Pumpherston Golf Club - GDPR Policy

WHO is the CONTROLLER of your personal data?

Pumpherston Golf Cub (referred to as "we", "us", or "our" in this privacy notice) are part of the business controlling you r personal data. When we mention "we", "us" or "our" in this privacy notice, we are referring to the relevant business which is responsible for processing your personal data. Unless we inform you otherwise, the controller will be Pumpherston Golf Club. However, where processing of personal data is undertaken by us to be passed to other entities such as Scottish Golf, that entity will be a separate controller of your personal data. The contact details for each controller are as follows:

Our Contact Details:
If you have any questions about this privacy notice or our processing activities, we can be contacted as follows:

Mail: FAO Secretary, Pumpherston Golf Club, Drumshoreland Road, West Lothian, EH53 0LN

Email: secretary@pumpherstongolfclub.co.uk

It is important that you read this privacy notice along with any terms of use that apply to the services or Website which are presented to you.

HOW and WHAT data do we collect about you?
We respect your privacy and are committed to protecting your personal data. This privacy notice describes how we look after your personal data when you:

Provide your contact details when you visit our Club, to assist the NHS Scotland Test and Protect programmes, the UK and other devolved nations NHS track and trace equivalents.

Visit our venue as a member, guest, visitor, engineer, delivery person or for any other reasonable excuse or legal purpose.

This will be deemed by us to be (“Engagement”).

Personal data, or personal information, means any information about an individual from which that person can be identified. We collect this information directly from you during your visit either by using our Evepass QR code application or by a member of our staff noting this information directly.

Identity Data

Name, title and place and date of birth and personal characteristics including age and gender.

Contact Data

Billing address, email address and telephone numbers.

Financial and Transactional Data

Credit history (if using Premium credit), bank account and card payment details, and details about payments as well as products or services provided by us, (example lockers).

Profile Data

Preferences, feedback, survey responses and interests including activities noted on Social Media Platforms (for example, Facebook likes/groups).

Marketing and Communications Data

Preferences in receiving communications and marketing from us.

Location Data

GPS-based location information from your use of our Website, or Social Media Platforms via your smartphone(s), tablet(s) or other devices.

Photo and Video Data

Photos and or video footage of you captured when you attend any events hosted or sponsored by us in one of our pubs or elsewhere (your attention will always be drawn to any photography or filming that is taking place, and your consent will be obtained where required).

Inferred Data

which is inferred or derived from the data we collect, for example inferences about your interests based on your Identity Data or Location Data.


WHY do we collect your personal data?
We collect the above categories of personal data about you for the following purposes:

To comply with our legal obligation to collect contact details of visitors to our venues to assist the NHS Scotland Test and Protect programmes and help to contain the spread of COVID-19. We will only share details collected about you for this purpose with NHS Scotland Test and Protect if requested, and your details will not be shared or used for any other purpose.


To perform a contract, we have in place with you, including managing payments, fees and charges and delivering the requested products or services.

To enable you to make bookings at our premises.

To communicate with you – this includes where we manage our relationship with you, where we respond to complaints or enquiries, where we invite you to events, or where we make suggestions to you about various products and services that you could benefit from.

To improve our services to you – this includes asking you to complete surveys about how we can improve the services we offer you and/or the application process, or asking you for information on how we can improve our Website or our Engagements with you.

To maintain and optimise our Website – this includes where we need to solve performance issues, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, to improve the availability of the Website and to secure the Website against fraud.

To protect our business and prevent or detect crime – this includes recording calls that are placed with our Customer Hub for fraud prevention purposes, and the use of CCTV across our premises.

For data analytical purposes to improve our products/services, marketing, customer relationships and experiences.

To improve our marketing strategies so that we can send you relevant offers and content; by creating individual profiles and profiled audience segments so that we can tailor our content to you.

To improve our marketing strategies by ‘matching’ data we have collected, such as your e-mail address, with your profile on a Social Media Platform so that we can show you marketing content which may be of interest to you (for example, by using Facebook).

To satisfy our legal obligations and to defend and exercise our legal rights.

We will only use your personal data for the purposes above, unless we reasonably consider that we have another appropriate reason, and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

What is our LEGAL BASIS for collecting your Data?
Under data protection laws, we must have a legal basis under which we process your personal data. When we collect and use your information, we do so under one of the following:

We have a legitimate interest as a business.

To perform a contract, we have with you.

To comply with a legal obligation; or

If you have given us your consent.

Legitimate Interest as a business means conducting and managing our business to enable us to give you the best service and to promote and grow our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We will not use your personal data for activities unless we have a compelling interest which is not overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, such as entry into a promotion or subscription to a particular service, or to take steps at your request before entering into such a contract.

Compliance with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to, such as anti-money laundering legislation.

With your consent, this can only be relied on by us as a legal basis for processing where your consent has been freely given, is unambiguous and clear (i.e. you have actively opted into a service we provide by ticking a box. Please note we may still process the data if we have another lawful basis for processing (in most instances, this will be for a more limited purpose e.g. back-up storage or to record a transaction).

WHO do we share your personal data with?

To ensure that we provide the best service to you, we may from time to time have to share your personal data with the parties set out below:


NHS Scotland Test and Protect
Premium Credit
Scottish Golf
Club V1 systems


We may in some circumstances provide your details to local licensing authorities, the Health & Safety Executive, the Police and HMRC, to comply with any legal or regulatory requirements or investigations.

NHS Scotland Test in connection with the collection of contact details at our pubs for COVID-19 contact tracing purposes.

Courts, parties to litigation and professional advisers where we reasonably deem it necessary in connection with the establishment, exercise, or defence of legal claims.

Our insurance claims manager, and our insurance companies for the purposes of valuing and making insurance claims.

We require and expect all these parties to respect the security of your personal data and to treat it in accordance with the law. Where third parties act as processors on our behalf, we only permit them to process your personal data for specified purposes and in line with our instructions.


How SECURE is my data?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They are subject to a duty of confidentiality.

Unfortunately, no transmission of information over the internet can be completely secure, and you should also note that the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect account information and passwords, so please take care to protect this information.

How LONG will my personal data be used for?
We will only retain your personal data to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To 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.

What are my RIGHTS?
Under certain circumstances, you have various rights in relation to your personal data under data protection laws. If you wish to exercise any of these rights, please email us at secretary@pumpherstongolfclub.co.uk

You will not have to pay a fee to access your data or exercise any of your other rights, but please note that we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

To respond to any request in relation to your data access rights, we may need to request specific information from you to help us confirm your identity. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

You have the right to:

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

You also have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, or where you have successfully exercised your right to object to processing.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You also 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details at the start of this notice.
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