Privacy Policy

This notice applies to all prospective players who submit a ‘Prospective Player Form’ to Wolverhampton Wanderers Football Club (1986) Limited (the Club, we, us) (or in respect of whom a ‘Prospective Player Form’ is submitted, by a parent or guardian) through the Club’s Academy website to register as a ‘prospective player’ with the Club’s Academy (who we shall refer to throughout this notice as you and your). It is important that both you and a parent or guardian read this notice, together with any other information 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.

The Club is committed to protecting the privacy and security of your personal information. This privacy notice explains how the Club uses information about you, the ways in which we protect your privacy and some of the rights you have in relation to our handling of your personal data.

The Club is the “controller” for the personal information we process about you. This means that we are responsible for deciding how we hold and use personal information about you.

The Club has appointed Matt Wild as its data protection officer (the DPO) to oversee compliance. The DPO makes sure that we do everything correctly regarding your personal information. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at dpo@wolves.co.uk. You can make a complaint at any time to the Information Commissioner’s Office (the ICO) if you are not happy about how we are using your data.

THE CATEGORIES OF PERSONAL DATA WE COLLECT AND PROCESS

We may collect and process different types of personal data about you, including:

• Personal identifiers and contact data (such as your name, age, preferred football position, email address, postcode, contact number and biographical information about you); and
• Still and moving images and audio.

We will also collect the following “special categories” of personal data:

• Your nationality.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data where we are permitted to do so by applicable law. Most commonly, we will use your personal data in the following circumstances:

• 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; and/or
• Where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

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. Please contact the DPO if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We may also use your personal data when you have consented to our use of your information (by providing explicit written consent).

The lawful bases we rely on in relation to our use of any “special category” data are:

• In limited circumstances, with your explicit written consent; and/or
• Where we need to carry out our legal obligations.

HOW WE COLLECT YOUR PERSONAL DATA

We will collect your personal data directly from the ‘Prospective Player Form’ submitted to us.

HOW LONG DO WE STORE YOUR PERSONAL DATA?

We will only keep your data for as long as necessary, including for meeting legal needs. To determine the appropriate length of time to hold your data, we consider the amount, nature, and sensitivity of it, as well as the potential risk of harm from unauthorised use or disclosure.

Footage

We will securely destroy any footage provided to the Club through the ‘Prospective Player Form’ (and any of your personal data incorporated therein) within twenty-eight days of it being provided to us (ie within twenty-eight days of our receipt of your ‘Prospective Player Form’) in accordance with applicable laws and regulations.

Other

If we decide that you are suitable for joining the Club’s Academy / we decide to progress your possible registration with the Club’s Academy, we will keep your other personal (ie that which is not contained within the footage provided) for only so long as is necessary (including to facilitate communications with you or your parent / guardian regarding the possibility of you joining the Club’s Academy).

If we decide that you are not suitable for joining the Club’s Academy for whatever reason (or you notify us that you are no longer interested in joining the Club’s Academy), we’ll securely destroy all of your other personal data at the same time as the footage is destroyed, or if later, as soon as reasonably practicable after we make such decision (or you notify us that you are no longer interested in joining the Club’s Academy), in accordance with applicable laws and regulations.

If you are ultimately successful in joining the Club’s Academy, you will be provided with a copy of the Club’s Academy’s privacy notice, the terms of which will replace and supersede the terms of this notice to govern the Club’s use and collection and other processing of your personal data going forwards.

WHO WE SHARE YOUR PERSONAL DATA WITH AND WHY

We do not typically share personal data submitted to us through the ‘Prospective Player Form’ with any third parties (unless in exceptional circumstances, where the law or our legitimate interests allow us to do so).

HOW WE KEEP YOUR DATA SECURE

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.

REQUESTING ACCESS TO YOUR PERSONAL DATA

You have the right to request access to the personal data we hold about you. To make a request for your personal information, contact Matt Wild at dpo@wolves.co.uk.

You also have the right to:

• be told how your personal data is being used;
• be provided with a copy of all personal data we hold on you;
• correct some of the personal data we hold if it is not correct or out of date;
• delete all of the personal data we hold on you;
• stop us using your personal data in a certain way; and/or
• make us send your personal data to you or another organisation.

Some of the rights may not always apply to the personal data we hold for you, as there are sometimes requirements and exemptions attached to such rights which mean we need to hold on to certain information. At other times, the rights may not apply at all.

PARENTS/GUARDIANS

Where you are aged 15 or below, the Club will also collect and process the following personal data about your parent(s) / guardian(s):

• Name; and
• Contact details (postcode, email address and telephone number),

which will be used for the same purposes / activities (under the same lawful bases for processing) as set out above. This data will be collected directly from you from the ‘Prospective Player Form’ submitted to us. The provisions above regarding the storage of your personal data, the sharing of your personal data and the security of your personal data shall also apply to the personal data of your parent(s) / guardian(s). Your parent(s) / guardian(s) shall have the same rights regarding access to their personal data (etc) as are detailed above (in relation to you and your personal data).

CHANGES TO THIS PRIVACY NOTICE

We keep this privacy notice under regular review and reserve the right to update it as and when necessary.

CONTACT

If you would like to discuss anything in this privacy notice, please contact our Data Protection Officer, Matt Wild, at dpo@wolves.co.uk.