Data transfer in preparation for the World Handicapping System in England

Last week, the following communication was sent out to GCMA members from the Chief Executive, Tom Brooke. With the launch of the World Handicap System just weeks away, the team at the GCMA have worked tirelessly over the last week in an attempt to reach a point of clarity on the issues surrounding GDPR and the transfer of club member data to England Golf. Unfortunately, despite our very best efforts, there remains an extremely grey area with conflicting information and points of view shared between England Golf, the National Golf Club Advisory Association and the ISV’s (Intelligent Golf, Club Systems etc) This is a frustrating situation for us, as our ideal position would be to provide our members with clear guidelines and advice, but in this particular case we must stop short of recommending a specific course of action, due to the potential GDPR legal implications involved. We are therefore setting out for our members all relevant information and points of reference that we have available, for each club to carefully consider before completing the transfer of member data to England Golf for the purposes of administering the World Handicap System. England Golf WHS Privacy Notice  The GCMA HQ Team, along with members of the Board and our Regional Managers, took part in a live ‘zoom’ Q&A with England Golf on Tuesday, 29th September, to seek clarity on their position. England Golfs Head of Legal, Emily Green, along with Richard Flint, Club Support Director, responded to a number of questions put forward by our Regional Managers. The key topic was surrounding the need for the Home Union to obtain email addresses for anyone wishing to obtain a handicap under the new system. England Golf’s position remains that there is a Legitimate Interest for them to obtain this data in order for the WHS to be operated. England Golf claim that email addresses will be required to act both as a unique identifier as well as for England Golf to communicate directly with golfers on handicapping matters. CDH numbers will become invalid once the WHS is launched and England Golf believe that the CDH number format has been the cause of a large number of duplication issues in the past. Their position was again communicated that data WILL NOT be shared with any third party other than County Unions, software providers and, if required, legal services such as the HMRC. Furthermore, data will not under any circumstances be shared for commercial interests and this point is reflected in their WHS Privacy Notice. If a golfer does not have an email address or access to a computer, England Golf have stated that a shared email address is acceptable and that clubs should support members by providing access to a computer within the clubhouse if necessary. For your reference, the England Golf WHS Privacy Notice is attached here. It is important to note that EG’s WHS Privacy Notice differs to their generic Privacy Notice which is available on their website. NGCAA Guidelines  The CEO of the NGCAA has confirmed that they have referred the matter to two Barristers and a Solicitor, before publishing their recommendation report. Whilst the NGCAA  recognise that England Golf ‘may’ have legitimate interest, this is not necessarily the case. The NGCAA reference the fact that every golf club will have a contract between the ‘Club’ and each individual ‘Member’. They suggest that contract terms do vary from club to club and therefore this should be carefully reviewed by any individual...
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