Summary of how we use your data
- The FA uses your personal data in order to carry out an owner’s and director’s test on you and in order to keep a register of Officers at a particular Club. The owner’s and director’s test is carried out to establish an individual’s suitability to act as an Officer (as defined in The FA’s Owners and Director’s Test Regulations) of a Club (as defined in The FA’s Owners and Director’s Test Regulations).
- Data is shared with relevant leagues and clubs so that they can ensure compliance with applicable league and FA rules.
- Where we rely on your consent, such as for the processing on information (if any) relating to your conviction for or potential conviction for criminal offences, you can withdraw this consent at any time.
- Should The FA process your personal data in connection with an owner’s and director’s test and this reveals that you are subject to a Disqualifying Condition (as defined in The FA’s Owners and Director’s Test Regulations), you will not be able to act as an Officer (as defined in The FA’s Owners and Director’s Test Regulations) of a Club (as defined in The FA’s Owners and Director’s Test Regulations).
What does this policy cover?
It also describes your data protection rights, including a right to object to some of the processing which The FA carries 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 the owner’s and director’s test, we collect personal information about you via the declaration and from information contained within public registers, for example, records held by Companies House and the Insolvency Register, or from information available publicly and from other regulatory bodies or statutory agencies. This includes:
- your name;
- your age/date of birth;
- your home address, email address;
- details of the club in respect of which you intend to be appointed an Officer; and
- details (if any) of the clubs in respect of which you have been appointed an Officer since 2005.
What information do we receive from third parties?
Sometimes, we receive information about you from third parties. In particular: from information contained within public registers, for example, records held by Companies House and the Insolvency Register, or from information available publicly, from your club and from other regulatory bodies or statutory agencies such as the police or other sports governing bodies.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
- As required by The FA to conduct our business and pursue our legitimate interests, in particular:
- we will use your information to respond to any comments or complaints you may send us;
- we use information you provide to investigate any complaints received from you or from others about you;
- we will use your data to ensure the integrity of the game is upheld, and that only those that will maintain the integrity of the game are approved by The FA – where this involves the processing of sensitive personal data, this will be because this is necessary for our measures to preserve the integrity of the game; and
- we will use 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).
- Where you give us consent:
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
- For purposes which are required by law:
- in response to requests by government or law enforcement authorities conducting an investigation.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.
Who will we share this data with, where and when?
We will share your data with relevant leagues such as the Premier League, EFL and your club in order to ensure compliance with league and FA rules. It may also be shared with other sports governing bodies to ensure compliance with their rules and help maintain the integrity of sport in general.
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.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request by email to email@example.com or by writing to: Data Protection Officer, Wembley Stadium, PO Box 1966, London, SW1P 9EQ.
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 – or our data protection officer – 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.
For the purposes of the owner’s and director’s test, the provision of information is mandatory: if relevant data is not provided, then we will not be able to process the test and you will not be able to act as an Officer of a Club.
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.
Which entity is my data controller, and which affiliates might my data be shared with?
The data controller for your information is The FA.
How long will you retain my data?
The FA retains information it has collected in order to carry out an owner’s and director’s test on you for the period of your registration as an owner or director and for a number of years thereafter in accordance with the below:
- The FA will keep a copy of a Declaration (and any information (including relevant correspondence) submitted in connection with the Declaration) for the period of the appointment to which the registration relates and for 3 years thereafter; and
- Where your data is held on FA systems, then at the end of the retention periods 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 our systems remain intact in the event that your data is removed in a particular location.