Privacy Policy

1. Scope and Purpose

This document outlines to all data subjects, who interact with Portmarnock Golf Club, under what conditions their data will be processed, how Portmarnock Golf Club strives to ensure that the individual’s privacy is respected at all times, who conducts the processing, what security features are in place, and what rights the data subject retains at all times. Above all, this document aims to ensure that transparency exists with respect to how Portmarnock Golf Club processes data.

If you have any questions in relation to this document or if you wish to exercise any of your rights concerning your personal data, please email us at gdpr@portmarnockgolfclub.ie.

2. Who Are We?

Portmarnock Golf Club is a member-owned golf club founded in 1894. The golf course is located at Golf Links Road, Portmarnock, Co.Dublin, Ireland. D13 KD96. The club can be contacted by telephone on 01 8462 968.

3. What data do we collect, why do we collect it, and how long do we keep it?

This section of the document outlines the types of data held by Portmarnock Golf Club and how long the data is held. This is broken into individual sections relating to specific activities.

3.1 Enquiries

Portmarnock Golf Club may be contacted in a number of different ways. If we cannot provide you with an immediate response to your enquiry, your information may be recorded in order to allow us to respond accordingly.

Enquiry information may also be collected from you as part of direct e-mail or verbal communications with any of our team when visiting our clubhouse or pro-shop.

3.1.1 What data do we collect?

As part of this contact, we may collect the following data:

  • Name
  • Telephone number
  • Email address

3.1.2 Why do we collect this information?

This information is collected to allow us to revert to you with the appropriate response to your enquiry and to ensure that your query is satisfactorily dealt with.

3.1.3 How long do we keep this information?

If you are not a member of the golf club your information will be deleted within three years.

3.1.4 Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Portmarnock Golf Club as outlined in section 4.

3.2 Membership applications

If you have applied to become a member of Portmarnock Golf Club, we will collect certain information from you during the application process.

3.2.1 What data do we collect?

Upon your first engagement with us, we will ask you to complete a membership application form which will include your:

  • Name
  • Address
  • Email
  • Phone number
  • Date of Birth
  • Occupation
  • Employer
  • Career resume
  • Social and business appointments
  • Current and past golf club memberships

3.2.2 Why do we collect this information?

This information is obtained in order to allow Portmarnock Golf Club’s membership committee to assess your application in line with the club’s values and good standing.

3.2.3 How long do we keep this information?

We will keep the information which you have provided to us as part of the application process only while applications are being reviewed.

Should you be unsuccessful in your application, your application forms along with supporting documentation will be retained for a period of three years, to serve as a matter of record should you re-apply for membership at a later date.

Should you be successful in your application process, your application form will be held on file for the duration of your membership.

3.2.4 Do any third parties process your data?

Your information is not processed by any external third parties during the membership application process. Your information is shared with the Portmarnock Golf Club‘s membership committee through secure file transfer.

3.3 Member Subscriptions

As a member of Portmarnock Golf Club, we will collect data relating to payments of your annual subscription fees.

3.3.1 What data do we collect?

Should you decide to make your subscription fees via direct debit, we will ask you for data such as your:

  • Name
  • Address
  • BIC & IBAN number
  • Signature

3.3.2 Why do we collect this information?

This information is required in order to enable Portmarnock Golf Club to complete a direct debit mandate form which is provided to your bank.

3.3.3 How long do we keep this information?

Direct debit mandates are retained for as long as you continue to pay by direct debit. From the date of the last successfully collected direct debit, the mandate will be retained for two years. While records of subscription fees are retained for a period of seven years in order to ensure that we satisfy our obligations to the Revenue Commissioner’s Office.

3.3.4 Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Portmarnock Golf Club as outlined in section 4, as well as Portmarnock Golf Club’s external auditors.

3.4 Lapsed or Resigned Memberships

This section outlines what data is retained in the event that you choose to leave Portmarnock Golf Club and how long this information is held.

3..4.1 What data do we hold?

All information collected during the application process, as well as information collected during normal membership interactions with the club are held on file following the cessation of your membership in line with the retention policy defined in section 3.4.3.

3.4.2 Why do we collect this information?

This information will have been collected as part of your ongoing club membership.

