Premier League Primary Stars

PRIVACY NOTICE

In this Privacy Policy, terms such as "we", "us, "our" or similar expressions shall mean the Premier League Charitable Fund (PLCF).

We take your privacy very seriously and are committed to protecting your personal data (meaning any information about you from which you can be identified). This Privacy policy explains what personal data we collect when you: access https://plprimarystars.com or contact or engage with the Premier League Primary Stars on social media platforms (including our Facebook, Twitter and Instagram pages) (the Services); and/or when you otherwise interact or communicate with us. It also explains how we may use this data, and what rights you have in relation to such data.

Premier League Primary Stars (PLPS) is funded and delivered by The Football Association Premier League Limited (PL) and the PLCF. The PL and PLCF aim to be transparent about the way we collect and process personal data. This website is managed by the PLCF.

If you have any questions about this Privacy Notice and our cookies policy, please contact our Data Protection Lead at the PLCF by emailing dataprotection@plcf.co.uk

1. WHO WE ARE

The PLCF is a charity that is committed to providing the best opportunities for people from all walks of life to develop their full potential, particularly through sport. It does this through a number of programmes that embrace one or more of the following themes: community cohesion, education, health and sports participation. It receives most of its funding from the PL. The information we collect may be used by either organisation in accordance with arrangements in our Data Sharing Agreement.

We are a "controller" under the General Data Protection Regulation (the GDPR) and other applicable data protection legislation (Data Protection Law). This means we are responsible for deciding how we use the personal data that we collect about you and, in accordance with the Data Protection Law, we will ensure that the personal data we hold about you is, at all times:

1.         used fairly, lawfully, and transparently;
2.         collected for limited, specific purposes only;
3.         adequate, relevant to and limited to what is necessary for those purposes;
4.         kept accurate and up-to-date;
5.         not kept for longer than is necessary; and
6.         held securely.

We shall be accountable for and able to demonstrate our compliance with our obligations under the Data Protection Law, and this Privacy policy is one of the ways in which we do that.

We have appointed a Data Protection Lead to oversee compliance with this Privacy policy and our data protection compliance activities.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

Personal data means any information about an individual from which that person can be identified. The types of personal data that the PLCF collects include:

Registration Data: To access and use some elements of the Services you must create a PLPS account, by providing us with the information which is identified on the relevant registration page: name, email, employment details and school. We will also collect a password. Please note that some elements of the Services will not be available if you do not provide the required information. We may also ask or allow you to submit other optional information, including your current interests and activities.
Contact Data: When we want to communicate with you, or you with us, we use your email address, telephone numbers, social media handles/ usernames and location (country/ place of residence).
Media Data: We use images from photographs and video footage of crowds and fans and other media content created by us (or on our behalf) at Premier League matches and events or provided by you for our use.
User Data: We collect your usage and preference details related to your use of the Services such as resources downloaded and videos viewed, survey responses, feedback and other data that you provide to us as part of your account.
Technical Data: Certain data is automatically generated and collected by us when you use the Services such as your IP address, MAC address and other device identifiers; your clickstream to, through and from the Services (including date and time); pages you viewed or searched for; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page.

For the purposes of the Services, we will never ask you for any special category data (race, ethnic origin, politics, religion, trade union membership, health, sex life or sexual orientation).

3. WHERE DO WE COLLECT INFORMATION FROM?

We collect information in the following ways:

Information you give us

The PLCF may obtain personal information from you when you register on the PLPS website which will include your name, email address and teaching role.

Information from Third Parties

We may supplement the information that you provide with other information that we obtain from our dealings with you (for example, through telephone conversations, e-mail correspondence or social media communications) or which we receive from other organisations, such as the Premier League and your local club community organisation.
We receive information from The Education Company Limited via their Spirit database look up. This database identifies all schools in England and Wales via a postcode search. We do not collect any personal information from this database.

Information we get from your use of our website

We collect information about the way you use our website to provide you with the services you require. We capture data relating to user activity of how you use the website which includes:
- Total number of classes created by teacher
- Total number of pupil accounts associated with teacher
- Number of packs created
- Number of packs saved
- Number of times logged in
- Time and date of last login
- Number and date of resources downloaded
- Number and date of videos viewed
- Number of competition entries
We capture data relating to teacher, pupil and parent/guardian registrations via the registration forms.

Information in the public domain

We obtain information from the Spirit Database (The Education Company Limited).

