UKGF / England Golf Correspondence

England Golf has been up to their old tricks again. Below you will see the full correspondence between the UK Golf Federation and England Golf in relation to the determination to have every club in England send through email addresses and dates of birth for every registered golfer. 

 

Dear Jeremy 

Ref: Our Letter 01.10.20 & Your Reply 05.10.20 Regarding - World Handicap System | Data Requirement Notice and GDPR Obligations 

Thank you for you and your team’s time last Friday and your detailed written response to our concerns.  

Whilst the information provided is helpful, it still leaves our members in a quandary as to how to respond to your request for member data. In seeking to help you get the data you need to run a handicap system with a high level of integrity, we have some suggestions that should help allay the fears of our members. 

  • 1. The key part of the GDPR legislation is ‘Legitimate Interest’. Our members in general do not have a legal background and only have a basic working understanding of the GDPR legislation. The concerns around ‘Legitimate Interest’ would be alleviated to a large degree if your privacy policy was explicit in detailing that the data will only be used for the purposes of running the handicap software. There are more elements to the WHS Privacy Policy than just running a handicap and you could remove much of the resistance to providing you with data by reducing the scope for which said data is used.

  • 2. Your current approach to acquiring member data is asking the data controller at a club, often a volunteer, to make a decision based on England Golf’s Privacy Policy, their own club’s privacy policy and GDPR legislation. The safest action is inaction. However, this leaves the club members potentially without handicaps. It is an invidious position and we would strongly recommend that you reconsider your position in this regard.

  • 3. The current WHS policy is no email, no handicap. We would urge you to reconsider this as our research suggests that 8% of golf clubs do not have access to their members through email. Surely an app or web-based portal can ensure that no-one is excluded. We are fearful of the adverse publicity if golfers lose their handicap because they don’t have an email address.

  • 4. There is also a reluctance for golfers to provide their date of birth and whilst we appreciate that importance of system integrity, suggest that you seek a different way for golfers to confirm their identity. Their postcode perhaps?

We clearly want to support England Golf through the process of launching the WHS and urge you to consider our suggestions, so we pass clear information onto our members. We are circulating this letter to our members and will be more than happy to pass your response on, in the same way. 

Kind regards  

Yours sincerely,

Douglas Poole,  

CEO,  UK Golf Federation 

 

 

 

Response letter 09J20 Hi Doug,

Thanks for the note.

As we have previously set out, the England Golf WHS privacy notice covers this off and therefore there are no requirements for golf club members to opt in on this basis.

I appreciate that you have already received this, but to reiterate:

As part of the licence that they have signed, ISVs will display a privacy notice relating to England Golf being a data controller in respect of its members’ data.  England Golf has a contract with its members, namely individuals who are members of affiliated golf clubs.  The details requested in the licence, including e-mail address, are necessary for the performance of that contract in accordance with the terms of Article 6 of the GDPR.  Full details of the lawful basis or bases for England Golf’s processing of its members data is set out in the required privacy notice as required by the GDPR, which ISVs are required, under the terms of the licence, to include in their end user agreements.

England Golf, as National Governing Body for golf in England, has a legitimate interest in providing a handicap system with the highest levels of integrity to enable fair competition across the sport.  It also has a legitimate interest in providing and promoting other benefits of being a member, in promoting participation in the sport, in protecting the sport, in monitoring participation in the sport, in participating in initiatives in relation to the sport and physical activity generally, and in reporting to public bodies as required.  These purposes are all legitimate and personal data will not be processed in a manner incompatible with these purposes. 

We will continue to communicate with all licensed ISVs to ensure their compliance with the terms and conditions set out in the WHS license agreement.

Regards,

Richard

 

Response Email to our Letter 09J email Morning Doug

I’m not sure how you would like me to respond further…

I can only re-iterate our honest, transparent and communicated messages/process to deliver the highest integrity level of handicap calculation and delivery via the World Handicap System (WHS).

This involves a seismic change of responsibility from Golf Club calculation hubs to ourselves England Golf (EG) as the National Governing Body,

inherent within this responsibility is a twofold cost, development & maintenance, neither of which have been charged to Golf Clubs.

The WHS introduction has been communicated via many channels for over a year, direct from ourselves (EG) for many months via our “know the score” campaign, then from July regarding Golf Club responsibilities (as already communicated).

The “corporate speak” as stated in your letter is in fact the legal framework within which we are administering WHS through circa 1800 golf clubs for circa 640,000 golf club members,

as such I deem your comments  “unfair” at the very least in describing our logistical efforts to deliver such a complex project for those golf club members in England.

Our board, leadership team, partnership managers and club support officers have and will remain on call to support all/any golf club in England thru delivering the WHS to their members.

I will also as already shown be available to discuss any ongoing concerns not already covered.

 

Best regards

Jeremy

My response Final Email 13.10.20  

Dear Jeremy & Team

 

Just to Conclude!

We have every sympathy with the many difficulties presented to EG by the WHS however,  as you repeatedly state you are the national governing body and these are the responsibilities that come with that status . 

Our contribution as a relevant and responsible national organisation has been, having recognised the invidious position you’ve put data controllers in up-and-down the country to point that out. We fear that there are issues with the transfer of this data and indeed the amount of data you do not get causing issues for the game, ie handicapping going forward. 

Our only agenda here is to help EG but also the data controllers that don’t have a legal team to call on, they are just concerned about what action to take. We have outlined a simple infrastructure , already in place , whereby you have the opportunity to ask every golfer with a handicap in England whether or not they wish EG  and the WHS to have the data that you deem necessary for the specific purpose of running a handicap. 

We believed you should take this opportunity. 

Kind regards

Doug

Douglas Poole – CEO – UK Golf Federation