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Season Ticket Holder Data Protection & Privacy
Season Ticket Holder Photography & Filming Policy
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DATA PROTECTION & PRIVACY
Carnoustie Golf Links – Season Ticket Holders Privacy Notice
Data Controller: Head of Customer Experience
Carnoustie Golf Links collects and processes personal data relating to our Season Ticket Holders (STH’s) to manage the Season Ticket relationship. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
What information does Carnoustie Golf Links collect?
Carnoustie Golf Links collects and processes a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number, date of birth and gender;
- the terms and conditions of your Season Ticket agreement, including your Season Ticket status and ticket type;
- bank details required for Season Ticket payments;
- information about your emergency contacts;
- information relating to your booking details and events attendance;
- details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
- information about medical or health conditions, if this is a requirement requested for Season Ticket pause;
- and photography or film footage of you at Carnoustie Golf Links taken for business purposes – please refer to our Photography and Filming Policy for more information.
Carnoustie Golf Links collects this information in a variety of ways. For example, data is collected through Season Ticket agreement documentation; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during Season Ticket; from correspondence with you; or through interviews or other meetings.
Data is stored in a range of different places, including in your STH personal file, in Carnoustie Golf Links’ booking management systems and in other IT systems (including Carnoustie Golf Links’ MailChimp and SurveyMonkey systems and STH area of the Company website).
Why does Carnoustie Golf Links process personal data?
Carnoustie Golf Links needs to process data to enter into a Season Ticket agreement with you to meet our obligations within the contract. For example, we need to process your data to provide you with a Season Ticket, to process your booking requests in accordance with your Season Ticket agreement and to administer STH benefits, etc. In some cases, Carnoustie Golf Links has a legitimate interest in processing personal data before, during and after the end of the Season Ticket relationship. Processing Season Ticket Holder data allows Carnoustie Golf Links to:
- manage and maintain the STH ballot;
- run STH events and tournaments;
- communicate with our STH’s in variety of formats including telephone, email and publication;
- operate and keep a record of investigation and disciplinary processes, to ensure acceptable conduct; and
- ensure STH’s are complying with relevant policies and procedures
Some special categories of personal data, such as information about health or medical conditions, is processed to support STH’s with a specific request to support their needs or to pause their Season Ticket.
Who has access to data?
Your information will be shared internally amongst the Departments who require access to Links CC as part of their daily duties – only if access to the data is necessary for performance of their roles. Your data may also be shared with other STH’s when the ballot information is shared via the Carnoustie Golf Links website. STH’s can view STH numbers and surnames only. This information is not accessible by anybody who is not a Carnoustie Golf Links STH.
How does Carnoustie Golf Links protect data?
Carnoustie Golf Links takes the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the performance of their duties. Please also refer to our standard Privacy Policy.
Where Carnoustie Golf Links engages third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
For how long does Carnoustie Golf Links keep data?
Carnoustie Golf Links will hold your personal data for the duration of your Season Ticket. The periods for which your data is held after the end of your Season Ticket are detailed below:
- Name: 4 years after having cancelled Season Ticket.*
- DOB: 4 years after having cancelled Season Ticket.*
- Postal Address and Email Address: 4 years after having cancelled Season Ticket. After 4 years, data is anonymised to only keep town & post code information which is kept indefinitely for analytical purposes only. *
- Previous Address & Previous Email: 4 years after having cancelled Season Ticket.*
- Telephone, Email: 4 years after having cancelled Season Ticket.*
- Gender, Emergency Contact & Bank Details: 1 year after having cancelled Season Ticket to support any ongoing queries.*
- Booking Records, Season Ticket Status & Type: 4 years after having cancelled Season Ticket. *
- Proof of Age, Address or Medical Information: Securely destroyed or deleted as soon as cancellation approved.
- Season Ticket Agreement and Investigation/Disciplinary History: 4 years after having cancelled Season Ticket.*
- Events Attendance Data: 1 year after event or having cancelled Season Ticket (whichever is sooner).
- Ballot Data on Website: removed from our website the day after play.
*unless and investigation or disciplinary process has concluded with the Season Ticket Holder being banned or still having outstanding issues on their account. In which case, this information will be retained indefinitely in order to manage potential Season Ticket requests for the same individual in the future.
Should you have any queries on specific retention periods, please liaise with the Head of Customer Experience.
Your rights
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require Carnoustie Golf Links to change incorrect or incomplete data;
- require Carnoustie Golf Links to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where Carnoustie Golf Links is relying on its legitimate interests as the legal ground for processing;
- and ask Carnoustie Golf Links to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Carnoustie Golf Links’ legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact the Data Controller. You can make a subject access request by completing Carnoustie Golf Links’ form for making a subject access request. Further details on how to do this can be provided by e-mailing [email protected]. If you believe that Carnoustie Golf Links has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You have some obligations under your Season Ticket agreement to provide Carnoustie Golf Links with data. Without certain information, Carnoustie Golf Links would be unable to proceed with your Season Ticket agreement.
