Summary of how Match officials data is used by The Football Association Limited (“The FA”), County Football Associations (“County FAs”) and Other Football Associations.
- All match officials are required to register annually with their main and affiliate County FAs and Other Football Associations. This is typically completed through Whole Game System or Platform For Football - The FA’s football administration systems - although some County FAs may exceptionally allow information to be provided on paper forms. Match officials will use Whole Game System or Platform For Football system to complete referee registration. Access to this information is given to The FA, the County FAs and Other Football Associations you affiliate with and any leagues you officiate in.
- Information contained in your registration, particularly your name and contact details, may be provided as part of your main County FA’s annual handbook. You can select what information will be displayed and preview how this will appear in the handbook when registering through Whole Game System or Platform For Football.
- You are asked to provide diversity information, which includes sensitive information about your ethnicity and sexual orientation. This is held and processed by The FA on an anonymous basis, but you can also choose not to provide this information.
- Match officials may be required to undergo both competence and fitness tests/observer report, which will be organised by your league, County FA, Other Football Association, The FA or PGMOL depending on your level. The body organising your test will receive information about your performance, including (for fitness test) your blood pressure and the results of your test. This is used to assess your ability to perform the role of match official.
This policy describes how The FA and County FAs and Other Football Associations will make use of your data when collected or used in relation to your role as a match official in interaction with The FA and its systems.
This policy describes your data protection rights, including a right to object to some of the processing which The FA and County FAs and Other Football Associations 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 The FA, County FAs and Other Football Associations collect about me?
To initially register as a match official, your County FA or Other Football Association will make an initial registration of your role on an FA system.
You are then asked, annually, to register with your County FA or Other Football Association and any affiliated County FA or Other Football Association through Whole Game System or Platform For Football. Referee registration will occur in both the Whole Game System and Platform For Football.
In both cases, you are required to provide County FAs, Other Football Associations and The FA with certain information about you, including details on your qualifications, types of football you wish to officiate, days when you wish to officiate, contact details and general availability.
Information is also collected about referees and match officials from third parties in relation to their performance. In particular:
- Match officials at all levels are reviewed on a regular basis by FA, PGMOL, County FA, Other Football Association or league appointed observers, with reports produced by these observers. These are subject to FA, PGMOL County FA, Other Football Association or league specific marking and observation schemes, more details of which can be provided by the FA, PGMOL, County FA, Other Football Association and/or league. The FA can request access to the information and obtain these reports as required.
- Across all levels of the game clubs are asked to complete a club report on a Match Referee Form following each game to provide their view on the performance of the match referee. Depending on the competition, this data is captured using MOAS, Full Time or County FA/Other Football Association specific systems.
- Referees at level 2A, 2B, 3 and 4 and assistant referees at level 3E, 3F and 4 are included in FA produced merit tables based on the reports received from clubs and observers. These merit tables are used to help develop referees and assistant referees by County FAs, Other Football Associations and The FA, as well as determining which referees will be considered for advancement to a higher level of competition or reclassified.
- PGMOL data including observer reports, club reports on match referees, delegate reports, match videos and match official performance data for match officials operating within the PGMOL structure is shared with appropriate members of FA staff to ensure consistency and continuity for appointments and performance management.
- The FA will share observer reports, club reports on match referees, delegate reports, match videos and match official performance data for match officials operating at Level 2A, 2B, 3 and 4 with the appropriate members of PGMOL staff to ensure consistency and continuity for appointments and performance management.
Information is also obtained from providers of fitness tests appointed by your league, County FA, Other Football Association, The FA or PGMOL. Information about your results (such as blood pressure, distance run and whether you have met the appropriate fitness level) will be collated or shared with The FA, PGMOL, County FA or Other Football Association.
How do various parties use this information, and what is the legal basis for this use?
Your County FA or Other Football Association will use this information for the following purposes:
- To fulfil a contract, or take steps linked to a contract: this is relevant where you make a payment for affiliation or for particular items such as the County FA handbook during the registration process on Whole Game System or Platform For Football, taking your payment and providing you with a receipt of payment.
- As required by your County FA or Other Football Association to conduct and administer the game and pursue its legitimate interests, in particular:
- communicating with you or about you where necessary to administer the game, such as informing you of an appointment or change to fixtures or to clubs about your appointment;
- communicating with you to ask for your opinion on County FA or Other Football Association initiatives;
- administering and assessing the performance of referees and match officials who are affiliated with their county, producing county handbooks, making decisions on match official progression and providing appropriate training and coaching to improve match official performance;
- maintaining records of the game as played in their county or jurisdiction, in particular maintaining details of discipline as enacted by you and records of matches you have officiated;
- ensuring that children and individuals at risk in the game are appropriately protected from harm, including carrying out safeguarding activities and checks of whether appropriate mandatory training and criminal records checks have been carried out; and
- if you provide a credit or debit card as payment, checking the validity of the sort code, account number and card number you submit through a third party in order to prevent fraud (see data sharing below).
