April 2024

Hinksey Heights Golf Club respects your privacy. Your personal data is protected in the UK by the General Data Protection Regulation. Under the General Data Protection Regulation, we have a legal duty to protect any information we collect from you. Any information that you give us is held with the utmost care and security. We will only process it where there is a lawful basis to do so. We do not and will not pass on your details to any third party or government department unless you give us permission to do so or as otherwise required by law.

POLICY INFORMATION

This policy applies to:

- All customers of Hinksey Heights Golf Club
- Members of Hinksey Heights Golf Club
- All sites under the control of Hinksey Heights Golf Club
- All staff operating on behalf of Hinksey Heights Golf Club

Hinksey Heights Golf Club will use its best endeavours to ensure that staff and contractors of the clubs adhere to this policy at all times.

INTRODUCTION

The purpose of this policy is to enable Hinksey Heights Golf Club to:

- Comply with the law in respect of the data it holds about individuals
- Protect the personal data of Hinksey Heights Golf Club members and visitors

The data protection principles require that personal information is:

- Processed fairly and lawfully
- Processed for limited purposes
- Adequate, relevant and not excessive
- Accurate and up to date
- Not kept for longer than is necessary
- Processed in line with the rights of individuals
- Secure
- Not transferred to countries outside the EEA without adequate protection

This policy applies to information relating to identifiable individuals.

WEBSITE:

WHAT INFORMATION IS COLLECTED?

Hinksey Heights Golf Club collects information relating to website users in various ways including directly from the user and by using technical means such as cookies.

User-supplied information: when you register with us, we may ask you for your name, e-mail address, and other similar information. Any information supplied by the user is supplied voluntarily unless otherwise stated. If you do not want us to hold information about you, please do not supply it to us; this may mean, however, that we are not able to respond to your requests.

OTHER INFORMATION (COOKIES):

We use Google Analytics to research user activities on our website in order to enhance its performance and usability. In the course of conducting this research Google places a First Party session ‘cookie’ on your browser and collects aggregate information. The cookie is a small amount of information recording details of your visit to our website but does not identify you. Aggregate information is used to show us the total number of visits to our website and which parts of the site are used the most. It does not identify individuals, as it does not contain any personal data. This information helps us to develop our website and initiate improvements to the services. If you would prefer, you can set your browser to disable cookies. Information on how to disable cookies can be obtained by referring to either your Operating Systems Manual or your Browser Guide, or by contacting your Internet Service Provider. You should be aware that if you disable cookies our website may not perform as it was intended. If you have any questions or concerns regarding this cookie policy please contact us.

In order to help you access and use the site as efficiently as possible, the company may use cookies to store and record your use of the site. Cookies are technical files that are sent to your browser and stored on your computer. Use of cookies is standard in many web sites. Most browsers are initially set up to accept cookies. You can reset your browser settings either to notify you when you receive a cookie, or to refuse to accept cookies. You should understand that certain areas of the site may not function properly if you set your browser to not accept cookies or if you reject a cookie.

You can inform us at any time if you no longer wish to receive our marketing communications. We provide links to automatically opt out in our email communications to you.

APPLICABLE LAW:

This Website is created and controlled by Hinksey Heights Golf Club and is subject to the laws of England & Wales and subject to the jurisdiction of the English courts. Hinksey Heights Golf Club reserves the right to make changes to the site and this privacy statement from time to time.

POLICY STATEMENT

Hinksey Heights Golf Club will:

- Comply with both the law and good practice
- Respect individuals’ rights
- Be open and honest with individuals whose data is held
- Provide training and support for staff who handle personal data, so that they can act confidently and consistently

Responsibilities

Hinksey Heights Golf Club recognises its overall responsibility for ensuring that it complies with its legal obligations.

The Data Protection Officer (DPO) is the person with the following responsibilities:

- Briefing Hinksey Heights Golf Club on data protection responsibilities
- Reviewing data protection and related policies
- Advising other staff on data protection issues
- Handling subject access requests and other requests by users in relation to their rights including receiving any complaints
- Security

This section of the policy only addresses security issues relating to personal data. It does not cover security of the building, business continuity or any other aspect of security.

