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PRIVACY NOTICE


WHAT IS THE PURPOSE OF THIS DOCUMENT?
Ross County Football Club is committed to protecting the privacy and security of
your personal information.
This privacy notice describes how we collect use and protect personal information
about you in accordance with the General Data Protection Regulation (GDPR).
It applies to all employees, workers, contractors, candidates, sponsors and
customers.
Ross County Football Club Limited, Ross County Football Club (1998) Limited and
Ross County Foundation (“Ross County”, “RCFC”, “we”, “us” or “the club”) is a “data
controller”. This means that we are responsible for deciding how we hold and use
personal information about you. We are required under data protection legislation
to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers, contractors,
candidates, sponsors and customers. This notice does not form part of any contract
of employment or other contract to provide services. We may update this notice at
any time.

It is important that you read this notice, together with any other privacy notice we
may provide on specific occasions when we are collecting or processing personal
information about you, so that you are aware of how and why we are using such
information.
We will comply with data protection law. This says that the personal information we
hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not
used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those
purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.


THE KIND OF INFORMATION THAT WE HOLD 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.
There are “special categories” of more sensitive personal data which require a
higher level of protection.


We may collect, store, and use of the following categories of personal information
about you depending on the purpose of your activity or interaction with us:
☒Personal contact details such as name, title, contact/ delivery address, telephone
numbers and personal email addresses
☒Date of Birth
☒Gender
☒Marital Status and dependants
☒Next of kin and emergency contact information
☒National Insurance number
☒Bank Account details, payroll records and tax status information
☒Salary, annual leave, pension and benefits information
☒Start/End date
☒Location of employment or workplace☒ Copy of Passport
☒ Copy of Birth Certificate
☒Recruitment information (including copies of the right to work documentation,
references and other information included in a CV or cover letter or as part of the
application process).
☒Employment records (including job titles, work history, working hours, training
records and professional memberships).
Copy of driving licence
☒Compensation history
☒Performance information
☒Disciplinary and grievance information
☒CCTV Footage and other information obtained through electronic means such as
swipe card records
☒Information about your use of our information and communication systems
☒Photographs
☒ Player Video
☒Credit/debit card number/ expiry date
☒Incomplete tasks / transactions like abandoned baskets

☒Record of attendance at events and participation in prize draws, competitions,
raffles, lotteries.
☒Marketing Preferences
☒Data provided by social media accounts
We may also collect, store and use the following “special categories” of more
sensitive personal information for our team members:
 ☒Information about your race or ethnicity and sexual orientation.
 ☒Information about your health, including any medical condition, health and
sickness records.
 Information about criminal convictions and offences.


HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about employees, workers, contractors, candidates,
sponsors and customers through:
 The application and recruitment process, either directly from candidates or
sometimes from an employment agency or background check provider. We
may sometimes collect additional information from third parties including
former employers, credit reference agencies or other background check
agencies.
 The on-line and offline sales of our services eg: (Tickets, Hospitality, Lottery,
50/50, shop, courses, mascot, sponsorship)
 Data provided via social media platforms where you register for an account
with us using a social media account.
 If you are a football player we may also collect personal data about you from
any club, school, or other organisation you are affiliated with or from other
referrals such as from coaches or talent scouts.
 If you are providing us with family members and emergency contacts or next
of kin data then they have a right to know and to be aware of what personal
data we had about them, how we collect it and how we use and may share
that information. Please share this privacy policy with those of them whom
you feel are sufficiently mature to understand it. They also have the same
rights as set out in this privacy policy.


HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most
commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. 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.
4. Where you have agreed to receive marketing information from Ross County
Football Club about products and services.
We may also use your personal information in the following situations, which are
likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest or for official purposes.


WITHDRAWING CONSENT
Where you have given us your consent to use your personal data in a particular
manner, you have the right to withdraw this consent at any time, which you may do
by contacting us as per the details outlined in this policy .
Please note however that the withdrawl of your consent will not affect any use of
the data made before you withdrew your consent and we may still be entitled to
hold and process the relevant personal data to the extent that we are entitled to
do so on a legal basis other than your consent.
Withdrawing consent may also have the same effects as not providing the
information in the first place, for example we may no longer be able to provide
certain benefits you.


SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION
As an employee, worker or contractors of Ross County Football Club you can
reasonably expect that Ross County Football Club will use your information for
internal record keeping, to carry out the administrative and management
requirements of an Employer. This will include paying you your salary via your bank
account, calculating and making tax and NI contributions, and ensuring that you
have the tools, training and competency required to carry out your role. We will also
use your data to safeguard your personal safety, health and welfare whilst at work.
As a supporter of Ross County Football Club you can reasonably expect that Ross
County Football Club will use your information to deliver the product or service you
have engaged with us to provide. With your consent we will also use your
information for marketing of other products and services.


