Summary of how we use your data
• The Trustees of The Football Association Benevolent Fund, (the “Trustees”, "we" or "us"), with the assistance of individuals with the relevant skills, knowledge and experience in this field (the “Advisory Group”) and County FAs, use your personal data in order to assess whether you are eligible for a grant from The Football Association Benevolent Fund (the “Fund”).
• This Fund is set up to provide grants to those participants or previous participants in Association Football in particular positions of hardship, due to poverty, age, ill health, disability or other hardships including those in need by reason of abuse, neglect or other trauma. In order to demonstrate eligibility for such a grant, you are required to complete a detailed application form setting out the circumstances of your hardship. This may involve the processing of sensitive personal data where we require your health information, which is processed on the basis of your explicit consent.
• Unless your application relates to abuse, neglect or other trauma, or is from former members and / or dependents of England’s 1966 FIFA World Cup winning squad, County FAs are responsible for assisting you in completing your application form ensuring that it has been completed appropriately, providing initial feedback on applications and for providing you with other support. For other types of applicant who have evidenced abuse, neglect or other trauma, the Advisory Group will review your application and make a recommendation to the Trustees.
• The Trustees are responsible for taking a final decision on whether you are eligible and what grant will be awarded in any given case. Administrative support to the Trustees is provided by The FA.
• Where we rely on your consent, such as for the processing of sensitive personal information, you can withdraw this consent at any time. However, we will be unable to process your application where you refuse or withdraw your consent to processing information which is necessary to demonstrate your eligibility.
What does this policy cover?
This policy describes how the Trustees, County FAs the Advisory Group and The FA will make use of your data when you submit an application for a grant from The Fund.
It also describes your data protection rights, including a right to object to some of the processing which the Trustees, County FAs, the Advisory Group and The FA carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
What information do we collect?
For the purposes of processing applications for grants from the Fund, we process information you provide in your application form. As well as providing basic contact details, you are required to provide detailed information regarding the circumstances of your hardship, your history as a participant in the game and details of any ongoing health or other hardship issues. This information is processed by County FAs, members of the Advisory Group and the Trustees. Additional information may be sought from County FAs and the Advisory Group by the Trustees. If you are a current or former member of the Professional Footballers’ Association (“PFA”), we will ask the PFA to provide us with details relating to any assistance that has been provided previously or is currently being considered. We may also seek further information from any third party references you have provided by way of evidence.
How do we use this information, and what is the legal basis for this use?
Unless your application relates to abuse, neglect or other trauma, or is from former members and / or dependents of England’s 1966 FIFA World Cup winning squad, County FAs will be responsible for assisting you in completing your application form, ensuring that it has been completed appropriately, providing initial feedback on applications and for providing you with other support.
In cases of abuse, neglect and other trauma, the Advisory Group will be responsible for assessing applications and making recommendations to the Trustees.
The Trustees are responsible for taking a final decision on whether you are eligible and what grant will be awarded in any given case. We process this personal data for the following purposes:
As required by The Trustees to conduct our business and pursue our legitimate interests, in particular:
o To inform you of the process to be undertaken in respect of your application for a grant;
o To assess your eligibility for a grant;
o To provide you with ongoing support, both financially and practically;
o To communicate with you or about you where necessary to assess your eligibility or administer your grant;
o To investigate any complaints received from you or from others, in relation to your application;
o To maintain records of grants that have been awarded to applicants;
o We will use your data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
For purposes which are required by law:
o in response to requests by government or law enforcement authorities conducting an investigation; and
o in order to keep appropriate records of your grant and application for the purposes of complying with legislation applicable to charities.
Where we have obtained your consent, we will collect and hold sufficient information on your sensitive personal data, including any medical data and details of abuse, neglect or trauma, to be able to ensure your ongoing eligibility for the grant.
Wherever we rely on your consent, you will always be able to withdraw that consent, If you withdraw consent to our processing of your data that is necessary to process your application, we will be unable to award you a grant.
You can withdraw your consent by following the instructions in any electronic communication with us or by contacting us using the details set out below.
Who will we share this data with, where and when?
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
For some applicants where relevant, we will inform County FAs where you have been granted any award.
Personal data will also be shared with the members of the Advisory Group and / or County FAs (depending on the type of application) as well as third party service providers, including The FA, who will process it on behalf of the Trustees to provide them with administrative services.
Your information is not shared outside the EEA.
If you are a survivor of abuse, neglect or other trauma and a member of the PFA, we may share the reasons for your application to the Fund and current financial circumstances with the PFA (i) to determine if you are, or have been, in receipt of PFA assistance and (ii) to enable the Fund and PFA to coordinate any support and assistance provided to you.
What rights do I have?
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.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where it would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, you can get in touch with us 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 likely to be the Information Commissioner’s Office in the UK.
In order to assess your eligibility, the provision of details in your application form – including details relating to your health where this forms part of the basis for your application - is mandatory: if relevant data is not provided, then we will not be able to process your application and you will not be eligible for a grant.
How do I get in touch with you, or your data protection officer?
If you wish to make a data privacy request, you can do so via our online form, which can be found here. We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, you can get in touch at firstname.lastname@example.org or by writing to: Data Protection Officer, Wembley Stadium, PO Box 1966, London, SW1P 9EQ.
How long will you retain my data?
We will retain information we receive in application forms and details of grants we make for 3 years after the decision to award a grant has been made, to ensure that we retain details sufficiently long for the purposes of financial audit, to track any repeated applications.
Where we process personal data with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests).
Where your data is held on FA systems, then at the end of the retention period set out above we will not irrevocably delete your information for another 3 months – your data will be held in an inactive form for this time to ensure that any consequential links across FA systems remain intact in the event that your data is removed in a particular location.