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Foundation Privacy Policy

  1. Introduction

Tottenham Hotspur Foundation takes your privacy seriously. This privacy policy sets out what personal information we process about you, how we use your personal information and your rights regarding the personal information we hold about you.

This policy applies to personal information we process when you access our websites, when you engage with us on social media platforms, when you enrol on our programmes and when you communicate with us generally.

 

  1. About us

Tottenham Hotspur Foundation is registered as a data controller in the United Kingdom and our registration number is Z1034030. Our registered office is Percy House, 796 High Road, Tottenham, London N17 0DH.

 

  1. Legal notice

This policy has been prepared in line with the data protection laws applicable in the United Kingdom, including the General Data Protection Regulation (GDPR) and any subsequent amendment or legislation passed to enact GDPR into UK Law.

 

  1. How to contact us about this Privacy Policy

We have staff who oversee our data processing activities and they have access to a dedicated Data Protection Officer appointed to Tottenham Hotspur Football Club. If you have any questions or concerns about this Privacy Policy or about your personal data in general, please let us know by emailing foundation.personaldata@tottenhamhotspur.com.

 

  1. Personal information we process and what we use it for

We must process personal information about you so that we can provide you with our services. We collect most of this information from you directly, but we may also receive data from third parties such as schools, partner organisations and funding partners. The table below outlines the personal information we collect about you, what we use it for and our legal reason, also known as the lawful basis, for processing it.

Purpose/activity  Personal data types   Lawful basis
To register you as a course participant and keep in touch with you during the programme you have registered for   • Your name, postal address, email address and phone number (contact details) • Our legitimate interest as a provider of services and activities in the community 
To register you as the parent or legal guardian of a course participant who is under the age of 16 and for emergency contact   • Name, contact details, relationship to the participant  • Legal obligation (Safeguarding and Vulnerable Groups Act 2006)
To make reasonable service adjustments to make sure that you can access our services safely if you have a disability or health condition  • Name, contact details
• Type of adjustment required and details of why the adjustment is required
• Health condition and precautions required  		 • Legal obligation (Equality Act 2010)
• With your explicit consent  
 To register you as a volunteer on one of our programmes • Name, contact details, date of birth 
• Results of disclosure checks from the Disclosure and Barring Service (DBS) if you are working with children under 16 or adults receiving health or personal care		 • Our legitimate interest as a provider of services and activities in the community
• Legal obligation (Safeguarding and Vulnerable Groups Act 2006) 
To assess your suitability as a job applicant for the role you have applied for   • Name, contact details, previous work, education, referees and answers relevant to the role • Performance of a contract with you 
Purpose/activity  Personal data types   Lawful basis
To provide feedback to the organisation who has referred you to one of our programmes   • Name, contact details,
• Your health conditions and any improvements if these are related to the purpose of the course you have registered for		 • Our legitimate interest as a provider of services and activities in the community
• After anonymisation 
To allow Tottenham Hotspur Football Club to contact you about latest news, competitions, tickets, merchandise and offers • Name, contact details  • With your explicit consent  
To produce case studies which can be included in publications and other forms of publicity • Photographs
• Details of activities		 • With your explicit consent 
To enable us to anonymously monitor the fairness, equality and inclusion of our programmes  • Racial and ethnic origin
• Age
• Gender
• Disability		 • With your explicit consent 
To allow you to contribute towards fundraising and donations for the Foundation • Name
• Email address and/or Address
• Card Details		 • Performance of a contract with you 
  1. Our commitment

We commit to only processing your personal information for the purposes outlined in the table above. If these purposes change over time, or we want to use the data for a new purpose that we did not originally anticipate, we will only go ahead if the new purpose is compatible with the original purpose. If the new purpose is not compatible with the original purpose, we will ask for your specific consent for the new purpose. If the law changes so that we must process your data for a new purpose, we will inform you before making the change.

At the point when we collect your personal data, we will always remind you of why we need it and how we plan to use it.

  1. Automated decision-making and profiling

We do not conduct any automated decision-making such as profiling. If this changes, we will update this privacy notice and update you accordingly.

  1. Sharing your information with third parties

We may share your personal information with third parties as part of our service to you. The list below shows who we may share information with and the situations where we might do so.