PRIVACY NOTICE
Ross County Football Club may be required to perform and provide statistical
analysis on the data that we hold and collect. Such data will normally be
anonymised for this purpose, unless disclosure of individuals is a legal requirement of
the process. At this point Ross County Football Club would gain your consent for
your personal data to be used in such a way.
It is important to Ross County Football Club that the integrity of the sport is protected,
meaning that player personal information may be used to uphold the rules,
regulations and decisions of the Scottish FA, The Scottish Professional Football
League and the charter, regulations and rules, etc of UEFA and FIFA, including in
connection with any investigation, enquiry or adjudication and any related action or
fine.
If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to
perform a contract we have entered into with you (such as paying you or providing
a benefit), or we may be prevented from complying with our legal obligations (such
as to ensure the health and safety of our workers).
Change of purpose

We will only use your personal information 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
information 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 information without your knowledge
or consent, in compliance with the above rules, where this is required or permitted
by law.


HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
”Special categories” of particularly sensitive personal information require higher
levels of protection. We need to have further justification for collecting, storing and
using this type of personal information. We have in place an appropriate policy
document and safeguards which we are required by law to maintain when
processing such data. We may process special categories of personal information
in the following circumstances:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations or exercise rights in connection
with employment.
3. Where it is needed in the public interest, such as for equal opportunities
monitoring or in relation to our occupational pension scheme.
Less commonly, we may process this type of information 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. We may also process such information about
members or former members in the course of legitimate business activities with the
appropriate safeguards.
It is important to Ross County Football Club that the integrity of the sport is protected,
meaning that player personal information may be used to uphold the rules,
regulations and decisions of the Scottish FA, The Scottish Professional Football
League and the charter, regulations and rules, etc of UEFA and FIFA, including in
connection with any investigation, enquiry or adjudication and any related action or
fine. As well as to comply with any anti-doping rules or guidance, in accordance
with applicable laws.
Our obligations as an employer
We will use your particularly sensitive personal information in the following ways:

• We will use information relating to leaves of absence, which may include
sickness absence or family related leaves, to comply with employment and
other laws.
• We will use information about your physical or mental health, or disability status,
to ensure your health and safety in the workplace and to assess your fitness to
work, to provide appropriate workplace adjustments, to monitor and manage
sickness absence and to administer benefits.
• Criminal convictions which restrict attendance to football matches.
We may not collect any of the above types of special category personal data
about you. In relation to the special category personal data that we do process we
do so on the lawful basis that the processing is necessary for:
 Fulfilment of a legal obligation
 Support for individuals with a particular disability or medical condition; or
 Based on your explicit consent
Do we need your consent?

We do not need your consent if we use special categories of your personal
information in accordance with our written policy to carry out our legal obligations
or exercise specific rights in the field of employment law. In limited circumstances,
we may approach you for your written consent to allow us to process certain
particularly sensitive data. If we do so, we 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. You should be aware that it is not a condition
of your contract with us that you agree to any request for consent from us.

INFORMATION ABOUT CRIMINAL CONVICTIONS
We may only use information relating to criminal convictions where the law allows
us to do so. This will usually be where such processing is necessary to carry out our
obligations and provided we do so in line with our data protection policy.
Less commonly, we may use information relating to criminal convictions where it is
necessary in relation to legal claims, where it is necessary 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.
We may also process such information about members or former members in the
course of legitimate business activities with the appropriate safeguards.
We may also collect, store and use the above noted “special categories” of more
sensitive personal data regarding you criminal convictions which restrict attendance
to football matches.

DATA SHARING
We may have to share your data with third parties, including third-party service
providers.
We require third parties to respect the security of your data and to treat it in
accordance with the law.
We may transfer your personal information outside the EU.
If we do, you can expect a similar degree of protection in respect of your personal
information.
In addition, in order to administer and uphold the rules, charters, regulations and
decisions of the Scottish FA, the Scottish Professional Football League, UEFA and FIFA,
we may share some personal data with such bodies (including special categories of
personal data). For example, this may occur in connection with any investigation,
enquiry or adjudication and any related action or fine. This information may be
stored by the relevant body in order to maintain a record of relevant Club history
and to assist in the development of good practice within the professional game. If
you are going on international travel for work, we may transfer your personal
information outside of the EU. The information transferred will be limited to what is
necessary to enter into the contract to provide accommodation, travel, or
attendance at overseas matches.
We do not envisage that we will use Automated Decision Making when processing
any PII Data.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law,
where it is necessary to administer the working relationship with you or where we
have another legitimate interest in doing so.
Which third-party service providers process my personal information?

”Third parties” includes third-party service providers (including contractors and
designated agents). The following activities are carried out by third-party service
providers: payroll, pension administration, benefits provision and administration, IT
services.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security
measures to protect your personal information in line with our policies. 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 purposes
and in accordance with our instructions.

When may we share your data with third parties?

