We value your data and take your privacy seriously.
This policy describes how The R&A collects and uses your personal information when you interact with The R&A via our Websites (www.randa.org, www.theopen.com, shop.theopen.com and www.rules.golf) or otherwise, including when you purchase tickets for The Open and other R&A championships, or when you apply to work or volunteer at The R&A.
We have tried to keep it simple, so please take the time to read this policy in full to understand our practices regarding your personal information. This policy was last updated in May 2020.
Who are we?
The R&A comprises R&A Championships Limited (SC247047), R&A Group Services Limited (SC247048), R&A Rules Limited (SC247046), R&A Trust Company (No. 1) Limited (SC247045), R&A Trust Company (No.2) Limited (SC247049) and The R&A Foundation (SC247050) (together “The R&A”, “we”, “us” and “our”). This policy applies to any and all of the organisations within The R&A.
The R&A will share your personal information with their group companies and their suppliers and service providers for the purposes set out below only.
If you would like to contact us about this policy, you can do so by:
· emailing us at email@example.com; or
· writing to us at F.A.O. Data Privacy Manager, The R&A, Beach House, Golf Place, St Andrews, Fife, KY16 9JA.
How we collect information about you
We may collect personal and non-personal information about you when you interact with The R&A via the Websites or:
· if you sign up to receive our newsletters, emails or alerts;
· if you provide feedback in relation to any of the Websites;
· that you provide in relation to any user account you may hold with us for any of the Websites;
· when you sign up to The One Club;
· that you provide when you register for and participate in our Rules Schools and other Rules events;
· when you enter prize draws or competitions;
· when you choose to complete any surveys we send you;
· that you provide in relation to any enquiry, order or transaction you carry out through any of the Websites including ticket sales for The Open, including your name, address, phone number, email address and credit/debit card details; and
· that you provide if you apply to work or volunteer at The R&A.
We use software that collects personal information that you provide in relation to enquiries, orders or transactions that you start on any of the Websites but which you then abandon or do not complete, i.e. data may be captured regardless of whether you click “next” or “submit” on the relevant page.
We also collect certain non-personal information when you visit and use any of the Websites, our apps or Wi-Fi at R&A events. For example, we may collect and store your IP address, reference site domain name, and demographic information. We also may collect information including, but not limited to, traffic data, location data and usage while on any of the Websites or when using our apps or Wi-Fi at R&A events. We will only collect such data in aggregate form (so that no individual user is identified).
How we use your personal information
Orders or purchases via the Websites or in store
We collect your name, contact and payment details and other personal information you provide when you order or purchase products and services from us via our Websites or in store, including when you purchase tickets for The Open and other R&A championships. The R&A will use this personal information to process your order/purchase. Where you have purchased products/services from the Websites, we will retain the payment details you provided for that purchase for 12 months from the date of the purchase to allow us to process any refund that may be due to you. This processing of your information is necessary for the performance of our sales contract with you.
We will retain the information you provide to us for your purchase for a period of ten years from the date of your purchase for analysis purposes to understand audiences for The Open at each venue and to improve efficiencies at R&A championships and team events in general and at particular venues. This processing of your personal information is necessary for our legitimate interests of understanding our customers and providing better products and services for our customers. We will not store your payment details for this purpose.
We collect information about you when you start an enquiry, order or transaction on the Website but which you then abandon or do not complete. We collect your personal information even if you do not click “next” or “submit” on the relevant page. We may use this information to contact you by email about that enquiry, order or transaction. Such contact will be to determine if we can offer any assistance to help you complete the enquiry, order or transaction, or if we can provide alternative products or services that may be of greater interest to you. We will not store your payment details for this purpose. The legal basis for processing your personal information in this way is that it is necessary for our legitimate interests to promote our products/services to you. When we collect your information, we will give you the option not to receive these emails. Otherwise, we will retain your personal information for ten years for our legitimate interests of understanding our customers and users of our Website.
Enquiries, providing feedback or complaints
We collect your name, contact details and other personal information you provide when you make an enquiry or provide feedback to The R&A. We may collect this information via completion of online forms or by corresponding or speaking with us by telephone, email, letter, in person or otherwise. We will use your personal information to process your enquiry, to follow up on your feedback and to resolve any complaint. We will keep your personal information for a period of 12 months from the date of your enquiry, feedback or complaint or the date of our last correspondence with you. This is to allow us to be able to respond to any follow up queries or subsequent correspondence from you on your enquiry, feedback or complaint. This processing is necessary for our legitimate interests in providing a better experience for you and others who interact with The R&A and in improving our customer service and our business operations.
