1. CONTENT OF THIS PRIVACY NOTICE
- What personal information do we collect about you
- How we use this information and what is the legal basis for this us
- Direct Marketing
- What information do we receive from third parties
- With whom do we share this information
- International data transfer
- What rights do you have
- How long we will retain your data
- How do you get in touch with us
- Subject Access Request
- Changes to this privacy notice
2.1 The purpose of this Privacy Notice is to give you a better understanding of:
- what information we collect;
- how we use that information;
- how this information is shared;
- your data protection rights; and
- other useful privacy and security related matters;
and this Privacy Notice applies to you if you are a beneficiary or supporter of the RFU Injured Players Foundation ("the IPF") who has contacted us in relation to any of the following:
- to make a donation to the IPF
- to take part in a fundraising or awareness raising event on behalf of the IPF
- to supply details in relation to a rugby injury sustained by yourself or someone else
- to seek funding and/or welfare support
- to purchase something from us
- to receive updates about upcoming events, offers and ways to get involved further with the IPF,
or we have contacted you for these reasons.
2.3 The RFU Regulatory and Governance Privacy Notice may also apply if you are a participant in rugby in England, including players, coaches, agents, referees, representatives of clubs/schools/colleges/universities/constituent bodies/ representative bodies (including members, officials and owners), spectators, parents, volunteers and/or such other individuals who may be under the jurisdiction of the RFU or those whose details we require to perform regulatory functions.
2.4 You can find additional information about privacy and your rights on the Information Commissioner's website.
2.5 References to we, our or us in this privacy notice are to the RFU Injured Players Foundation, (also referred to as "the IPF"), a charity registered in England under Charity No. 1122139 and whose registered office is at Rugby House, 200 Whitton Road, Twickenham, TW2 7BA and any subsidiaries or group companies, including IPF Trading Limited.
2.6 References to 'you' or 'your' in this privacy notice are to you in your personal capacity as an individual and/or in your capacity as a representative for a third party (such as a club/school/college/university representative).
2.7 The RFU has appointed a Data Protection Officer and such individual shall also act as the IPF's Data Protection Officer, tasked with overseeing our compliance with data protection laws.
2.8 This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of the IPF's collection and use of personal information. However, we are happy to provide any additional information or explanation needed.
2.9 Should you wish to contact us in relation to this Privacy Notice, our contact details are set out in the "How do you get in touch with us?" section at the end of this Privacy Notice.
3. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
3.1 We may collect, store and process the following personal information about you, whether you are an adult or a child:
- your name, username and password;
- your gender;
- your age/date of birth;
- your home address, email address and phone number;
- information about how and when your rugby injury occurred, such as, date of injury, description of circumstances of injury, information about the type of injury, information about support provided to date;
- details of your next of kin, family members or emergency contacts;
- your name and contact number if you are reporting a rugby injury sustained by you or someone else;
- your detailed medical history, diagnosis, treatment plans, and relevant personal circumstances if you have sustained a reported rugby injury, providing you have consented to us accessing this information;
- your personal and financial information if you apply for a grant through the IPF;
- your recollections about your injury and the circumstances of how this was sustained;
- your payment and delivery details, including billing and delivery addresses and credit card details, where you make purchases from us or to donate to us (all through our 3rd party agents);
- information about donations you have made to us (value and quantity), and donations you have scheduled to make to us (including regular donations by direct debit/standing order);
- your CAF Account information if you make a donation to the IPF using CAF;
- if you are a UK Tax Payer (yes or no) for Gift Aid purposes, providing you have submitted this information directly to us;
- information about any fundraising you have undertaken for us, including events you have taken part in with the IPF or plan to take part in with the IPF in future;
- your preferences for volunteering with the IPF;
- your employment status, if you submit this as part of any fundraising event application;
- your running vest or t-shirt size, if you submit this as part of any fundraising event application;
- information about injuries sustained in relation to future involvement in fundraising events involving physical activity, such as but not limited to, running, cycling, and other charity events;
- your marketing preferences, including any consents you have given us;
- your social media account names and/or handles;
- the products you have purchased from us;
- your rugby activity such as your role, club affiliation, and courses undertaken;
- which emails you have received, opened and clicked on;
- how you have reached our digital platforms and the internet protocol (IP) address you have used;
- your device, browser type, versions and plug-ins, and your operating system;
- your journey through our digital platforms, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information;
- which videos you have watched and for how long;
- what content you like or share;
- which adverts you viewed and responded to;
- which pop-up or push messages you have seen and responded to;
- information collected in any forms you complete;
- your responses to customer surveys (where you have given us permission to do so);
- other information obtained through electronic means;
- records of your attendance at any events or competitions hosted by us;
- images in video and/or photographic form and voice recordings;
- if you are a Trustee of the IPF, or applying to be a Trustee, your background information relating to other trustee work or directorships, providing you have submitted this to us;
- and if you are a volunteer or applying for a specified volunteer role, your background information relating to related work and safeguarding checks including DBS checks and information relating to criminal convictions, providing you have submitted this to us.