  • Service providers: In order to provide our services effectively we may need to appoint data processors to carry out some of the data processing on our behalf. These include, for example, Tottenham Hotspur Football Club, who provide us with our IT service, and other software suppliers. We have agreements in place with our data processors which means they cannot do anything with your personal information unless we instruct them to do so.
  • Funding partners: We may share your personal data with the organisations we work in partnership to deliver our community activities. These include schools, local authorities and charities who are all also registered data controllers. We have agreements in place with them to acknowledge that we are both responsible for preserving your privacy and processing your data in accordance with the law. The data may or may not be shared anonymously, but we will let you know which is the case when you register.
  • Publicity and Media: From time to time we may wish to publicise the work we are doing through publications or the media, including social media. We may ask you to be a part of this but we will only disclose your personal information, such as your photograph, with your explicit consent, or that of your guardian if you are under 16.
  • Tottenham Hotspur Football Club: If you give your explicit consent, we will pass on your contact details to the Club so that they can inform you about their latest news, competitions, ticket and merchandise updates and offers. When you set up a user account with the Club you will have the opportunity to express your preferences for the way your data is used.
  • Legal and other obligations: We may also share your personal data with third parties in the following circumstances:
    • If we are under a legal or regulatory requirement to do so
    • To lawfully assist the police or security services with the prevention and detection of crime or terrorist activity
    • Where disclosure is necessary to protect the safety or security of any persons
  1. International Data Transfers

We do not currently transfer your personal information outside of the European Economic Area. If this changes in the future, we will update this Privacy Policy and put in place measures to ensure your information is given the appropriate level of protection.

  1. Keeping your information

We retain your personal information for the minimum reasonable time period to allow us to fulfil the purposes that we collected it for. Our retention schedule is as follows:

  • If you are a participant on a course, we will keep your personal data for the length of the programme you have signed up for and a limited period afterwards to allow follow-up. The follow-up period varies from course to course and we will let you know what it is when you sign up for the course.
  • If you apply for a job and are successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment and for 7 years afterwards as required by law.
  • If you apply for a job and are unsuccessful, we will retain your personal details for a period of 6 months after your application. If you give us your explicit consent, we may hold your data on file for a further 6 months for consideration for future employment opportunities.
  • If you apply to be a volunteer and are successful, we will retain your personal data for as long as you remain a volunteer with us and for 6 months afterwards to enable us to deal with any queries that may arise. If you give us your explicit consent, we may hold your data on file for a further 6 months for consideration for future volunteering opportunities.
  • If you apply to be a volunteer and are unsuccessful, we will retain your personal data for 6 months after your application. If you give us your explicit consent, we may hold your data on file for a further 6 months for consideration for future volunteering opportunities.

At the end of the retention period we will delete or destroy your personal information except where we need to keep it to comply with our legal obligations, resolve ongoing disputes or defend ourselves against future legal claims, or enforce our agreements.

We may continue to use data without further notice to you to help us ensure the fairness of our services and activities. If we do this, we will anonymise the data first so that you cannot be identified as being associated with it.

  1. Your Rights

You have certain rights in relation to your personal information. If you wish to exercise any of the following rights, please contact foundation@tottenhamhotspur.com.

  • Right of access. You have the right to access the data that we hold on you. We provide you with access to as much of your personal information as possible on our electronic system Waves. However, if you require access to other information, you should make a subject access request in writing.

 

  • Right to rectification. You can request that we update any of your personal information, which is out of date or incorrect. We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

 

  • Right to erasure: In some circumstances you can ask for your personal information to be deleted. You should be aware however that this is not an absolute right and there are situations where legally, we will not be able to comply with your request. If we cannot comply with your request, we will clearly explain our reasons.

 

  • Right to object. You can object to our processing of your personal information where we do so in our legitimate interests or in the public interests. If you do object, you should provide specific reasons why you are objecting to the processing of your data. You should be aware that this is not an absolute right, and we can continue processing if we can demonstrate compelling legitimate grounds for the processing or if the processing is for the establishment, exercise or defence of legal claims. If we cannot comply with your request, we will clearly explain our reasons.

 

  • Right to restrict processing. In some circumstances, you have the right to ask us to restrict the processing of your personal data. This may be because you have issues with the content or accuracy of the information we hold and want us to restrict processing whilst these issues are addressed. Alternatively, it could be because you have objected to our processing of your data for the purposes of our legitimate interests, and you want us to restrict processing whilst we considering our response. Where we comply with these requests, we will always inform you before lifting the restriction.

 

  • Consent withdrawal. Where you have given clear consent for us to process your personal data for a specific purpose, you have the right to withdraw your consent at any time.

 

  1. Changes to this policy

As our work at the Foundation develops in the future, it may be necessary for this Privacy Policy to change with it. We reserve the right to amend this Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy on our websites. We will let you know, however, if any of these changes are likely to affect you materially. You should check our website from time to time for any changes to the Privacy Policy.

  1. More information and complaints

If you have any questions or require further information, please contact us by emailing: foundation.personaldata@tottenhamhotspur.com.

If you are not satisfied with how we have handled your query or your personal data in general, you can contact the Foundation's Protection Officer by emailing: foundation.personaldata@tottenhamhotspur.com.

Or, if you are not satisfied with how the Data Protection Officer has handled your query or your complaint, you can contact the Information Commissioner’s Office in any of the following ways:

  • In writing: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
  • By phone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
  • By email: casework@ico.org.uk. 
  • On line: ico.org.uk