Registering to receive our newsletters, emails and alerts
We will collect your name and email address and other personal information you provide when you register to receive our newsletters, emails or alerts via our Websites. We will use this information to send you the newsletters, emails or alerts you have requested. We will send you these with your consent which we obtain at the point you request these regular updates. You may withdraw your consent to processing your personal information for this purpose at any time by contacting us or by clicking “unsubscribe” in the communications we send you. We will retain this information until you withdraw your consent.
Membership of The One Club
We process the personal information you provide on registration with The One Club to provide you with and to maintain your membership of The One Club and to provide you with the services you expect from membership of The One Club. This processing is necessary for the performance of our contract with you for your membership of The One Club in accordance with the terms and conditions of The One Club. We retain your personal information and process it for as long as you are a member of The One Club. The R&A cannot administer your membership of The One Club if you do not provide the information required by the registration process.
User account registration with our Websites
When you create a user account with one of our Websites, we collect your name and contact details and other personal information you provide during user account registration. We will retain this personal information for the duration of your user account with us. We will process your personal information to administer and maintain your user account. This processing of your personal information is necessary for our legitimate interests of allowing you to engage with us and to complete transactions for our products/services more easily.
We may use the personal information we collect as part of our customer relationship with you to inform you by email about exclusive offers and promotions we think may be of interest to you. When we collect your personal information, we will give you the option not to receive these emails. You can change your mind at any time by contacting us or clicking “unsubscribe” in the emails we send you. This is necessary for our legitimate interests for promoting our products and services.
If you have consented to receive marketing emails from The Open’s official patrons and partners, we may share your personal information with those official patrons and partners for those purposes.
Your interactions with The R&A
Individuals interact with us in multiple ways and provide us with personal information in different contexts. The R&A may use your personal information to obtain a profile of your different interactions with us and to understand your preferences This is necessary for our legitimate interests of personalising your experience and for tailoring the content, offers and promotions we send to you.
When you visit our Websites or receive e-mails from us (including newsletters) we may automatically collect the following technical information:
· technical information, including the Internet protocol (IP) address used to connect your computer device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
· information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Websites (including date and time);
· page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us;
· when we e-mail you, such e-mails may contain tracking facilities. Activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but is not restricted to: the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.
We may collect information in an aggregated form (so that no individual user is identified) for statistical analysis to allow us to understand our customers and improve our services and performance including the functionality of our Websites and user experience.
The legal basis for processing your personal information (as well as pseudonymised or anonymised information generated from your personal information) in this way is that it is necessary for our legitimate interests of providing a better experience for you and other users of our Websites, promoting our products and services and understanding our customers and users of our Websites. We will retain this information for as long as is necessary for the relevant activity.
Wi-Fi at R&A events
When you register to use Wi-Fi at The Open, we collect the type of device and IMEI number of the device you use to connect to the Wi-Fi. We collect these to ensure we only present you with the registration page once for the Wi-Fi. Otherwise, each time your device drops off and back onto the Wi-Fi, we would need to ask you to register again. We will retain this information for one year from the date of collection. The legal basis for processing your personal information in this way is that it is necessary for our legitimate interests to provide the best possible customer experience.
We collect and use personal information that you provide to us when you enter one of our competitions to administer the competition including to communicate with you, whether your entry has been successful or not, and fulfilment of prizes. Our legal basis for this processing is your consent which you give on entering the competition. We will retain your information for as long as is necessary for those purposes. If you withdraw your consent, we cannot process your competition entry.
The R&A Rules Academy and Rules Schools
We collect personal information from you if you register to participate in The R&A’s Rules Academy via www.randa.org/rulesacademy or if you register to participate in any of our Rules Schools. Where appropriate, we will collect payment information from you and use this to process payment due to us. We will retain your payment details for as long as is necessary to process the payment and any refund due to you.
Once enrolled on a programme, we will use your personal information to deliver the programme to you and to provide you with information about your qualification. This processing is necessary for the performance of our contract with you for your participation on a programme at The R&A’s Rules Academy or our Rules School.
We may confirm your examination mark to a third party wishing to verify your examination mark. We will retain your personal information (but not your payment details), indefinitely, unless you decide to close your Rules Academy account, in which case we will delete your account immediately and you will have to complete the registration process again if you wish to participate in the Rules Academy. As the organiser of The R&A Rules Academy programme and Rules Schools, we have a legitimate interest in retaining this information indefinitely so that we can inform you and relevant third parties about your qualifications.