4. HOW DO WE USE THIS INFORMATION, AND WHAT IS THE LEGAL BASIS FOR THIS USE?
4.1 The IPF uses your personal data to:
- respond to your enquiry;
- determine eligibility for charitable support;
- provide appropriate welfare or financial assistance to you, your family members or other relevant parties in response to a rugby injury being reported;
- conduct injury prevention and management research projects (if you have given your explicit consent for your data to be used in this way);
- acknowledge any contribution that you may make;
- process any donations you make;
- claim Gift Aid on donations made by you (if applicable);
- reserve event places or other fundraising opportunities if specifically requested by you;
- administer any volunteering opportunities if specifically requested by you;
- administer any relevant competitions or prize draws;
- send information to you about the IPF and its activities more generally;
- fulfil any contract that we may enter into with you;
- conduct research;
- send marketing information to you in ways set out in this Privacy Notice;
- to track your activity on our digital platforms;
- to create an individual profile for you so that we can understand and respect your preferences;
- to personalise and improve your experience on our digital platforms;
- to personalise and/or tailor any communications that we may send you;
- for profiling purposes to enable us to personalise and/or tailor any marketing communications that you may consent to receive from us;
- to personalise digital advertisements to you on 3rd party platforms;
- or other reasonable purposes for which you have provided such information.;
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. For the purposes of this policy, please note that the purposes and lawful basis set out below apply equally if you are a child or an adult.
|Purpose||Personal information used||Lawful basis|
|To respond to a reported injury||All personal and contact information as submitted on an injury report form including date of injury, type of injury and current status following injury.||This is necessary to enable us to gather all the information required to determine if we are able to offer support to an injured player and to make contact with them or their next of kin, rugby club or the person who reported the injury.|
|To offer financial and/or welfare support to an injured player, their next of kin or their rugby club||All personal and contact information as submitted on an injury report form plus information from medical records. Bank details of funding recipients.||This is necessary to enable us to determine what support would be most beneficial to an injured player and to provide charitable support.|
|To refer an injured player to third party providers for specialist support||All personal and contact information as submitted on an injury report form plus information from medical records (if consent given)||This is necessary to enable us to instruct any third parties or specialist care providers with the information needed to deliver their services to an injured player, such as but not limited to physiotherapy, vocational rehabilitation, or the provision of aids and adaptations.|
|To arrange volunteer support visits for injured players||Injured player contact details and summary of their personal circumstances (Date of injury, club, level of injury, functional capability and personal well-being) Volunteer personal and contact details.||This is necessary to provide volunteer delivered welfare support to injured players so that we and they can understand and respect your preferences and to organise and administer volunteer visits and support.|
|To undertake injury prevention research||Injured players' personal recollections of the circumstances of their rugby injury. Medical information and records. Contact details of injured player.||This is necessary to enable us to properly administer and undertake injury prevention research to prevent other players from sustaining injuries in rugby union. We process special category personal data on the basis of the "special category reasons for processing of your personal data" referred to below.|
|To process a donation, reclaim Gift Aid on a donation||All contact and personal details associated with processing donations. UK Tax Payer Status of donors wishing the IPF to claim Gift Aid for their donation. Transaction and payment information.||This is necessary to enable us to properly process and record donations and to enable us to claim Gift Aid through HMRC.|
|To respond to fundraising enquiries and to support fundraisers and volunteers who choose to raise money for the IPF||All contact details needed to stay in touch with fundraisers and volunteers||This is necessary to enable us to respond to fundraising enquiries we receive, and to maintain contact with fundraisers and volunteers to support their fundraising for the IPF|