3.4.3 How long do we keep this information?

Should you decide to leave the Club, after a period of five years, only your name and address as well as any paid entrance and annual subscription fee records are retained. This information is kept indefinitely to accommodate you choosing to re-apply through the application process.

3.4.4 Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Portmarnock Golf Club as outlined in section 4, as well as Portmarnock Golf Club’s external auditors.

3.5 Visitor Bookings

For visitors booking a tee time at golf at Portmarnock Golf Club, we will require a certain amount of personal data in order to facilitate this process.

3.5.1 What data do we collect?

As part of the booking process, you will be asked to provide your:

  • Name
  • Address
  • Email
  • Phone number,
  • Handicap
  • Home club
  • Payment information (credit/debit card)

3.5.2 Why do we collect this information?

We collect this information in order to enable us to confirm your booking, to communicate with you prior to a booking, and to process the payment for your booking. This information is also used in order to allow subsequent bookings to be made without the requirement of entering all the required data again.

3.5.3 How long do we keep this information?

Portmarnock Golf Club keeps visitor information gathered during the booking process for a period of three years.

Credit/debit card details are not retained by Portmarnock Golf Club but processed instead by our payment partners as outlined in section 3.5.4. Records of payments made are kept on file for seven years in order to ensure that we satisfy our obligations to the Revenue Commissioner’s Office.

3.5..3 Do any third parties process your data?

Your information will be processed by BRS Golf to facilitate the booking process, while all payment details will be handled by Sagepay and Worldnet Virtual Terminal. Your data may also be processed by the generic list of third-party processors engaged by Portmarnock Golf Club as outlined in section 4.

3.6 Competitions

In order to enter a competition at Portmarnock Golf Club, we require a certain amount of information in order to confirm your entry. Members entering competitions are not required to provide any additional information to that which Portmarnock Golf Club already retains.

3.6.1 What data do we collect?

As part of the competition booking process, we may collect certain data from you such as your:

  • Name
  • Address
  • Email
  • Phone number,
  • Handicap
  • Home club
  • GUI number
  • Payment information (credit/debit card)

3.6.2 Why do we collect this information?

We collect this information in order to enable us to confirm your handicap for the purposes of the competition, as well as to facilitate communication with you regarding the competition itself and prize giving.

3.6.3 How long do we keep this information?

All information on competitions is minimised to include only names after a period of two years. The names of competitors who have played in a competition at Portmarnock Golf Club are retained indefinitely.

Credit/debit card details are not retained by Portmarnock Golf Club but processed instead by our payment partners as outlined in section 3.5.4. Records of payments made are kept on file for seven years in order to ensure that we satisfy our obligations to the Revenue Commissioner’s Office.

3.6.4 Do any third parties process your data?

All payment details will be handled by Sagepay and Worldnet Virtual Terminal.

Your information may be processed by the generic list of third-party processors engaged by Portmarnock Golf Club as outlined in section 4.

3.7 Employment Applications

If you have applied for a position with Portmarnock Golf Club, we will collect certain information from you in order to facilitate the application process.

3.7.1 What data do we collect?

During this process, we will ask you for a copy of your CV and cover letter which may include your:

  • Name
  • Address
  • Email
  • Phone number
  • Employment history
  • Any further information that you felt compelled to provide us, as part of your application.

3.7.2 Why do we collect this information?

This information is required in order to enable us to effectively assess your skills and qualifications for the job that you have applied for.

3.7.3 How long do we keep this information?

Should you be unsuccessful in the application process, Portmarnock Golf Club will keep your CV on file for a period of one year.

3.7.4 Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Portmarnock Golf Club as outlined in section 4.

4. Third Party Data Processing

As outlined in section 3, it is sometimes required that third parties process your data. Any data which you provide to us will be processed under conditions of absolute confidentiality and we will ensure that we do not share this information with anyone other than a select group of trusted partners. All of our partners have provided guarantees of GDPR compliance, such that we have confidence that your information will be processed with the highest standards of data privacy.

Under no conditions do we transfer any of the data which you provide us outside of the European Economic Area (EEA).