When you register to participate in The R&A’s Rules Academy via www.randa.org/rulesacademy or if you register to participate in any of our Rules Schools, we may share your contact details and other relevant information, including exam results, with the national and/or local golf bodies for your country of residence. That national or local golf body may use your contact details to contact you about rules schools, golf education, volunteering opportunities and golf events. It is in the legitimate interests for those national and local golf bodies to use your data in this way for the purposes of developing the sport of golf in their territory. For more information about how the national and local golf bodies in your territory may use and protect your personal information, please see their privacy policies.
Applying to our Greenkeeping Machinery Programme or our Greenkeeping Scholarship Programme
If you apply to our Greenkeeping Machinery Programme or our Greenkeeping Scholarship Programme, The R&A will process the information that you provide on the application form or otherwise to process your application, to contact you in connection with your application and, if you are successful to provide you with the scholarship award or the greenkeeping machinery, as applicable.
Our legal basis for processing your personal information provided on the application is that it is necessary for our relationship with you established by your application. The R&A cannot process your application if you do not provide the information required by the form.
If you apply to our Greenkeeping Scholarship Programme, we may share your personal information that you provide to us with the further or higher education institute at which you are enrolled who will assist The R&A with the application process.
If your application for the Greenkeeping Machinery Programme or the Greenkeeping Scholarship Programme is successful, The R&A will process your personal information to provide you with the award. We will retain your personal information for seven years from the date of the award. Our legal basis for retaining your personal information is that it is necessary for The R&A’s legitimate interest in administering the programmes, monitoring applications and handling any enquiries in the event of any dispute concerning the grant of a scholarship or concerning a successful decision to enrol you on any of the programmes.
We retain unsuccessful applications for a period of five years from the date of the decision not to progress your application for our legitimate interests of being able to respond to any follow up queries on the application and for the purposes of any subsequent applications.
Applying to Work or Volunteer at The R&A
We collect personal information from you if you apply to work at The R&A. We will only use the information you supply to us to process your application, to make a decision about your recruitment or appointment and to monitor recruitment statistics. This may include checking you are legally entitled to work in the UK.
We use your personal information collected during the application process on the following legal bases:
· Where it is necessary to process your application or to comply with a legal or regulatory obligation; or
· Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. Those legitimate interests include demonstrating compliance with legal, regulatory and corporate governance obligations, use as part of investigations by regulatory bodies, or in connection with legal proceedings and requests, good employment practice and ensuring safe working practices.
We may collect information about criminal convictions as part of the recruitment process, but we will only do so if it is appropriate given the nature of the role and where we are legally able to do so.
We will share your personal information in accordance with the section below “Who we share your information with”. Where we want to disclose information to other third parties, for example where we want to take up a reference or undertake criminal records checks (where appropriate) through Disclosure Scotland, we will not do so without informing you beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for three months from the decision not to progress their applications in case of a future vacancy which we may invite them to apply for, following which we will delete it. We will retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
If you have applied as a volunteer or temporary worker at an R&A championship or team event, and you are successful, we will record, process, keep and securely hold personal information as part of your volunteering / work record in accordance with the section below “Volunteers and Temporary Workers at R&A Championships and Team Events”.
Volunteers and Temporary Workers at R&A Championships and Team Events
The kind of information we hold about you
We typically collect personal information from you through the recruitment process and in the course of your engagement with us, as well as from publicly accessible sources, via our IT and other systems and third parties such as employment agencies.
We may collect, store, and use your personal information, including:
· Personal details such as name, address, date of birth, photographs, telephone numbers, personal email addresses, next of kin, and emergency contact information.
· Financial details such as your National Insurance number, bank account details, payroll records, tax information, pay and/or expenses.
· Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter).
· Work records (including any terms issued to you and time/attendance records) and CCTV footage.
· Information about your use of our information and communications systems.
· Images of you taken at an R&A championship or team event.
We may also collect, store and use "special categories" of more sensitive personal information (which requires a higher level of protection) such as health information and information about criminal convictions and offences.
How we use information about you and our legal bases for doing that
We will use personal information (or special categories of personal information) about you:
· To pay you, deduct tax and National Insurance contributions or reimburse expenses.
· For operational reasons, to maintain records and ascertain compliance with policies.