|To allocate event places to fundraisers from application forms||All personal and contact details, plus Twitter "handle" (account name), occupation, job title, name of employer, description of event/activity applying to take part in, club information, running vest/t-shirt size, how they plan to fundraise (if a fundraising target needs to be reached as part of obtaining an event place), how they found out about the IPF, whether they belong to any other organisations, agreement to term of conditions (specific to each event)||This is necessary to enable us to judge who the IPF can allocate its limited event places to in sought after events such as the London Marathon, Prudential Ride London 100 and other over-subscribed charity challenge events, based on ability to reach any fundraising targets tied to event places and each applicant's link to the IPF/reason for wanting to fundraise specifically for the IPF.|
|To confirm event participants with event organisers from IPF fundraisers and volunteers||All contact details needed to book event entries for fundraisers and volunteers with event organisers||This is necessary to enable us to secure event entries for fundraisers and volunteers in to events such as running events, cycling events or other challenge events. The IPF will submit participant name and contact details in order for the event organisers to begin the event registration process, with participants independently submitting any other details needed by the race organisers.|
|To arrange and manage any contracts for the provision of any merchandise, products and/or services.||All contact and personal details associated with fulfilling any request for merchandise, products or services. Transaction and payment information.||This is necessary to enable us to properly administer and perform any contract for the provision of merchandise, products and services.|
|To send you other marketing information we think you might find useful or which you have requested from us, including our news items, information about membership, the IPF, events, fundraising, how we use donations to fund our work, and other relevant information.||All contact details and marketing preferences.||Where you have given us your explicit consent to do so.|
|To answer your queries or complaints.||Contact details and records of your interactions with us.||We have a legitimate interest to provide complaint handling services to you in case there are any issues with your membership.|
|Retention of records.||All the personal information we collect.||We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage services or support offered to you and in some cases, we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the "special category reasons for processing of your personal data" referred to below. For criminal records history we process it on the basis of legal obligations or based on your explicit consent.|
|The security of our IT systems.||Your usage of our IT systems and online portals.||We have a legitimate interest to ensure that our IT systems are secure.|
|To conduct data analytics studies to better understand event attendance and trends within the sport.||Records of your attendance at any events or competitions hosted by us.||We have a legitimate interest in doing so to ensure that our membership is targeted and relevant.|
|For the purposes of promoting the IPF, our events fundraising activities.||Images in video and/or photographic form.||Where you have given us your explicit consent to do so (save for the capturing of large crowd scenes where personal images are incidental and it is not practicable to do so).|
|To comply with health and safety requirements.||Records of attendance.||We have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate in sport.|
4.2 In relation to the special category personal data that we do process we do so on the basis that:
- the processing is necessary for reasons of substantial public interest, on a lawful basis, or which are set out in Schedule 1, Part 2 of the Data Protection Act 2018 and include where processing is necessary for :
- the safeguarding of children and individuals at risk;
- a substantial public interest;
- based on our legal obligations;
- it is necessary for the establishment, exercise or defence of legal claims;
- it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
- based on your explicit consent (solely in relation to information from the disclosing and barring service which is disclosed by you).
5. DIRECT MARKETING
5.1 From time to time, we may contact you by email, post or SMS with information about products and services we believe you may be interested in.
5.2 We will only send marketing messages to you in accordance with the marketing preferences you set.
Withdrawing consent or otherwise objecting to direct marketing
6. WHAT INFORMATION DO WE RECEIVE FROM THIRD PARTIES?
6.1 We may receive information about you from third parties and in particular we may combine your information with other information that we obtain from our dealings with you or which we receive from other organisations, including information from constituent bodies, representative bodies, clubs, schools, colleges, universities, other sports, other rugby union governing bodies, other rugby stakeholders (such as the Rugby Players' Association, the Association of Rugby Agents, Premier Rugby Limited), and such other reputable third parties with whom we have relationships.