4. WHAT MIGHT WE DO WITH YOUR INFORMATION?

We will only use your personal data where Data Protection Law allows us to. Data Protection Law says we can collect and use personal data on the following bases:

1. it is necessary for us to be able to perform an agreement with you.
2. it is necessary for our legitimate interests (and your interests and fundamental rights do not override those interests);
3. if we have your consent (which you can withdraw at any time); or
4. to comply with a legal obligation i.e. rules laid down by courts, statute or regulation.

Accordingly, we lawfully use your personal data in the following ways:

Delivering the Services: We use the Registration Data so that we can deliver the Services to you in an effective, efficient and accurate way. Without it we would not be able to deliver a tailored service to you or respond to issues with these Services that are identified by us or you, or ensure you get the most out of your experience. Therefore, we use this data on the basis that it is necessary for us to be able to perform our agreement with you (i.e. the terms and conditions of the relevant Services) and for our legitimate interests of delivering the Services in this way.

Operating the Services: We use the Technical Data to operate and administer the Services including as necessary for testing, analysis, maintenance, support, reporting and hosting of data. Therefore, we use this data on the basis that it is necessary for our legitimate interests of operating the Services in this way. We also use Technical Data together with certain Identity Data and Contact Data to assist in security and fraud prevention, system integrity (such as preventing hacking, cheats and spam) and/ or to facilitate our response to a legal process. Therefore, we use this data on the basis that it is necessary both for our legitimate interests in protecting the Services in this way and in order that we can comply with a legal obligation.

Communication: We use the Contact Data to inform you of:

1. New PLPS resources, announcements and exciting opportunities. This is provided to you in a monthly newsletter sent directly to your email address.
2. Research opportunities. When the PLCF engage with researchers to test the impact of PLPS, researchers and organisations may email you directly for input into research design, methodology and evaluation.
3. Local football club community organisations. The PLCF may provide local football club community organisations with your details so they can contact you about their programmes and activities.

We give you the option of providing opt-in consent to receive the above communications from us or deciding not to do so.

The PLCF will never provide external organisations with these details without your consent. If you opt in to any of these, you can ask to be removed at any time by emailing plprimarystars@premierleague.com.

What if you do not want to share your personal data?

Unless otherwise specified above, generally we collect your personal data on a voluntary basis. However, please note that if you decline to provide certain mandatory personal data, you may not be able to access certain Services and we may be unable to fully respond to any inquiries you make.

5. HOW WE UPDATE YOUR INFORMATION

We continuously review our PLPS register to ensure your data is as accurate as possible and always appreciate it if you let us know if your details change.

6. WHO MIGHT WE SHARE YOUR INFORMATION WITH?

We are committed to protecting your data and therefore it will never be disclosed or sold to external organisations other than those acting as agents and data processors carrying out work on our behalf. Where we enter into a relationship with an external party, any such arrangements will be subject to a formal agreement between the PLCF and that organisation to protect the security of your data. They only act under our instructions and we maintain full responsibility for your data. The third-party suppliers which the PLCF engage for this PLPS are:

EdComs
EdComs administer this website on behalf of the PLCF and are the data processor.

The Education Company Limited
The Education Company Limited administer the Spirit database and information from registration contact details are shared with this database. The Education Company Limited are also the data processor.

Where a third-party supplier engages with an external organisation, we will ensure the third-party supplier is compliant with data protection laws. EdComs use the following organisations to provide marketing and mailing software:

Dotmailer – are used to provide email mailouts to registered users and recruitment emails to potential new users

Mandrill – are a transactional email platform from MailChimp and send automated emails to registered users.

7. HOW TO ACCESS, CORRECT OR DELETE YOUR INFORMATION

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email the Data Protection Lead at dataprotection@plcf.co.uk or write to us at Premier League Charitable Fund, 30 Gloucester Place, London W1U 8PL.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information that you think is inaccurate.

If you do not want to receive any further information about Premier League Primary Stars and would like us to remove your name from our mailing list, please contact us to let us know. Please address all your requests, by email or mail, to our Data Protection Lead. To help us locate any personal information about you (or in case we need to get in touch with you to obtain further information to help us locate your records) please include your full name, address and telephone number with your request.

8. HOW WE KEEP YOUR DATA SAFE

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed (a Data Security Breach). In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only use your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Data Security Breach and will notify you and any applicable regulator where we are legally required to do so.

Where we have given you or you have chosen a password which enables you to access certain Services, you are responsible for using reasonable care in keeping this password confidential.

9. HOW LONG WE STORE YOUR DATA FOR

We will hold your personal information on our systems for as long as is necessary for the relevant activity. If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us, we won’t keep any information that we don’t need.