(This Privacy Notice was last updated in January 2024)
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PHOTOGRAPHY & FILMING
Carnoustie Golf Links – Photography & Filming Policy
This policy statement applies to all Season Ticket Holders of Carnoustie Golf Links, hereon referred to as ‘CGL’ throughout this policy.
Carnoustie Golf Links will, on occasion, take photographs and videos as an aid to routine business operations including, but not limited to, capturing memories from events and marketing/PR opportunities. When this is the case, Season Ticket Holders will be informed in advance via email or by printed notices at or near the location. At this time, you will have the opportunity to advise the team if you would like to be excluded from any filming or photography taking place.
The following document sets out how Carnoustie Golf Links use photography and videography to carry out its day to day business activities.
Purpose:
There may be times when you are either the object of a CGL photograph/film, or at least it is possible that you might be visible on said photograph/film. The purpose of this policy statement is to:
- protect Season Ticket Holders (STHs) who take part in CGL services, events and activities, specifically those where photographs and videos may be taken
- set out the overarching principles that guide our approach to photographs/videos being taken of STHs during our events and activities
- to ensure that we operate in line with our values and within the law when creating, using and sharing images of STHs.
Please note that any historical photography/filming prior to the introduction of this Policy were taken with verbal consent from the STH. This Policy is a formalisation of such consent.
For the avoidance of doubt, photography/filming shall mean any image, video, audio or other recording stored in or on any optical storage medium, magnetic storage medium, electronic memory, or any tangible medium of expression, as currently exists or which becomes available in the future.
Legal Framework
This policy and consent form is written in compliance with the Data Protection Act 2018 and in direct conjunction with our Season Ticket Holder Privacy Notice and our standard Privacy Policy.
We recognise that:
- sharing photographs and films of our activities can help us celebrate the successes and achievements of our business and STHs, provide a record of our activities and raise awareness of our organisation
- the welfare of the STH taking part in our activities is paramount
- STHs have a right to decide whether their images are taken and how these may be used, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation
- consent to take images is only meaningful when the individual understands how the images will be used and stored
Photography and/or filming for CGL use:
- We recognise that CGL may use photography and filming as an aid to routine business operations including, but not limited to, capturing memories from events, marketing opportunities etc. This should only be done with CGL’s permission and using our equipment, or by hiring in an approved external photographer
- CGL reserve the right to copy, modify and reproduce images for business purposes
- You would agree to waive any claims to compensation or royalties for the use of these images
If we hire a photographer for any content, we will seek to remain GDPR compliant by:
- providing the photographer with a clear brief about appropriate content and behaviour
- reporting concerns regarding inappropriate or intrusive photography
Photography and/or filming for wider use:
There will be occasions where people such as, but not limited to, journalists or photographers (not hired by CGL), wish to record photography/filming and share them professionally or in the wider world. If you do not wish to appear in such photographs/film, please either avoid the area in which photography/filming is taking place or tell the photographer so that they can take the appropriate steps to ensure you are not captured.
If consent to take photos or filming is not given:
If you do not consent to photographs being taken, we will respect your wishes. We will agree in advance how you would like to be identified so the photographer knows not to take pictures of you. Should you give consent but wish to revoke it in the future, you may do so by submitting a request in writing to the Head of Customer Experience.
Your rights
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require CGL to change incorrect or incomplete data;
- require CGL to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where CGL is relying on its legitimate interests as the legal ground for processing;
- and ask CGL to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override CGL legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact the Head of Customer Experience.
You can make a subject access request by completing CGL’s form for making a subject access request. This form is accessible by requesting a copy from a member of the Guest Relations team. If you believe that CGL has not complied with your data protection rights, you can complain to the Information Commissioner.
Storing images:
We will store photographs and videos of STH’s securely, in accordance with our Season Ticket Holder Privacy Notice and our standard Privacy Policy. We will keep hard copies of images in a locked drawer and electronic images in a protected folder with restricted access.
CGL may also share personal data with independent third-party companies that have been engaged for these purposes. CGL may also transfer my personal data to countries outside the European Economic Area (EEA), such as (but not limited to) the United States of America, which have different, and less protective data protection laws. But, where the latter is the case, CGL relies on admissible data transfer mechanisms, such as Standard Contractual Clauses, Binding Corporate Rules or the US recipient’s Privacy Shield certification, if any.
Images will be stored for an indefinite period for historical record, archiving and cataloguing purposes. We will never knowingly retain images on unencrypted portable equipment such as laptops and mobile phones. If any data is transferred via a mobile phone or portable device, it will be transferred onto the secured network and deleted from such device following conclusion of its purpose of use. Images which are taken for the purpose of a Season Ticket or event entrance identification will be removed from CGL systems in line with our Season Ticket Holder Privacy Notice.