6.2 We may receive information about you from the RFU's group companies, subsidiaries or associated (joint venture) companies in which the RFU has an interest including: World Rugby, European Professional Clubs Rugby Limited, England Rugby Travel Limited, Twickenham Experience Limited, British & Irish Lions DAC, Six Nations Rugby Limited, , RFU Hotel Limited and RFU Health and Leisure Limited, as well as commercial entities more widely.
6.3 We may receive information about you from the rights owner(s) of event(s) you have attended at Twickenham Stadium (or other locations at which we operate), if we have been informed that you have provided the necessary consent.
6.4 We may receive information about you from medical professionals if you have sustained a rugby injury and/or from rugby club members or volunteers if they submit an injury report after you have sustained a rugby injury.
6.5 We may combine your information with other information that we obtain from our dealings with you or which we receive from other organisations. For example we may engage reputable third parties to analyse your information and supplement it with demographic and other statistical information which those third parties hold. By understanding more about you, we can then communicate with you in the most appropriate way and with the most relevant information.
7. WITH WHOM DO WE SHARE YOUR INFORMATION?
7.1 We share personal information with the following parties:
- Any party approved by you.
- Other service providers: for example, email marketing, market intelligence, market research, mail houses, print facilities, third party marketing platforms, merchandising services, payment processors, data analytics service providers, promotional advisors, contractors or suppliers and IT services (including Customer Relationship Management, website, video and teleconference services). This includes the Rugby Football Union and its group of companies who provide services to us.
- When someone visits IPF's digital platforms we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
- Injury reporting: We sometimes share injury report data with other relevant bodies or groups if an injured player is associated with them and it is in all parties' interests for them to be made aware of the injury report. For example, if an injured player is covered by another nation's rugby union/governing body. We also share anonymised injury data with relevant RFU Staff, RFU Constituent Bodies and RFU County officials, as well as the RFU Insurance providers, and IPF commissioned researchers where appropriate.
- Medical professionals or medical service providers where you have provided specific consent for this following a rugby injury. We do this to either provide you with appropriate medical support such as physiotherapy or occupational therapy, or if you have agreed to participate in medical research programmes involving the IPF.
- Volunteer Liaison Officers (VLOs) in order for them to be able to support specific injured players. We will obtain your consent to share any data with volunteers before doing so.
- Event organisers for the purposes of ensuring participation and complying with any event regulations.
- Where we are required to do so by law or to assist with investigations or initiatives.
- Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
- 7.2 We do not disclose personal information to anyone else except as set out above or in the RFU Regulatory and Governance Privacy Notice.
8. INTERNATIONAL DATA TRANSFER
The personal information we collect may be transferred to and stored in countries outside of the UK and the European Economic Area (EEA). Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We require third parties to respect the security of your data and to treat it in accordance with the law, and if we do share your personal information outside the UK or European Economic Area, you can expect a similar degree of protection in respect of your personal information.
9. WHAT RIGHTS DO YOU HAVE?
9.1 You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format. These rights may be limited, for example if fulfilling your request would reveal personal data about another person or if there is a legal or regulatory reason for not providing data, or if you ask us to delete information which we are required by law to keep or have legitimate interests in keeping. Further details on such limitations are set out in the RFU Regulatory and Governance Privacy Notice.
9.2 You have rights as an individual which you can exercise in relation to the information we hold about you. You can read more about these rights on the Information Commissioner's Office website https://ico.org.uk/.
9.3 To exercise any of these rights, you can get in touch with us - or the RFU's data protection officer who can answer on our behalf - using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This is the Information Commissioner's Office in the UK.
10. HOW LONG WILL WE RETAIN YOUR DATA?
10.2 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.
10.3 It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address. You can contact us by using the details set out in the "How do you get in touch with us?" section below.
11. HOW DO YOU GET IN TOUCH WITH US?
11.1 The IPF tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
11.2 The RFU manages any queries that you may have relating to your personal information on behalf of the IPF. Please note, when you request to access information held about you from the IPF, we will not be able to provide you with information which may be held about you separately by the RFU.
12. SUBJECT ACCESS REQUEST
13. CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice may be updated from time to time. The date of the most recent revisions will appear on the bottom of the page.
Last modified 15th March 2021.