In section 3, specific instances of such data processing are provided relevant to the type of data which has been collected. Several generic data processing third parties are also used as part of the daily operation of Portmarnock Golf Club which are outlined in this section. It should be noted that these third parties may process data provided to us in conjunction to those listed in section 3.

Third Party  

Why it processes data

Role

BRS Golf

Online booking for members and visitors

Data Processor

Microsoft

Cloud-based documentation, storage, analysis and communication tools used within Portmarnock Golf Club

Data Processor

Sagepay

Point of Sale application taking online bookings for visitors

Data Controller

IDJ Golf

Manage Portmarnock Golf Club pro-shop

Data Controller

ADT Security

Provide security monitoring of video surveillance of Portmarnock Golf Club premises

Data Processor

DC Networks

Manage Portmarnock Golf Club IT infrastructure

Data Processor

Worldnet

Point of Sale application taking online bookings for visitors

Data Controller

Handicap Master

Manages Portmarnock members golf handicap and competitions.

Data Processor

Mailchimp

Cloud Based mailing system for communication to Portmarnock members

Data Processor

Several third-party processors listed in this document are designated as acting as data controllers. This means that these third parties will make decisions relating to how your data is processed and are required to ensure that they treat your data in accordance with relevant data protection regulation. This involves adequate communication with you to ensure that you have full transparency relating to what processing they will conduct with your information. If you feel that your data protection rights are not being observed, you should contact us directly or the data protection commissioner.

5. Retention Periods

The specific retention periods which will be applied to your information are outlined in section 3.

Information relating to you may also be contained in routine communications with us, such as via e-mail transactions. We apply a general retention period of three years to any such communications. Therefore although stricter retention periods may be applied to all formal records of your data as outlined in section 3, copies of this information may be retained for longer if contained in written communications with us.

6. Security of Your Information

We take our information security responsibilities very seriously and employ the most appropriate physical and technical measures, including staff training and awareness, to ensure that your information is safe. These measures are regularly reviewed.

6.1 Training

All staff members of the Portmarnock Golf Club team have received training relating to data security and the processing of personal information. Individuals have been additionally provided with training relating to the processing of data specific to their roles within Portmarnock Golf Club.

6.2 Physical Security

All of the data provided to Portmarnock Golf Club in either physical (paper) form or by digital means is stored securely on the premises in the Portmarnock Golf Club offices or else using trusted third party processors as listed in sections 3 and 4.

6.3 Encryption

All data processed by Portmarnock Golf Club by digital means is, where possible, encrypted in transit and also at rest. Encryption in transit is achieved by the use of SSL certificates, while encryption at rest is achieved on multiple levels, using both server level and application level encryption.

7. Your Rights

You have a number of rights in relation to your personal data. We have summarised those rights for you below

7.1 The Right of Access

You have the right to be informed about which of your data we are currently processing, why we are processing it, and how this processing is taking place. As part of any such request, you may ask us to provide you with a copy of this data.

7.2 Right to Portability

You may wish for your data to be transferred to another data controller of your choice, in which case we will either pass this information to you, or to the controller of your choice.

7.3 Right of Rectification

If you feel that data which we are processing pertaining to you is inaccurate, then please let us know, and we will fulfil your right to have it amended and rectified.

7.4 Right to Erasure

Under many conditions, you will have the right to be completely “forgotten” by Portmarnock Golf Club. If you make such a request, we will strive to delete or anonymise all of your personal data.

7.5 Right to Restrict Processing

You have the right to ask us to restrict processing of your personal data for a particular reason. This means that while this request exists, we will still store your data, but won’t use it.

7.6 Right to Object

If you feel that we are processing your data in a way which is unlawful, excessive, or if you would simply like us to stop, you have the right to object to this processing.

8. Complaints

If you have any complaints about any data processing activities which are being conducted relating to you or any information which you have supplied to us, please contact us and let us know (gdpr@portmarnockgolfclub.ie). We will do everything in our power to resolve the situation. You always reserve the right of course to make an official complaint to the Data Protection Commissioner’s Office.


9. Changes to our privacy policy

We keep our privacy statement under regular review and we will place any updates on this web page. The privacy statement was last updated on 26th of April 2019.