PRIVACY POLICY POLISI PREIFATRWYDD

Last Updated: August 2026

At Inter Penarth AFC ("we", "our", or "the Club"), we take the privacy and security of our players, parents/guardians, coaches and volunteers very seriously. This Privacy Notice explains how we collect, use, store and protect your personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are and How to Contact Us

Inter Penarth AFC is a grassroots football club affiliated with the Football Association of Wales (FAW). For the purposes of UK data protection legislation, the Club acts as a Data Controller for the day to day administrative data we collect directly from you.

Club Secretary / Data Contact: Matthew Rose
Contact Email: secretary@interpenarth.com
Club Website: www.interpenarth.com

2. The Personal Data We Collect

We collect only the minimum necessary information required to organise trials, manage club membership, coordinate matches and training sessions, safeguard children and administer club and FAW registrations:

Prospective Players & Parents: Full names, contact telephone numbers, email addresses, dates of birth, current school year and previous playing experience submitted via initial inquiries.
Registered Players (Minors): Full name, date of birth, gender, age group squad, FAW Comet ID, availability and essential emergency medical information (e.g., severe allergies, asthma, dietary requirements, or pre-existing medical conditions).
Parents / Guardians: Full name, address, email address, mobile telephone numbers, relationship to player, emergency contact preferences and membership fee payment history.
Coaches & Club Volunteers: Full name, contact details, ID (Passport/Driving Licence), proof of address, signed FAW forms, role assigned, coaching qualifications, first aid certification, safeguarding status and FAW Comet registration status.
Safeguarding, Registration & Welfare: Data that is considered relevant to the safeguarding and wellbeing of our players, parents, coaches and volunteers plus what is required for Governing Body Affiliation and Registration.

3. How We Collect Your Data

We collect personal information directly from you through dedicated digital club systems:

Website Expression of Interest, general contact & Trial Forms (Wix): Prospective players, parents and volunteers submitting an inquiry or requesting a trial submit basic contact and player details through Wix Forms on our website.
Player & Volunteer Registration (Team Fee Pay): Waiting list management, formal player registration, parent/guardian contact details, emergency medical notes, consent preferences and recurring subscription payments are processed securely through Team Fee Pay.
Squad & Matchday Management Apps (Spond): Where team coaches utilise Spond for squad operations, you provide player availability, fixture attendance confirmations and emergency contact details.
Direct Club Communications: Details you provide when emailing our official committee addresses (@interpenarth.com) or communicating directly with committee officers regarding club administration.

4. Safeguarding, DBS Checks & The FAW

The Football Association of Wales (FAW) governs junior and senior grassroots football in Wales. In accordance with statutory safeguarding guidance and governing body regulations, Disclosure and Barring Service (DBS) checks and formal official registrations are managed centrally by the FAW via their dedicated management system (FAW COMET).

The Club does not process, receive, or hold your sensitive DBS disclosure certificates, five-year address histories, or original identity verification documents (such as passports, driving licences, or utility bills).
Coaches and volunteers submit this sensitive background information directly to the FAW via the FAW portal.
The Club only receives and records verification of a volunteer’s clearance status, FAW ID, and credential expiry dates directly through the FAW Comet system.

For full details on how the FAW collects and processes criminal record checks, identity verification, and statutory safeguarding data, please review the Football Association of Wales (FAW) Privacy Notice.

5. Why We Use Your Data (Lawful Bases)

Under UK GDPR, we rely on the following lawful bases to process your personal data:

Consent:
- Processing prospective member inquiries submitted via our Wix website forms, allowing us to contact you regarding trial sessions and squad availability.
- Publishing identifiable player photographs or videos on our club website and official social media channels.
Contractual Necessity: To complete club registration, assign players to squads, organise match fixtures and training, manage availability via Spond/Team Fee Pay, enter local leagues, and collect monthly subscription dues via Team Fee Pay.
Vital Interests: To hold critical emergency contact numbers and medical disclosures pitch-side so team managers and first aiders can respond immediately to an accident or medical emergency.
Legitimate Interests: To coordinate day to day club operations, maintain accurate squad rosters, coordinate matchday logistics, ensure volunteer compliance and communicate fixture or weather updates.
Legal Obligation: To satisfy child welfare and safeguarding standards mandated by the FAW, insurers and UK law.

