Lincoln City Football Club Privacy Policy
Our contact details
Name: Lincoln City Football Club Company Limited
Address: LNER Stadium, Sincil Bank, Lincoln, LN5 8LD
Phone Number: 01522 880011
Data Protection Officer: Richard Parnell
E-mail: rpar@theedimps.com
1. Introduction
Lincoln City Football Club Company Limited (“LCFC”) takes your privacy very seriously and is committed to protecting your personal data and handling it responsibly.
This privacy policy sets out how we use, look after and store the personal information collected from you.
We collect information whenever you interact with us and this interaction includes but is not limited to when you attend a football match or any other event at the LNER Stadium, when you use our website, when you buy a ticket, when you buy merchandise, or just get in touch with us.
LCFC is a data controller. This means that we are responsible for deciding how we hold, use and store personal information about you. We are required under the data protection laws to notify you of the information contained in this privacy policy.
We may update this at any time so please check back at any time to view any changes.
It is important that you read this policy, 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 your personal information.
2. Data Protection Principles
We will comply with all relevant data protection law including the General Data Protection Regulation (GDPR). This requires that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only if necessary for the purposes we have told you about; and
- Kept securely.
3. What type of information we have
Personal data, or personal information, means any information about an individual from which that person can be identified, whether directly or indirectly. It does not include data where the identity has been removed (anonymous data).
There are also "special categories" of sensitive personal data which require a higher level of protection.
We collect, use, store and transfer some of your personal data from your interactions with us, for example when you purchase tickets, attend a football match or other event at the LNER Stadium, when you complete forms at an event or online, or when you email or phone us.
We take reasonable care to keep your personal information secure and to prevent any unauthorised access or use of it.
The personal data we collect from you includes:
- Your name, date of birth, address, email address, phone number, gender, and the contact details of a third party in the event of an emergency when you purchase tickets, enter competitions or send any enquiry to LCFC;
- Your payment card and address details;
- Your marketing preferences, including any consents you have given to us or third parties;
- Information about your use of our website and social media;
- Your communications with us (for example, by email, social media, events or enquiries);
- Information about your attendance at the LNER Stadium, such as football matches and other events;
- Photo and video footage taken at football matches and other events held at the LNER Stadium, as all parts of the stadium are covered by CCTV (we will only do this if you are over 13 years of age and you have provided your consent or you have provided consent by default under our Ground Regulations);
- Our ticket provider links with our data analytics provider and lets us know if you have purchased a ticket for a football match or other event; and
- Our data analytics provides us with insights from data sets about our supporters.
We may also ask for your relevant health information, which is classed as special category personal data, for the purposes of your health, wellbeing, welfare and safeguarding.
4. How we collect the information and why we have it
We typically collect personal information from you through the TicketMaster ticketing system (https://www.eticketing.co.uk/imps) when purchasing tickets for matches or events online, via the web browser when you email us at any point on the LCFC website (www.weareimps.com) and where you login to register your interest in any competitions you enter via our social media.
We will only use personal data for any purpose for which it has been specifically provided. We have set out below 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. We have also identified what our legitimate interests are where appropriate.
Under the GDPR, the lawful bases we rely on for processing this information are as follows:
(a) Your consent. You are able to remove your consent at any time. You can do this by sending an email to rpar@theredimps.com.
(b) We have a contractual obligation. Where we have a contract with you we will rely on the contractual provisions in order to process your personal data. This may include:
- Processing membership forms and payments;
- Organising matches;
- Sending out match or Club information and updates;
- Sharing data with coaches, managers or officials to run training sessions or enter events; and
- Sharing data with leagues we are in membership of, county associations and other competition providers for entry in events.
(c) We have a legal obligation. We are legally required to process your personal data in cases where we need to comply with a legal obligation to which LCFC is subject under UK or EU Law. This may include:
- Responding to requests by government or law enforcement authorities such as HMRC; or
- Local council safety requirements to collect CCTV footage.
(d) We have a legitimate interest. We process your personal data when necessary to pursue our legitimate interests in the following:
- Enforcing ticket terms and conditions;
- Processing job applications;
- Legal claims, compliance, regulatory and investigative matters including using incident reports and CCTV footage to protect the security of spectators and staff and pass information to law enforcement agencies;
- Responding to comments or complaints;
- Issuing receipts for purchases made;
- Checking/verifying credit or debit card details in order to process transactions or prevent fraudulent activity;
- Analysing your engagement with us to help tailor information we send to you;
- Sharing data with committee members to provide information about club activities, membership renewals or invitations to social events; and
- Sharing data with third party service or facility providers.
You have a right to object to any processing that we undertake for our legitimate interests.
5. What we do with the information we have
We will only use your personal information when the law allows us to. If you opted-in to receive information and offers from us and our partners (for example by giving consent on one of our competition or registration forms) then we will provide any offers or information to you by email, phone/SMS or post.
Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered with you.
- Where we need to process the orders that you have placed with us.
- Where we need to administer your account with us.
- Where we seek feedback on the products and services that we provide.
- Where we need to notify you of changes to our products and services.
- Where we send you information about other products or services that you have specifically requested from us.
- Where we need to comply with a legal or regulatory obligation.
- Using incident reports cards and CCTV to investigate any issues arisen on a matchday/event and ensure the security and safety of our fans and staff.
- We may need to process a job application or respond to an enquiry about a possible job with us.
- 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.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else's interests).
- Where it is needed in the public interest or for official purposes.
- Where we may detect crime within the stadium.
6. How we store your information
We have put in place appropriate technical and security measures to protect the security of your personal information. Details of these measures are available upon request. Third parties will only process your personal information on our written instructions and where they have agreed to treat the information confidentially and to keep it secure as part of their contractual arrangement with us.
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 information to those employees, workers, 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. Details of these measures are available upon request.
We have put in place technical and organisational processes and 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.
7. How long your personal information is stored
We keep personal data about your purchases, bookings and interaction for as long as your ticketing account remains active or are otherwise actively involved with LCFC, and for a limited time afterwards (in case, for example, you decide to reinstate your account or have any questions about it). We will delete this data once your account is no longer active or you have otherwise ended your involvement with LCFC or sooner if you have specifically requested this and we are able to do so. We may need to retain some personal data for up to 6 years from the initial transaction so that we can meet our legal, regulatory and contractual obligations. We will then delete your information.
8. Your data protection rights
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes at any point by emailing rpar@theredimps.com.
Under data protection law, you have the following rights:
- Your right of access - You have the right to ask us for copies of 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;
- Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
- Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 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);
- Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances;
- Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances. 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; or
- Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
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. If you make a request, we have one month to respond to you.
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 email rpar@theredimps.com.
If you wish to submit a data subject access request, please email rpar@theredimps.com. We may need to request specific information. To ensure we are speaking to the correct person we will to of (certified copy of your passport, valid UK driving license or utility bill) 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.
9. Data Protection Officer (DPO)
We have appointed a data protection officer to oversee compliance with this privacy policy. If you have any questions about this privacy policy or how we handle your information, please contact our DPO by email on rpar@theredimps.com.
10. Changes to this Privacy Policy
We reserve the right to update this privacy policy at any time. We may also notify you in other ways from time to time about the processing of your personal information.
11. How to complain
If you wish to complain, please email our Data Protection Officer at rpar@theredimps.com or write to us at Lincoln City Football Club, LNER Stadium, Sincil Bank, Lincoln, LN5 8LD.
You can also complain to the Information Commissioners Office (ICO) if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113