Player Privacy Policy

This policy explains how the EIHL uses personal data provided by, or received in respect of, players as well as persons associated with them and the EIHL, but not employed or contracted by the EIHL, including, agents, managers, trialists, coaches, scouts, club staff, directors (including shadow directors and club owners) and player family members (you or your), in accordance with the General Data Protection Regulation and other applicable data protection legislation including the Data Protection Act 2018 (together, the Data Protection Law).

We keep our privacy practices and procedures under review and we may amend this policy from time to time. This version is dated 17 July 2019.

PLEASE READ THIS POLICY, TOGETHER WITH ANY OTHER PRIVACY NOTICES WHICH WE MAY PROVIDE TO YOU, CAREFULLY SO THAT YOU ARE AWARE OF AND UNDERSTAND THE WAYS IN WHICH WE COLLECT AND USE YOUR PERSONAL DATA.

This policy applies to our use of your personal data, but other organisations such as Ice Hockey UK (IHUK), English Ice Hockey Association (EIHA), the International Ice Hockey Federation (IIHF), the Champions Hockey League (CHL) and the EIHL member clubs (each a Club) (as applicable) are also likely to collect and use your personal data and you should also refer to their respective privacy policies to understand how each of these organisations use your personal data.

Background

1.1. The EIHL is a “controller” under the Data Protection Law which means that we are responsible for deciding how we use the personal data that we collect about you.

1.2. In accordance with the Data Protection Law, we will ensure that the personal data we hold about you is, at all times:

(a) used fairly, lawfully, and transparently;

(b) collected for limited, specific purposes only;

(d) kept accurate and up-to-date;

(e) not kept for longer than is necessary; and

(f) held securely.

1.3. We shall be accountable for and able to demonstrate our compliance with our obligations under the Data Protection Law, and this policy is one of the ways in which we do that.

1.4. We have appointed a Data Protection Lead to oversee compliance with this policy and our data protection compliance activities. The Data Protection Lead has also established a dedicated data protection team to provide the necessary support.

What Personal Data we collect and when

2.1. Personal data means any information about you from which you can be identified. It does not include data where your identity has been removed (i.e. anonymous data). There are also “special categories” of more sensitive personal data which require a higher level of protection, for example personal data revealing or concerning a person’s racial or ethnic origin, health, or criminal convictions and offences. We collect and use a range of personal data, including special category personal data in some circumstances, depending on your role or relationship with the EIHL.

2.2. You provide some of your personal data to us directly (or via your Club):

(a) the information you submit in EIHL registration forms and contracts.

(b) the information contained in identification documents you are required to provide in order to confirm your identity and eligibility (for example, birth certificate, passport and immigration documents);

(c) the information you provide when you enrol in programmes and training initiatives and other events administered by the EIHL;

(d) the information you provide in order to register to use certain digital platforms/ services we provide to you;

(e) your photograph and other media recordings (for example, upon joining the EIHL or a new Club, or during EIHL photoshoots);

(f) the information you submit when completing forms and surveys issued by us as and when required (for example, dietary requirements);

(g) your contact details and any emergency contact details; and

(h) any other personal information you share with us, including by way of email, telephone call or interview.

2.3. When you are asked to provide non-mandatory information to the EIHL this will be clearly indicated.

2.4. We will also collect other personal data relevant to your EIHL related activities from your Club or other third parties.

2.5. Clubs provide us with (as applicable):

(a) copies of player and manager contracts which include additional personal data such as details of remuneration;

(b) a copy of the representation agreement entered into by a player with intermediaries;

(d) details of staff roles and qualifications (where relevant);

(e) details of staff and player training;

(f) certain medical and health data (i.e. special category data).

2.6. IHUK also provides us with documents concerning a player’s “right to work” in the UK and a copy of the International Transfer Certificate.