The FA will use this information for the following purposes:
- As required by The FA to conduct our business and pursue our legitimate interests, in particular:
- communicating with you or about you where necessary to administer the game, including informing you about the annual registration window and responding to any questions submitted to the Whole Game System’s or MOAS’s administrators, or liaising with clubs who provide feedback on match official performance;
- administering and assessing the fitness, competence and performance of match officials, making decisions on progression and providing appropriate training and coaching to improve match official performance;
- maintaining records of the game as regulated by The FA, in particular details of discipline and misconduct in games you officiate and report on, and which matches you have officiated in;
- monitoring use of Whole Game System, Platform For Football and MOAS to help it monitor, improve and protect its content, services and sites, and investigate any complaints received from you or from others about either system;
- communicating with you to ask for your opinion on FA initiatives; and
- for use in formal scientific research projects.
- Where you give us consent:
- For purposes which are required by law:
- In response to requests by government or law enforcement authorities conducting an investigation.
Wherever The FA relies on your consent, you will always be able to withdraw that consent, although it may have other legal grounds for processing your data for other purposes, such as those set out above.
How is data shared, where and when?
Information about your performance and position on FA merit tables may be provided to leagues and to County FAs and Other Football Associations, in particular to Referee Development Officers and Referee Coaches appointed by County FAs and Other Football Associations.
The FA may in some circumstances share information about your performance and reports made about or by you with clubs involved in matches in which you have officiated. Unless The FA is confirming that all observers agreed with your position, The FA will inform you before sharing details of observer reports with clubs.
Personal data will also be shared with third party service providers, who will process it on behalf of the controllers for the purposes identified above. This may include the providers of IT services, survey providers, event organisers, providers of payment processing and software providers. The FA may also share information with third parties, like universities, for research projects.
Personal data will also be shared with third party service providers, who will process it on behalf of the controllers for the purposes identified above. Such third parties include providers of payment processing and software providers.
Currently, your information is not shared outside the UK or EEA, except in circumstances where you are nominated to participate in matches regulated by FIFA or UEFA. In these circumstances, your data will be shared with FIFA or UEFA, both of whom are located in Switzerland. This data is adequately protected as Switzerland is recognised by the European Commission as providing adequate protection under its data protection laws.
What rights do I have?
You have the right to ask any of the relevant data controllers 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 one of the data controllers doesn’t have to process the data to meet a contractual or other legal requirement, or where it is 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.
In some instances, you will need to contact more than one of the data controllers to ensure your rights are met, as they may have access to different data and have different reasons for holding the data. As the main provider of the systems on which your data is held, The FA will be in the best position to provide you with a number of these rights, particularly access to all information held about you in MOAS, Colina, Platform For Football or Whole Game System and to correct any underlying data connected to your FA number.
To exercise any of these rights, you can get in touch with The FA – or its data protection officer – using the details set out below. As mentioned above, you can also get in touch directly with your County FA or Other Football Association where appropriate. Contact details for County FAs and Other Football Association you are affiliated with can be found on the County FA or Other Football Association website. 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 is likely to be the Information Commissioner’s Office in the UK.
With the exception of the anonymous diversity information, the information requested is mandatory for those who wish to officiate in FA sanctioned matches. If relevant data is not provided, the various data controllers will not be able to appropriately administer the game or their county. Although contact details must be provided, match officials can elect for this to be excluded from their relevant County Handbook without detriment.
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 County FA or Other Football Association is my data controller?
The data controllers for your information are The FA, and any County FA or Other Football Association you register with as your main or affiliate County. More details on this, and the relevant contact details for that entity, can be found on the County FA website.
How long will you retain my data?
Information collected as part of a match official's application forms, including biographical details and affiliations, will be retained for the length of the match official's active career. Where a match official has not registered for 2 seasons, they will be considered inactive. Information relating to inactive officials will be removed after 5 seasons, to ensure we retain information for at least the length of any contract you may have been under with any data controller.
Information about a match official's appointments, a match official's fitness tests and their performance during appointments as adjudged by observers and clubs will be held for 7 seasons, to ensure we are able to defend ourselves against any relevant legal claim and to ensure that we maintain an appropriate and relevant record of your performance and conduct.
Information about discipline you have administered, and the fact of your appointment, may be held indefinitely by The FA, County FAs, Other Football Associations and leagues indefinitely, in order to maintain a record of the game. Where any of the parties processes personal data for marketing purposes or with your consent, it will process the data until you ask it to stop and for a short period after this (to allow it to implement your requests). It will also keep a record of the fact that you have asked it not to send you direct marketing or to process your data indefinitely so that it can respect your request in future.
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.
Where you provide a County FA or Other Football Association with your payment details, it will retain a record of the payment for at least 7 years from the date of your payment.