Privacy Policy

The Professional Golfers' Association ("PGA", "we", "us", "our") respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, whether you are a Member, assistant, customer, supplier, business partner, or other third party we have a relationship with, and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy notice
This privacy notice aims to give you information on how the PGA collects and processes your personal data through your use of our website, or offline when you provide us with personal data, for example in an application form, in person or over the telephone.

Our website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller
The Professional Golfers' Association Limited is the controller and responsible for your personal data.

Our Head of Governance is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Head of Governance using the details set out below:

Andrew Wright
The Professional Golfers' Association Limited
PGA Headquarters, Centenary House
The Belfry, Sutton Coldfield
B76 9PT
01675 470333
privacy@pga.org.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 24 May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data - includes first name, maiden name, last name, username or similar identifier, Membership number, marital status, title, date of birth and gender.
• Contact Data - includes home address, work address, email addresses and telephone numbers.
• Financial Data - includes bank account and payment card details (where provided).
• Transaction Data - includes details about payments to and from you and any subscriptions or purchases made from us.
• Technical Data - includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data - includes your username and password, benefits which you may have signed up to as a Member, your employment history, tournament history, details of any disciplinary matters, qualifications, annual Seminar attendance record, CPD Points, Advanced Programme Assignment marks and prior learning accreditation information (where provided).
• Usage Data - includes information about how you use our website, and services.
  Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not generally collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union Membership, information about your health and genetic and biometric data). However, we may in certain circumstances require such information where we have a valid legal basis to process it. This will either be for a reason permitted by the applicable data protection laws or with your explicit consent.

Criminal Records Data
The PGA uses the Disclosure and Barring Service (DBS) to assist it in ensuring that those who take up appointments do not pose a risk to the children in its care. The PGA may therefore process criminal records data disclosed by the DBS (formerly known as CRB). This will be processed in accordance with the DBS Code of Practice for Registered Persons. We also use the regional equivalents in Scotland and Ireland, PVG, Access NI and Garda Vetting, the information processed is in accordance with each organisations code of practice.

Scottish Fair Processing Notice
The following information applies to PGA Professionals and volunteer golf coaches conducting 'regulated work' in Scotland, and whom are Members of (or applying for Membership of) the Protecting Vulnerable Groups (PVG) Scheme. 

The data protection laws require that you are informed about how your personal information will be used. For the purposes of child wellbeing & child protection matters in Scotland, if your club receives information of concern, the club may share information about you with the sport’s Governing Bodies in Scotland (Scottish Golf) and the appointed representatives of the partners within the Scottish Golf Child Protection Panel, including The PGA.

This may be related to, but not exclusively restricted to, where it has been alerted to circumstances that might affect your status as a Member of the PVG scheme for regulated work with children or protected adults or your suitability to carry out the regulated work role for which you have applied/been appointed or already doing. 

In the event such sharing is deemed necessary, it will normally only be carried out between the registered Child Protection Officers in the Club, Governing Body, and those appointed representatives within the Scottish Golf Child Protection Panel, including The PGA.

We collect any information about criminal convictions and offences.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions
You may give us your Identity, Contact, Profile and Financial Data by filling in forms renewing your Membership or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for or renew your Membership;
create an account on our website;
subscribe to any Members benefits;
request marketing to be sent to you;
enrol as an assistant;
enter a tournament; or
give us some feedback.

Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties’ analytics providers such as Google based outside the EU;
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU; or
Identity and Profile Data of assistants from the University of Birmingham and the University of the Highlands & Islands 
Any data available in the public domain, such as court results or news clips.

3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data however in certain circumstances it may be the only legal basis which we can rely open. Where we do need to rely on your consent it will be very clear at the point at which we collect the data from you that we are relying on your consent. Where we have obtained your consent to process certain personal data you have the right to withdraw your consent to that processing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in table format, descriptions of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

The initial table is applicable to all individuals whose personal data is processed by The PGA.  We have also included some additional tables to cover specific scenarios where we process your personal data. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need more details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below then please do not hesitate to contact us.

If you are a Member of The PGA, the following table will also apply to your personal data which is processed by The PGA:

​If you are an assistant of The PGA, the following table will also apply to your personal data which is processed by The PGA:

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or in the case of Members in relation to benefits available to Members, and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside The PGA.  We will share Members personal information with legitimate third-party organisations, such as partners and benefits providers, who are involved with or support The PGA unless you have opted out of receiving such information.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences or if you do not have an account with The PGA by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.  Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.

Service providers acting as processors based inside and outside the EU who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
University of Birmingham and the University of the Highlands & Islands.
Members Benefit Providers based both inside and outside the EU.
Golf Clubs and other employers.
PGA Regional Offices. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. 

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. 

6. Data security
We have 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, agents, 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.

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

7. Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.