2.7. We may also collect or receive the following (as applicable):

(a) live on-field tracking and performance data (for example, positioning, distance run and passes made) (Tracking Data) and other match event data (for example, goals scored or fouls conceded);

(b) match-related photographs, videos and other recordings;

(c) information on your behaviour in relation to sports integrity, safeguarding and personal conduct including records of incidents and allegations of EIHL rule breaches and details of how such incidents and allegations are resolved. Such information may include details of criminal offences and illegality (i.e. special category data).

2.8. The EIHL takes its duty to safeguard vulnerable people, including youth players and other children, seriously, by collecting and analysing records of incidents and allegations of abuse, exploitation or inappropriate conduct, by reference to the law and our rules and regulations. Please note that we may collect and process your personal data (including from public sources) without your knowledge or consent where this is required and/ or permitted by law.

How and why we use your Personal Data

3.1. We collect and use personal data for a range of specific and legitimate reasons which will vary depending on your role or relationship with the EIHL. We only collect and use personal data in accordance with Data Protection Law. For the most part, we collect and use personal data because it is necessary for our “legitimate interests”, that is, in order to operate, administer, regulate and govern the EIHL competitions and to support Clubs’ associated activities in an effective and lawful manner.

3.2. In particular, it is necessary:

(a) to confirm identity and eligibility in the application of rules and regulations relating to player registration and transfers in order to ensure that players are eligible to play for, and where relevant be employed as a professional player by, their Club in the EIHL competitions;

(b) to ensure contracts and registration documents comply with the rules and regulations set down by the EIHL;

(c) for identity verification purpose so as to maintain a high level of security at matches and other EIHL events (including by producing identity cards);

(d) to ensure Clubs are meeting the standards set out in the EIHL Rules;

(e) to prevent unauthorised access to confidential information (including personal information) by creating registered accounts for use of certain digital platforms/ services which we provide to you

(f) to record and confirm player match appearances and performances;

(g) for safeguarding vulnerable individuals like youth players and other children;

(h) to comply with health and safety and other legal obligations and uphold our duty of care towards you and other individuals;

(i) to resolve disputes and allegations;

(j) to communicate with you;

(k) to maintain integrity and prevent crime and corruption within Ice Hockey;

(l) to promote / commercialise EIHL including by publishing or sharing photographs of and information on players and match officials and their performances and by sharing information such as Tracking Data with broadcast partners;

(m) to generate internal reports to help develop and improve EIHL rules, policies, procedures and strategies;

(n) for preserving the history of ice hockey and the EIHL competitions; and

(o) for other administrative and statistical tasks required to discharge the EIHL League’s function.

3.3. Before using your personal data for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you to ensure that your interests and fundamental rights and freedoms do not override those interests. In other words, we have determined that the EIHL has a legitimate need to process your personal data and we are not aware of any reasons that, on balance, mean we should not be doing so. If you have concerns about our processing please refer to Your Rights in Connection with Your Personal Data

3.4. In accordance with Data Protection Law, in rare circumstances we may also use your personal data because:

(a) we need to comply with a legal obligation (for example, because the court has ordered us to do so); or

(b) it may be necessary to protect yours or someone else’s vital interests in emergency situations.

3.5. We generally do not rely on your consent in order to process your personal data and we will inform you specifically when we seek to obtain this from you as well as your ability to withdraw that consent at any time.

Special Category Data

3.6. We also only use special category personal data in accordance with the Data Protection Law and therefore only if:

It is necessary for reasons of substantial public interest. Data Protection Law provides for the use of special category personal data where it is necessary for the purposes of measures designed to protect the integrity of a sport or a sporting event. This includes measures to prevent or protect against dishonesty, malpractice or other seriously improper conduct, or failure by a person participating in the sport or event in any capacity to comply with standards of behaviour set by a body or association with responsibility for the sport or event.

