share my personal data with third parties?

We will share your personal data with third parties where required by law or where we have another legitimate interest in doing so (for example, in sharing information with The Professional Footballers’ Association in order to fulfil contractual obligations, if relevant). We may also share your information with Adult Social Services, occupational health professionals and other third parties relevant to your circumstances and we will obtain your consent to any such sharing where required by law. These third parties will use any personal data in accordance with their own privacy policy, which they are obliged to notify to you in most circumstances. Data used for research purposes will be anonymised wherever reasonably possible.

We may also share your personal data with other third parties, for example in the context of the possible sale or restructuring of the organisation. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

Which third-party service providers process my personal data?

The following activities are carried out by third party service providers: IT services including web hosting; digital marketing; PR advisory services; assessment of funding applications. DISC in order to assess dementia needs and issues. We also use the services of a benefits advisor and solvency expert as appropriate.

All our service providers are required to take appropriate security measures to protect your personal data. We do not allow our third-party service providers to use your personal data for their own purposes; we only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transferring information outside the UK

We may transfer the personal data we collect about you outside the UK. If this is the case, we will ensure appropriate safeguards are in place so your data is protected to the same standard as would be required by laws in the UK.

1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained on request (see contact details above).

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Please note that we are not responsible for third parties who use your personal data for their own purposes. You should refer to the privacy policy of any relevant third party for more information.

1. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

1. Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as summarised below.

You have the right to:

1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

4. Object to processing of your personal data where we are relying on a legitimate interest (of our own or of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at info@theplayersfoundation.org. We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive – alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

1. Cookies

Our websites use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our services.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer or device. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie	Domain	Description	Duration	Type
_ga_*	.theplayersfoundation.org	Google Analytics sets this cookie to store and count page views.	1 year	Analytics
_ga	.theplayersfoundation.org	Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.	1 year	Analytics

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our website.

Except for essential cookies, all cookies will expire after two years.

1. Changes to this privacy policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

1. Questions

If you have any questions about this privacy notice, please contact us at info@theplayersfoundation.org. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk) with respect to data protection issues but we would prefer the opportunity to try and allay any concerns ourselves in the first instance.