07.10.20 Wales Golf WHS GDPR Update and Key Dates NGCAA WHS - GDPR advice 23.09.20 With the launch of the World Handicap System just weeks away, the team at the GCMA have been in communication with Wales Golf over the last week, for us to better understand the launch process and in particular, answer questions surrounding GDPR. You may have read the email to members last week on the same subject with England Golf. The issue of GDPR remains a ‘grey area’ and therefore we have done our best to present our members with all of the information and guidance available, both from Wales Golf as well as from 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. Wales Golf On Tuesday of this week, Wales Golf wrote to all clubs to provide an update and provide guidance on the process, timelines and in particular, the intentions for transfer of member data on to the new system. For further details, please see here: The Committee of the GCMA Welsh Region attended a call with Wales Golf on Thursday 8th October and the MD of one of the leading ISV’s was also present. It was clear that there remains some uncertainty between Wales Golf and the ISV’s regarding the transfer of data and this position was not settled on the call. 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 Wales 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 responsible for data management at their club as part of this process. The NGCAA report is attached here. Information Commissioners Office (ICO) We contacted the ICO last week and received the following response: (although this response refers to England Golf, we can assume that the same would apply for any of the Home Unions). ‘From the information you have provided, it appears that it would be up to your organisation (ie. The Club) as the controller, to decide which lawful basis would best fit your purposes. Therefore, as long as it is done in line with the data protection principles, your organisation would be able to share the personal data with England Golf by relying on legitimate interests as a lawful basis. If this processing is for a new purpose that is additional...
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