Data Protection Policy For Community Rugby Clubs
The Data Protection Act 1998 (DPA) places certain obligations on organisations which process personal data. This includes community rugby clubs, who may hold information on players, members, employees, volunteers and contractors. In particular, it regulates how an individual's personal information should be used and protects people from misuse of their personal details.
The definition of personal data is wide; it covers any information through which a living individual is identifiable. It will include name, address, date of birth and so on. The definition of processing is also quite wide and it covers almost anything you might do with personal data including organising, adapting, amending, retrieving, consulting, using, disclosing, erasing, destroying and storing it.
The details of the DPA are quite complex, but it consists of three main elements:
- Notification – each organisation processing personal data must, subject to certain exemptions, register with the Information Commissioner each year.
- Data Protection Principles – each organisation processing personal data must comply with the eight data protection principles:
- fairly and lawfully processed;
- processed for limited purposes;
- adequate, relevant and not excessive;
- not kept longer than necessary;
- processed in accordance with your rights;
- kept secure; and
- not transferred abroad without adequate protection.
- Data Subject Rights – individuals have rights principally the right of access to data held about them.
To help clubs navigate through this complex issue, the RFU has produced Guidance for Community Rugby Clubs on the Data Protection Act (MS Word DOC 46kB), and a Sample Community Rugby Club Data Protection Policy (MS Word DOC 34kB).
A working example of how a club has integrated data protection into their daily operations is provided by Nottingham Moderns' Data Protection Policy (MS Word DOC 77kB).
In addition, it is important for the RFUW that they keep a record of all clubs personal contact details for membership and insurance purposes as well as updating clubs about RFUW related news and information. To aid this process the RFUW have produced a Club Communication & Data Protection Details (MS Word DOC 42kB) form which should be filled in and send back to the relevant party accordingly.