(b) We have your explicit written consent. In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive data where there is no other legal basis. If we do so, we (or a third party) will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. For example:

– we are interested in collecting information about player’s racial or ethnic origin to ensure meaningful equal opportunity monitoring and reporting, and players’ are given the option to submit this information to us via their Club on the relevant form; and

– we request information concerning a youth player’s medical, dietary and other additional needs so that we can run tournaments and other events safely.

You have the right to withdraw your consent at any time and can do so by contacting us using the details provided below.

(c) Less commonly, we may process your personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

3.7. Unless otherwise required or permitted by law, before using your personal data for a purpose unrelated to the reason we collected it, we will notify you and explain the purpose and legal basis which allows us to do so.

3.8. If you have any questions or require any additional information about the purposes for which your personal data is required and/ or our legal justification you can contact the EIHL dedicated Data Protection Team using the contact details set out below.

Who we share your Personal Data with

4.1. In order to function effectively as a regulator and organising body in ice hockey and administer our relationship with you and your role within ice hockey as set out above we may share certain elements of your personal data with other individuals and organisations, always on a need-to-know-basis and for legitimate prescribed reasons:

(a) we share relevant player registration and identity information with IHUK for verification and administrative purposes;

(b) we share player registration information with the IHUK, CHL, IIHF for administrative purposes;

(d) we provide player photographs to:

– Clubs and partner clubs for use on their websites, social media and matchday programmes;

– our international and domestic broadcast partners for broadcasting matches and related content and for use on websites and social media; and

(e) video footage of players (including match footage, dynamic walks to camera and player name pronunciation, promotional messages and preview or post-match interviews and/or features) recorded on behalf of the EIHL is shared with domestic and international broadcast partners;

(f) we share certain personal data contained in Club staff contracts and details of qualifications with IHUK in order to comply with IHUK licensing requirements;

(g) we share personal data concerning safeguarding issues with Clubs, IHUK and official authorities as necessary;

(h) we provide personal data (including, where necessary important medical and dietary information) to individuals employed to work at tournaments and events administered by the EIHL;

(i) we share Club staff contact details with EIHL partners to allow relevant individuals to deal with each other directly;

(j) we share limited (and nameless) injury data with a professional medical consultant to produce injury surveillance reports;

(k) we provide Tracking Data and video footage to Clubs, broadcast partners and sports data partners for commercial, statistical and analysis purposes;

(l) information may be shared between the EIHL, DOPS and those individuals determining the outcome of disciplinary or regulatory proceedings and appeals in respect of such proceedings;

(m) we may share personal data concerning regulatory and sports integrity issues with IHUK, the police, the Gambling Commission and (if required) IIHF.

4.2. We also share elements of your personal data with third parties who provide the EIHL with certain services to facilitate our business operations (as described above):

(a) web/ app hosting;

(b) software/ app development and maintenance;

(d) archiving and storage services; and

(e) the production of identity cards.

4.3. All third-party service providers who we share your personal data with are required to take appropriate security measures to protect your personal data. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified limited purposes and in accordance with our instructions.

Transferring personal data outside the EEA

5.1. Some countries outside of the European Union (EU) do not have laws that protect privacy rights and personal data as extensively as the UK and other countries in the EU. Therefore, in accordance with Data Protection Law, if we do transfer your personal data outside of the EU, we ensure that your personal data is afforded a similar level of protection by ensuring one the specific safeguards approved by the European Commission is in place. You can find further information about these safeguards at https://ec.europa.eu/info/law/law-topic/data-protection_en.

5.2. We only routinely transfer personal data outside of the EU in the following circumstances:

(a) We transfer Tracking Data to non-EEA broadcast partners for public broadcast or sports data partners for commercial, statistical and analysis purposes.

(b) In certain circumstances we share player personal data with the IIHF which is located in Switzerland.

5.3. If you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA please contact us using the details provided below.

Security of your Personal Data

6.1. The EIHL is committed to protecting your privacy and has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Details of these measures are available upon request using the details provided below.