We may share your personal information with third parties, for example in the
context of the possible sale or restructuring of the business. We may also need to
share your personal information with a regulator or to otherwise comply with the law.
We may be required to disclose your information to Insurers and/or Professional
Advisors insofar as is reasonably necessary for the purpose of obtaining or
maintaining insurance coverage, risk management, salary and benefits, IT services,
professional advice or the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
We may disclose certain items of information (name, date of birth, contact details,
Passport or ID number, physical size or details of illness or injury) to our suppliers
insofar as is reasonably necessary for the booking of travel or accommodation,
personal protective equipment or occupational health services. Ross County
Football Club will always seek to advise you of any sharing of this information and
gain your consent prior to the sharing of data, except where vital interests preclude.
In addition to the specific disclosures above, Ross County Football Club may disclose
your personal data where such a disclosure is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or the
vital interests of another person. We may also disclose your personal data where
such disclosure is necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court
procedure.
Ross County Football Club does not, has not, and shall never, sell your personal data
to Third Parties for marketing purposes. We will share limited contact information with
McEwan Fraser Legal Services LLP

Transferring information outside the EU
Ross County Football Club is required to provide limited player information to FIFA.
We may also be required to transfer data across borders in the event of an
emergency situation overseas.
At all times, Ross County Football Club shall ensure that the transfer of personal data
over an international border is protected by appropriate safeguards, namely the use
of standard data protection clauses adopted or approved by the European
Commission OR through binding corporate rules, a copy of which can be obtained
via your contact at any time.
Ross County Football Club is required to provide limited player information to FIFA.
We may also be required to transfer data across borders in the event of an
emergency situation overseas. Ross County Football Club is required to provide
limited player information to FIFA.
At all times, Ross County Football Club shall ensure that the transfer of personal data
over an international border is protected by appropriate safeguards, namely the use
of standard data protection clauses adopted or approved by the European
Commission OR through binding corporate rules, a copy of which can be obtained
via your contact at any time.
We may also be required to transfer data across borders in the event of an
emergency situation overseas.
At all times, Ross County Football Club shall ensure that the transfer of personal data
over an international border is protected by appropriate safeguards, namely the use
of standard data protection clauses adopted or approved by the European
Commission OR through binding corporate rules, a copy of which can be obtained
via your contact at any time.
Ross County Football Club is required to provide limited player information to FIFA.
We may also be required to transfer data across borders in the event of an
emergency situation overseas.
At all times, Ross County Football Club shall ensure that the transfer of personal data
over an international border is protected by appropriate safeguards, namely the use
of standard data protection clauses adopted or approved by the European
Commission OR through binding corporate rules, a copy of which can be obtained
via your contact at any time.

We have put in place appropriate security measures to prevent your personal
information from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to your personal information to
those employees, agents, contractors and other third parties who have a business
need to know. They will only process your personal information on our instructions
and they are subject to a duty of confidentiality.

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.


DATA RETENSION
How long will you use my information for?
We do not retain personal information in an identifiable format for longer than is
necessary.
If we have a relationship with you (e.g. you are an employee, supporter, sponsor),
we hold your personal information for a maximum of 7 years from the date our
relationship ends, the only exception to this is some Health and Safety records which
we are required to keep for a minimum of 40 years. We hold your personal
information for this period to establish, bring or defend legal claims. Our relationship
ends when the contract is terminated.
The only exceptions to the periods mentioned above are where:
 The law requires us to hold your personal information for a longer period, or
delete it sooner;
 Where you have raised a complaint or concern regarding a service offered
by us, in which case we will retain your information for a period of 6 years
following the date of that complaint or query; or
 You exercise your right to have the information erased (where it applies) and
we do not need to hold it in connection with any of the reasons permitted or
required under the law.
If we have a relationship with you (e.g. you are an employee, supporter, sponsor),
we hTo 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.
In some circumstances we may anonymise your personal information so that it can
no longer be associated with you, in which case we may use such information
without further notice to you.


RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and
current. Please keep us informed if your personal information changes during your
working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (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.
• Request correction of the personal information that we hold about you. This
enables you to have any incomplete or inaccurate information we hold about
you corrected.
• Request erasure of your personal information. This enables you to ask us to
delete or remove personal information 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 information where you have exercised your right to object to
processing (see below).
• Object to processing of your personal information where we are relying on a
legitimate interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on this
ground. You also have the right to object where we are processing your
personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables
you to ask us to suspend the processing of personal information about you, for
example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information,
object to the processing of your personal data, or request that we transfer a copy of
your personal information to another party, please contact
dataprotection@rosscountyfootballclub.co.uk

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise
any of the other rights). However, we may charge a reasonable fee if your request
for access is clearly unfounded or excessive. Alternatively, we may refuse to comply
with the request in such 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 the information (or to exercise any of your
other rights). This is another appropriate security measure to ensure that personal
information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the
collection, processing and transfer of your personal information for a specific
PRIVACY NOTICE
purpose, you have the right to withdraw your consent for that specific processing at
any time. To withdraw your consent, please contact
dataprotection@rosscountyfootballclub.co.uk. Once we have received notification
that you have withdrawn your consent, we will no longer process your information
for the purpose or purposes you originally agreed to, unless we have another
legitimate basis for doing so in law.


DATA PROTECTION OFFICER

We have not appointed a Data Protection Officer however if you have any
questions about this privacy notice or how we handle your personal information,
please contact
dataprotection@rosscountyfootballclub.co.uk or write to us at:
Data Protection Dept.
Ross County Football Club
Global Energy Stadium
Victoria Park
Dingwall
IV15 9QZ
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.

CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide
you with a new privacy notice when we make any substantial updates. We may
also notify you in other ways from time to time about the processing of your personal
information.