THEPFA.COM – PRIVACY POLICY
THEPFA.COM – PRIVACY POLICY
The Professional Footballers’ Association of Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD and our associated companies (“we”, “PFA” “us”) are committed to protecting and respecting your privacy.
This policy together with our Website Terms of Use and Online Account Terms (and any other documents to which they refer or are otherwise referred to on our site) sets out the basis on which any personal data we collect from you (“you”, “your”), or that you provide to us, via our site www.thepfa.com (“our site”) will be processed by us in accordance with the General Data Protection Regulation (EU) 2016/679 – the “GDPR”, together with other UK data protection laws including the Data Protection Act 2018. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The data controller is the Professional Footballers’ Association of Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD. You can contact us in writing the above address, by telephone on 0161 236 0575 or via email at info@thepfa.co.uk. [We have appointed a data protection officer (DPO) to manage data protection matters at the PFA and to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO: Mr Philip Baylis, Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD, pbaylis@thepfa.co.uk. We are registered as a data controller with the Information Commissioner’s Office (ICO) under registration number Z6610183.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. This includes our PFA member privacy notice if you are a PFA member which is available on request from the DPO: Mr Philip Baylis, Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD, pbaylis@thepfa.co.uk.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
• If you are a PFA Member including playing and non-playing PFA members, information you provide when applying for the creation of an Online Account or submitting any other applications relating to your membership of the PFA via our site including personal contact details such as name, title, addresses, telephone numbers, personal email addresses, height, DOB, intermediary representation, ancestral history, nationality, place of birth, ethnicity, qualifications.
• Personal contact details that you provide by filling in any registration forms or applications on our site including in relation to Live Chat, the coaching directory, transfer lists, grant applications and communication preferences.
• Information (such as your name and email address) we may ask you to provide when you report a problem with our site such including in relation to Live Chat.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. We may collect the following categories of personal information if you complete a survey: name, title, addresses, telephone numbers, and personal email addresses.
• Details of your visits to our site including, but not limited to, traffic data, location data, IP addresses, weblogs and other communication data and cookies data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• If you contact us, we may also keep a record of that correspondence.
INFORMATION WE MAY COLLECT ABOUT YOU FROM OTHERS
If you are a PFA member and you apply for the creation of an Online Account or submit any other applications or information relating to your membership of the PFA via our site, we may contact third parties within the professional football domain (including, but not limited to, your current club, The Football Association, The Premier League, The English Football League, The National League and League Football Education) and request disclosure of any information which they may hold about you to enable us to verify any information which you provide to us via our site.
As part of the PFA’s services, we provide advice and support to our members who are charged by the Football Association for a breach of their regulations. Where you have consented, by ticking the relevant consent box(es) on our site or by us contacting you to gain consent, you give your permission for the PFA to be notified by the Football Association of the breach. We will then contact you to offer advice, support and representation. This information will be kept strictly confidential by the PFA.
IP ADDRESSES
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
COOKIES
Our site uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
WHERE WE STORE YOUR PERSONAL DATA
We (and our associated companies such as PFA Enterprises Limited) will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
USES MADE OF THE INFORMATION
We are committed to protecting and respecting your privacy and, subject to the below, will not pass your personal details to third parties for the purpose of direct marketing by them.
However, we may use information you have provided via our site and/or that we hold about you 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 allow you to participate in interactive features of our service, when you choose to do so.
• To deliver targeted content to you whilst you are browsing our site.
• To notify you about changes to our service.
Our lawful basis for the activities above is necessity for our legitimate interests of running the PFA website, studying how website users use our products/services and the provision of IT administration and services.
• To carry out our obligations or to provide services arising from any contracts entered into between you and us, including services provided as part of your PFA membership (if you are a PFA member).
Our lawful basis for these activities is necessity to perform any contractual relationship with you and in all other circumstances the pursuit of our legitimate interests of providing PFA members with PFA membership services.
If you are member of the PFA (or have applied for membership) we may also use the information you have provided via our site and/or that we hold about you in the following ways:
• If you apply for the creation of an Online Account or submit any other applications or information relating to your membership of the PFA via our site, to process, record and maintain details of your application(s) and/or membership and to contact you in connection with your application(s) and/or membership.
• To contact you with information relating to products or services of PFA business partners which we feel may interest you, where you have consented to be contacted for such purposes. If you agree to us using your information in this way, please tick the relevant consent box(es) on our site. Please note that all information relating to products or services of our business partners will be communicated to you via the PFA and not directly by our business partners.
• To deliver targeted content to you whilst you are browsing our site. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, those over the age of 35 or those affiliated to a particular football league). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
Our lawful basis for these activities is necessity to perform any contractual relationship with you and in all other circumstances the pursuit of our legitimate interests of providing PFA members with PFA membership services.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES:
We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our site’s Terms of Use and Online Account Terms and other agreements, or to protect the rights, property, or safety of the PFA, our members, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may share your personal information with the following third parties and for the following purposes:
• Microsoft Azure – IT hosting services.
• Mailchimp – distributing emails to members.
• Codeminders – IT services.
• EveryMessage – SMS delivery platform.
• Google Analytics – website analytics.
• Apple – IT services.
• Your current club, The Football Association, The Premier League, The English Football League, The National League and League Football Education – in relation to providing you with PFA membership services and in relation to transfer lists and coaching directory requests.
We may also share your personal information with other entities connected to the PFA including PFA Enterprises Limited and The Professional Footballers’ Association Charity in relation to your membership.
We will not transfer your data outside the European Union without first notifying you of our intentions and of the safeguards that apply to your data. If you are member of the PFA (or have applied for membership) we may disclose your personal information to the third parties listed in our PFA Member privacy notice or transfer information outside of the European Union as set out in this notice. A copy of the PFA Member privacy notice is available on request from the DPO: Mr Philip Baylis, Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD, pbaylis@thepfa.co.uk.
UNSUBSCRIBING FROM EMAILS
We will provide information on how you can unsubscribe from further email communications at the bottom of every email that we send you.
DATA RETENTION
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available from the DPO: Mr Philip Baylis, Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD, pbaylis@thepfa.co.uk.
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 information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
AUTOMATED DECISION MAKING
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
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.
YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting the DPO: Mr Philip Baylis, Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD, pbaylis@thepfa.co.uk.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes (for example, email marketing or phone calls).
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Object to any automated decision-making about you which produces legal effects or otherwise significantly affects you.
• 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.
Please be aware that these rights are subject to certain conditions and exceptions as set out in UK data protection law. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO: Mr Philip Baylis, Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD, pbaylis@thepfa.co.uk, in writing and they will explain any conditions that may apply.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the DPO: Mr Philip Baylis, Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD, pbaylis@thepfa.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Further guidance on your rights is available from the UK’s supervisory office for data protection, the Information Commissioner’s Office (https://.ico.org.uk/). You have the right to complain to the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully.
ACCESS TO INFORMATION
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try 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.
INFORMATION RELATING TO THIRD PARTIES
You should not provide any information relating to any other person, without first providing that person with a copy of this policy, informing them that they will be bound by this policy and obtaining their prior written consent to you submitting such information on their behalf.
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our DPO: Mr Philip Baylis, Floor 5, Lincoln Building, Brazennose Street, Manchester, M2 5AD, pbaylis@thepfa.co.uk.