6.2. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

6.3. Where we have given you or you have chosen a password which enables you to access certain digital platforms/ services, you are responsible for using reasonable care in keeping this password confidential.

Data Retention

7.1. In accordance with Data Protection Law, EIHL will only keep your personal data:

(a) for as long as necessary to fulfil the specific purposes we collected it for – for example, we will retain your contact details until such time as there is no foreseeable need to communicate with you. In a lot of cases, we wish to retain personal data because, although it is no longer necessary to process it currently, it is likely to become necessary to do so again in the near future. For instance, where your Club is no longer competing in the EIHL but may do so again in the future;

(b) to the extent reasonably necessary to comply with a legal requirement or legal reasons – for example, documents containing personal data may need to be retained for an extended period of time (generally for six years) if there is a real risk that they could be the subject of a claim, or may otherwise be relevant to future litigation; or

(c) as advisable in light of certain legal issues (or potential issues) – for example, we may retain information in relation to safeguarding issues after the conclusion of an investigation so that we can address historical allegations in the future.

7.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

7.3. In accordance with the EIHL Data Retention Policy and Data Protection Law, after the applicable retention period has ended, the personal data will be either (as applicable):

(a) securely deleted or destroyed – when the information is no longer required in any form;

(b) anonymised (so that it can no longer be associated with you) – for example, where the data remains useful in an aggregated/ generic form for statistical purposes; or

(c) transferred to the EIHL “archive” – an “archive” is a collection of personal data which is no longer necessary to achieve the purposes for which the information was originally collected or which is no longer used for general business activities, but are used only for historical, scientific or statistical purposes, dispute resolution, or investigations. We wish to continue to retain some personal data as it effectively forms part of the history of the EIHL, its competition and the sport, for example, player registration information after the player has retired. We maintain appropriate measures to keep archived personal data secure, in accordance with Data Protection Law.

7.4. Specific details of retention periods for different aspects of your personal data are available upon request by using the contact details provided below.

Your rights in connection with your Personal Data

8.1. Under Data Protection Law, you have certain rights (depending on the circumstances) in connection with your personal data, which include:

(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it, provided always that this does not adversely affect the rights and freedoms of other people.

(b) Request correction of the personal data that we hold about you. Where any of the information we hold about you is incorrect or incomplete we will act promptly to rectify this, including where you have requested us to do so.

(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

(d) Object to use of your personal data where we are relying on our legitimate interests (see “How and why we use your Personal Data”) and there is something about your particular situation which makes you want to object to our use on this ground.

(e) Withdraw your consent to our use of your personal data where we do so in reliance on your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

(f) Request the restriction of use of your personal data. This enables you to ask us to suspend the use of personal data about you, for example if you want us to establish its accuracy or the reason for using it.

8.2. We are committed to respecting your rights. You may action your rights (as applicable) by contacting us using the details provided below and we will comply with your requests within a reasonable period unless we have a lawful reason not to do so. Requests should be made in writing and to ensure that personal data is dealt with carefully and confidentially the EIHL will require the requestor to provide verification of their identity and all applications must be accompanied by copies of at least two official documents, which show your name, date of birth and current address (for example, driving licence, birth/ adoption certificate, passport, recent utility bill).

8.3. Note: in responding to such requests, we will explain the impact of any objections, restrictions or deletions requested, which may be significant if our use of your personal data is necessary for you to fulfil your role or relationship with the EIHL.

8.4. We will not charge you a fee to exercise your rights unless your request for access is clearly unfounded or excessive, in which case we may charge you a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.

9.1. If you have any questions about this privacy policy or how we handle your personal data, please contact the Data Protection Lead using the following contact details:

info@eliteleague.co.uk

Complaints

10.1. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK data protection authority. The ICO’s contact details as are follows: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; Tel: 0303 123 1113 (local rate) or 01625 545 745; https://ico.org.uk/global/contact-us/

Player Privacy Policy

Player Privacy Policy

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