10. CHANGES TO THIS NOTICE

We keep our privacy practices under review and may change this privacy policy from time to time by posting changes on the PLPS website or otherwise notifying them to you.

This Privacy Notice was last updated on 24 May 2018.

11. YOUR RIGHTS

Under Data Protection Law, you have certain rights (depending on the circumstances) in connection with your personal data, which include:

Request access to your personal data (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 using it lawfully, provided always that this does not adversely affect the rights and freedoms of other people;
Request correction of the personal data that we hold about you. Where any of the information we hold about you is incorrect or incomplete we will act promptly to rectify this, including where you have requested us to do so. Users of the Premier League Primary Stars website can update their information any time by emailing plprimarystars@premierleague.com;
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to use it. If you exercise your right to be forgotten, your personal details will be ‘hashed’ (deleted) but we will retain an anonymous record that a contact from that school had previously registered, for reporting purposes only. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to our use (see below);
Object to use of your personal data where we are relying on our legitimate interests (see above) and there is something about your particular situation which makes you want to object to our use on this ground;
Withdraw your consent to our use of your personal data where we do so in reliance on your consent. Once we have received notification that you have withdrawn your consent, we will no longer use your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law;
Request the restriction of use of your personal data. This enables you to ask us to suspend the use of personal data about you, for example if you want us to establish its accuracy or the reason for using it; and
Request the transfer of the personal data you have provided, on the basis of consent or for a contract with us, to you or a third party where technically feasible.

We are committed to respecting your rights. You may action your rights (as may be applicable) by contacting us using the details provided below and we will comply with your requests within a reasonable period unless we have a lawful reason not to do so.

Requests should be made in writing and to ensure that personal data is dealt with carefully and confidentially we will require the requestor to provide verification of their identity and all applications must be accompanied by copies of at least two official documents, which show your name, date of birth and current address (for example, driving licence, birth/ adoption certificate, passport, recent utility bill).

In responding to such requests, we will explain the impact of any objections, restrictions or deletions requested.

We will not charge you a fee to exercise your rights unless your request is clearly unfounded or excessive, in which case we may charge you a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK data protection authority. The ICO's contact details as are follows: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; Tel: 0303 123 1113 (local rate) or 01625 545 745; https://ico.org.uk/global/contact-us/

CONTACT US

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the following contact details:

PLCF Data Protection Lead
The Football Association Premier League Limited
30 Gloucester Place,
London, W1U 8PL

dataprotection@plcf.co.uk
(0)207 864 9000

COOKIES POLICY

In this Cookies Policy, any use of the words "you", "yours" or similar expressions shall mean any user of this website whatsoever. Terms such as "we", "us, "our" or similar expressions shall mean the Premier League Charitable Fund.

Cookies are small pieces of information that are stored by your browser on your computer’s hard drive and they are used to record how you navigate this website on each visit. Cookies identify your browser, and basic information that you have shared with Google to our servers when you visit our website. They do not identify you as an individual. If you do not want to accept cookies you can easily disable this function by changing the settings on your Internet browser.

HOW WE USE COOKIES

We use a type of cookie called Analytical/Performance Cookies. These allow us to recognise and count the number of users of our website and see how such users navigate through our website. This helps to improve how our website works, for example, by ensuring that users can find what they are looking for easily. The following table sets out a more detailed description of the cookies we use and their purpose:

Cookie Name: _ga, _gat

Description: These are third party cookies placed by Google that allow us to use the Google Analytics service.

Purpose: These cookies enable us to anonymously track how visitors access and browse our website, thereby enabling us to optimise and improve our service. Further information is available at:
www.google.co.uk/intl/en/analytics/privacyoverview.html

Cookie Name: PHPSESSID

Description: These manage your visit to our website.

Purpose: These cookies keep you logged in when using the site.

Cookie Name: New Relic

Purpose: This provides monitoring of server status for web and app use in real-time.

Cookie Name: JSESSIONID

Purpose: This is used to store a session identifier so that session counts can be monitored.

Cookies do not cause harm to your computer but if you do wish to stop your computer accepting cookies, navigate to the settings of your Internet browser.

CHANGES TO THIS COOKIES POLICY

Our policies and procedures are under continual review. We may, from time to time, update our cookies policy. Any such changes will be posted on this page.

CONTACT

Questions, comments and requests regarding this Cookie Policy should be addressed to dataprotection@plcf.co.uk or to the PLCF, 30 Gloucester Place, London, W1U 8PL.