For the purposes of the General Data Protection Regulation (“GDPR”) and UK data protection laws, the controller of your personal data is the Cumberland Lawn Tennis Club (the “Venue”) of 25 Alvanley Gardens, London NW6 1JD.
About this document
The Club has appointed a Data Protection Officer (DPO) to manage its obligations under data protection law and this person should be contacted with any questions or concerns you may have. Contact details for the DPO can be found below.
Information we may collect from you
We may collect the following types of personal data about you:
- Information you provide by filling in forms on our site www.cltc-hcc.com;
- Information you provide when requesting further information from us;
- Information you provide if you report a problem with our site;
- If you contact us, we may keep a record of that correspondence
IP Addresses and Cookies
We may collect information about your computer, including, where available, your IP address, operating system and browser type. This is for system administration purposes and involves statistical data about our users’ browsing actions and patterns. This type of data collection does not identify any individual.
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive and which help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences and to allow us to customise our site according to
your individual interests.
- To speed up your searches.
- To recognise you when you return to our site (notably your preferences where indicated and
log in details to the Members’ Area should you choose to be remembered.
How we use the information
We use the information in the following ways:
- To ensure that content from our site is presented in the most effective manner for you and for your computer
- To provide you with the information, products or services that you request from us
- To administer your log in details should you have access to the Members’ Area
Your marketing preferences
We will only contact you with information you have requested and will not use any personal information for general marketing purposes, unless you have advised us you wish to be contacted with details of future promotions etc.
Sharing your information with others
We do not sell your personal data to third parties.
Where necessary, however, we do share your information with third parties as set out below:
- Our employees and volunteers, for the purposes of administering the information you have provided
- Select contractors and suppliers, including our Club coaches, who may provide and administer activities you have requested information on (coaching services, league and tournament organisation etc)
- Our website provider (for example, Startadesign)
For all shared uses of personal data, the third parties are classed as Data Processors, with CLTC remaining the Data Controller.
How long your information is kept
We keep your personal data only for as long as necessary for each purpose we use it.
For most information provided through our website, we will normally retain it for a period of six years after your last interaction with us, subject to your right to erasure (see below).
By law, data subjects have various rights.
To follow is a summary of these rights as identified by the regulation and how CLTC will respect them.
The right to be informed
The right of access
Commonly known as a “data subject access request”, individuals are able to request confirmation of what data we have on them, how it is being used and under which lawful basis it is being processed. All such requests should be directed to the Club’s DPO and we will comply with all requests within a month of receipt. The Club will, however, retain the right to refuse, but will only exercise this right if we consider the request to be unfounded or excessive. In such cases, individuals will be able to complain to the Main Committee or to the ICO, details of whom are provided below.
The right to rectification
Individuals can request that incomplete or incorrect data be completed or corrected. All such corrections should be provided to the Club Office in writing, by email, on the phone or in person, at any time. Updates to the Club’s records will be made as soon as possible, but no later than a month after receipt.
The right to erasure
Individuals have “the right to be forgotten” and request all data relating to them be erased from Club
records if they feel the original processing purpose is no longer necessary, if they withdraw consent from any consensual processing, if they object on the basis of their believing there to be no overriding legitimate interest, the legal basis used was incorrect or if dictated by a legal obligation. All such requests should be directed to the Club’s DPO and we will comply with all requests within a month of receipt. The Club will, however, retain the right to refuse, but will only exercise this right in order to comply with a legal obligation, if it relates to a public interest or official authority task, for historical statistical archiving or research purposes, or to help defend a legal claim.
The right to restrict processing
Individuals can block or suppress processing of their data (but allow the Club to retain it) should they
contest the accuracy of the data held on them, where they have objected to the processing (see below), where they allege the legal basis upon which it is being used is incorrect, or should they require the data regarding a legal claim, even if we no longer need or require it. All such requests should be directed to the Club’s DPO in writing and we will comply with all requests immediately upon receipt. This compliance will either last forever or until such time as the reason given is disproved or a period of six years passes after the individual’s membership ceases (see above). You can also withdraw your consent where this is the basis for our processing of your data (without affecting the lawfulness of our previous processing based on consent).
The right to data portability
Individuals can request personal data held by one organisation be transported to another, although CLTC does not currently transport data to other companies, other than to third parties as outlined above.
The right to object
Individuals can object to their data being processed and challenge the use of their data as a legitimate interest or if they disagree with our assertion that we are processing in the public interest, in the exercise of official authority or for historical statistical archiving or research purposes. Individuals can also object if they believe they are being unlawfully directly marketed to. All objections should be directed to the Club’s DPO in writing and we will comply with all requests immediately upon receipt. All further processing will be restricted until such time as the objection has been investigated and either compelling evidence contrary to the objection can be demonstrated (such as the legitimacy of a legitimate interest) or the objection upheld. This process will be completed within a month.
Rights related to automated decision making and profiling
Individuals have a right to not be subject to a decision that is processed solely by automated means (i.e. without any human involvement) and which has a significant effect upon them, unless necessary for contractual purposes, is authorised by law or based on explicit consent. Any profiling (i.e. automated processing of personal data to evaluate certain things about an individual) must have appropriate safeguards in place. If Members believe they are being subject to unlawful automated decision making or profiling, they should contact the Club’s DPO in writing and we will investigate the matter immediately. If it is determined that automated processing is taking place, Members will be allowed to obtain human intervention, express their point of view, obtain an explanation and challenge it.
Please note that the above rights are not absolute and we may be entitled to further refuse requests where exceptions apply.
CLTC classes children as persons aged under 16 on the first day of each membership year (1 May). Children are entitled to visit our website, but are required to have a parent or guardian submit any information on their behalf. As such, all processing of children’s data is done with parent or guardian knowledge and consent.
Contact and complaints
Telephone: 0207 4356022
Post: 25 Alvanley Gardens, London NW6 1JD
If you are not satisfied with how we are processing your personal data, you can make a complaint to the Club’s Main Committee or to the Information Commissioner. Main Committee Member details can be found on the Club’s website or displayed on the Club noticeboard in the clubhouse and you can find out more about your rights under applicable data protection laws from the Information Commissioner’s Office website: www.ico.org.uk.