Data Recording and Storage

Hinksey Heights Golf Club will regularly review its procedures for ensuring that its records remain accurate and consistent and, in particular:

- Our IT systems will be designed, where possible, to encourage and facilitate the entry of accurate data
- Data on any individual will be held in as few places as necessary and the holding of unauthorised or unofficial data sets is against company policy
- Effective procedures will be in place so that all relevant systems are updated when information about any individual changes
- Members' data held will be released to other members in order to facilitate the golfing activities of the club. This will only be mobile and/or email for contact/communication. By entering any competitions you are deemed to have given permission for essential data such as your telephone number to be released to another relevant member or members. This permission may be withdrawn at any time by the member in notifying in writing to the club secretary at any time or by indicating this on the Club’s competition entry form(s)
- Members’ data will also be shared with CONGU via Club handicap systems, to facilitate monitoring of handicaps

Further details of this are contained in the privacy statement contained below.

CCTV

Hinksey Heights Golf Club has:

- Installed a CCTV system which produces clear images which the law enforcement bodies can use to investigate crime and these can easily be taken from the system when required
- Sited cameras so that they provide clear images
- Positioned the cameras to avoid capturing images of persons not visiting the premises
- Sited monitors in a position that provides the staff with the security required whilst restricting as far as is practical the ability of the public to see them
- Placed visible signs showing that CCTV is in operation

A limited number of authorised persons that may access the recorded images from the CCTV system, which are securely stored. The recorded images are held for 28 days and with the exception of law enforcement bodies, images will not be provided to third parties.

POLICY REVIEW

The policy is to be reviewed on an annual basis or at such time that the Data Protection legislation is amended.

PRIVACY STATEMENT

When you request information from Hinksey Heights Golf Club, sign up to any of our services or buy things from us, Hinksey Heights Golf Club obtains information about you. This statement explains how we look after that information and what we do with it.

We have a legal duty under the General Data Protection Regulation to prevent your information falling into the wrong hands. We must also ensure that the data we hold is accurate, adequate, relevant and not excessive.

Member’s email address and/or telephone numbers may be given to other current members of the club for the purposes of facilitating activities pertaining to the club, where the information is not currently available on the member’s directory via the club website.  Furthermore, Members’ data will also be shared with CONGU via Club handicap systems, to facilitate monitoring of handicaps

Whenever we collect information from you, we will make it clear which information is required in order to provide you with the information, service or goods you need. You do not have to provide us with any additional information unless you choose to, but if you do not provide it we may not be able to provide you with the information, service or goods you have requested. We store your information securely on our computer system, we restrict access to those who have a need to know, and we train our staff in handling the information securely.

If you are a Club Member, we will contact you from time to time with membership related communications.  We will not send you any marketing offers unless you have specifically opted in to receiving these.   If you have opted in, you can opt out any time.

The lawful basis for us processing your personal data will be:

- performance and fulfilment of our contract in the case of the provision of information, goods or services
- legitimate interest in relation to information and communications relevant to your membership and related matters
- your consent, where you have provided it, in relation to any other marketing

You have the right to a copy of all the information we hold about you (apart from a very few things which we may be obliged to withhold because they concern other people as well as you). To obtain a copy, please write to the Data Protection Officer (DPO) at Hinksey Heights Golf Club admin@oxford-golf.co.uk.

Hinksey Heights Golf Club reserves the right to charge you for a copy of your data (as permitted by law). We aim to reply as promptly as we can and, in any case, within the legal maximum of 30 days.  Hinksey Heights Golf Club is the trading name of Hinksey Heights Golf Limited, a company registered in England with company no. 13062420 whose registered office is at Hinksey Heights, South Hinksey, Oxford, OX1 5AB.

You can contact us in relation to this Policy and your personal data:

By mail to the registered office address

by email to admin@oxford-golf.co.uk.

The UK regulator for data protection is the Information Commissioner and you can find their details at www.ico.org.uk , but please contact us in the first instance.