· To promote the R&A championships and team events where we use images and footage of you taken at an R&A championship or team event.
· To ascertain your fitness to work, managing sickness, and health and safety obligations.
· To ensure information security and to protect our networks/systems and personal information of employees and customers/clients.
· For equal opportunities monitoring and to conduct statistical analysis.
We will only use your personal information when the law allows us to. Most commonly:
· Where we need to perform our contract with you, or to comply with a legal or regulatory obligation (e.g. our obligations to you as your employer under employment protection and health safety legislation).
· 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. Those legitimate interests include demonstrating compliance with legal, regulatory and corporate governance obligations, as part of investigations by regulatory bodies, or in connection with legal proceedings and requests, good employment practice and ensuring safe working practices.
We may also use your personal information in the following situations, which will be rare:
· Where we need to protect your interests (or someone else's interests).
· Where it is needed in the public interest or for official purposes.
We may also process special categories of personal information about you as follows:
· In limited circumstances, with your explicit consent.
· Where we need to comply with a legal or regulatory obligation (e.g. our obligations to you as your employer under employment protection and health safety legislation).
· Where it is needed in the public interest, such as for equal opportunities monitoring, or where it is needed to assess your working capacity on health grounds.
How long we retain information about you
We will only retain your personal information for as long as necessary for the purposes we collected it for.
Once you are no longer a volunteer or temporary worker for The R&A, we will record, keep, and securely hold the information provided as part of your application and during your engagement in our Human Resources files for a period of two years from commencement of your service for The R&A. This includes your application form, CV, references, contact information, and details of the terms of your engagement, your role, working hours, attendance, pay (if applicable), dates of engagement, any illness records, accidents or injuries. This will also include confirmation of criminal records checks carried out by Disclosure Scotland (which is only requested in limited circumstances).
Retaining this information is necessary to meet our legitimate interests of maintaining work records and good working practice, for dealing with any legal claims and for meeting any legal, regulatory and/or governance obligations.
For those in paid roles, we will destroy your bank details within one month of the last date of your engagement. We will retain details of payments made through our payroll system will for 7 years after the date on which your engagement ends, in line with HMRC requirements.
Information we receive about you from other sources
We work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them. We may also receive information if you have provided permission to other organisations to share it with us. Before providing permission to such third party organisations to share your personal information, you should check their privacy notices carefully.
We may receive information from publicly available sources (where possible) to keep your information up to date, for example, from the Post Office’s National Change of Address Database. We may occasionally purchase the contact details of people who might be interested in hearing from us. Before purchasing such information, we will check the wording used when your information was originally collected, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties.
Where you are a registered user of Facebook, we will use your email address in an encrypted format to enable Facebook to find other registered users of their services that share similar interests to you based on: (1) information that we observe about you from your different interactions with us; and (2) the information Facebook holds about you.
Our legal basis for processing information shared with us in this way is that it is necessary for the purposes of The R&A’s legitimate interest in understanding how our business is performing and considering how to improve our performance. We will retain information that we receive in this way for as long as long as necessary for the purposes for which we received it.
Who we share your information with
Retention of your personal information
We will only retain your personal information for as long as necessary for the purposes we collected it for and for as long afterwards as is necessary to comply with our legal obligations or as is necessary in our legitimate interests to retain it. Therefore, some information may be kept for more or less time depending on how long we reasonably feel it is required for. We have provided information about our retention periods in relation to certain pieces of personal information above. We review these retention periods on a regular basis.
If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
We fully co-operate with the police and other law enforcement agencies. We reserve the right to report to the police or any other such agencies any activities that we reasonably believe to be unlawful.
Linking to other websites
Your personal information may be transferred to, and stored in, countries outside of the UK and EU for the above purposes. The R&A will take steps to ensure your personal information is adequately protected in countries outside of the UK and EU. Please contact us if you would like more details on safeguards used by The R&A to protect personal information for these transfers.
Your data protection rights
You have the right to:
· access the personal information that we hold about you in many circumstances;
· ask us to delete or correct any personal information that we hold about you;
· prevent us processing your personal information;
· port your personal information in certain circumstances;
· not be subject to a solely automated decision;
· withdraw any consent that you have given. This does not affect the lawfulness of processing based on consent before withdrawal; and
· lodge a complaint with the UK regulator, the Information Commissioner’s Office, if you have concerns about how we use your personal information. Please see https://ico.org.uk/concerns/ to find out more.