6. How and Where We Store Your Data

We apply appropriate technical and organisational measures to ensure personal data is stored securely and protected against unauthorised access, accidental loss, or unlawful disclosure:

Centralised Cloud Storage (Zoho WorkDrive and Microsoft Azure): Where the Club generates or stores administrative records (such as squad emergency lists, attendance sheets, or volunteer credential registers), these files are housed securely within our club-managed Zoho WorkDrive and Microsoft Azure cloud workspace. Access is restricted using strict role based permissions, ensuring team coaches and committee members only access the specific details required for their roles.
Website Form Submissions (Wix): Submissions made via our online expression of interest forms are held securely on the Wix database and accessed only by authorised committee members managing team allocations.
Payment Processing: The Club does not store or process debit/credit card numbers or bank account details. All recurring registration fees and payment card transactions are handled via Team Fee Pay’s encrypted, PCI-compliant payment infrastructure.
Squad Management (Spond): Where used by coaches, player attendance, availability, and fixture call-ups are managed within Spond's GDPR-compliant environment, separating guardian details from minors and limiting access to relevant age-group coaches.
Device & Messaging Security: We maintain strict internal club rules prohibiting committee members and coaches from saving, sharing, or downloading player medical information, identity proofs, or volunteer records onto personal mobile camera rolls, personal cloud drives, or unmanaged messaging applications. Audits are run to check this and data removed with relevant training given. The club manages a WhatsApp community for parent and coach communications, however this is migrating to Team Fee Pay in time.

7. Matchday Coordination & Squad Communications (Spond, Team Fee Pay & WhatsApp)

To coordinate training, fixtures, and logistics, team managers and coaches use dedicated squad communication channels:

Spond & Team Fee Pay: Our primary digital tools for fixture schedules, availability tracking, team sheets and matchday call-ups. These platforms ensure player availability and guardian contact details remain structured and protected.
Club WhatsApp Community & Squad Groups: Used for urgent notices (such as last-minute pitch cancellations, weather updates, or arrival times) during our migration towards Team Fee Pay.
- Please note that when participating in WhatsApp groups, your phone number and profile name may be visible to other parents/carers in that squad.
- Participation in WhatsApp groups is entirely voluntary.
- Coaches and committee members are strictly prohibited from sharing sensitive personal information, registration forms, or medical notes within WhatsApp chats.
- If you prefer not to join a group chat, you can request match logistics directly via Spond, Team Fee Pay, or email. This should be discussed with the relevant Coaches of your age group.

8. Photography and Media

We love celebrating the achievements, development and fun of our players on our website and official social media channels:

We will only publish identifiable photographs or videos of junior players where positive parental/guardian consent has been given during registration on Team Fee Pay.
We will never publish a child's full name alongside an identifiable photograph without explicit, additional permission.
You may update or withdraw your media consent at any time by contacting your team manager or the Club Secretary or updating Team Fee Pay.

9. Who We Share Your Data With

We do not sell, rent, or trade personal information to any commercial third parties. We share data only where strictly necessary for grassroots football administration:

The FAW & Sanctioned Leagues: Registering players and teams for affiliated competition eligibility, fixture scheduling, and player insurance.
Service Providers: Trusted platforms that facilitate our administrative operations under data processing agreements (Team Fee Pay, Wix, Zoho, Microsoft Azure, and Spond).
Medical Services: Sharing critical medical details with emergency responders or hospitals in the event of an urgent pitch-side injury.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the operational and legal purposes outlined above:

Expression of Interest Submissions (Wix): Inquiries for squads currently at capacity or prospective players who do not take up a place are retained on a waiting list for up to 18 months, after which they are securely deleted.
Active Player & Parent Records: Held on Team Fee Pay, Zoho WorkDrive, and Azure for the duration of the active playing season and for re-registration. When a player leaves the Club, their administrative records are removed or archived at the end of that seasonal cycle.
Volunteer & Coach Records: First aid, coaching qualifications, and FAW Comet IDs are maintained for as long as the volunteer remains active with the Club, after which records are archived after 18 months and subsequently purged.

11. Website Cookies

Our website is hosted by Wix and uses essential cookies to enable secure navigation, load balancing, and core site functions. Any analytical or optional performance cookies can be controlled or disabled directly via our website cookie settings banner.

12. Your Legal Rights

Under UK data protection law, you have specific rights regarding your personal information:

Right of access: You can request a copy of the personal data held about you or your child.
Right to rectification: You can request that inaccurate, incomplete, or out-of-date information be corrected.
Right to erasure ("Right to be forgotten"): You can ask us to delete your personal data where there is no ongoing legal or governing body requirement for us to keep it.
Right to restrict or object to processing: You can object to or request that we restrict how we process your personal data under certain conditions.
Right to withdraw consent: Where processing is based on consent (such as website inquiries or social media photography), you may withdraw that consent at any time.

To exercise any of these rights, please contact our Club Secretary at secretary@interpenarth.com.

If you have concerns about how we handle your personal data, you have the right to contact the UK supervisory body:

Information Commissioner’s Office (ICO): ico.org.uk | Helpline: 0303 123 1113.