The Confederation of Professional Golf Limited (“CPG”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, whether you are a representative of a Member Country PGA, a PGA Professional, customer, supplier, business partner, or other third party we have a relationship with, and tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how the CPG collects and processes your personal data through your use of our website, or offline when you provide us with personal data, for example in an application form, in person or over the telephone.
Our website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
The Confederation of Professional Golf Limited is the controller and responsible for your personal data.
Our Director of Communications & Membership is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Director of Communications & Membership using the details set out below.
Headquarters Address:
The Confederation of Professional Golf Limited
Centurion Club
38-39 Albert Road
Tamworth
Staffordshire
B79 7JS
England
Registered Address:
7 Victoria Road
Tamworth
Staffordshire
B79 7HS
England
+44(0)20 71 83 59 83
info@cpg.golf
Registered in England: 2774749
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 (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.
This version was last updated on 04/08/2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We do not generally collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union Membership, information about your health and genetic and biometric data). However, we may in certain circumstances require such information where we have a valid legal basis to process it. This will either be for a reason permitted by the applicable data protection laws or with your explicit consent.
The CPG can make use of the Disclosure and Barring Service (DBS) to assist it in ensuring that those who take up appointments do not pose a risk to the children in its care. The CPG may therefore process criminal records data disclosed by the DBS (formerly known as CRB). This will be processed in accordance with the DBS Code of Practice for Registered Persons. Where applicable we can also use the regional equivalents in Scotland and Ireland, PVG, Access NI and Garda Vetting, the information processed is in accordance with each organisations code of practice.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact, Profile and Financial Data by filling in physical or digital forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policyfor further details.
We may receive personal data about you from various third parties and public sources as set out below:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data however in certain circumstances it may be the only legal basis which we can rely open. Where we do need to rely on your consent it will be very clear at the point at which we collect the data from you that we are relying on your consent. Where we have obtained your consent to process certain personal data you have the right to withdraw your consent to that processing at any time by contacting us.
We have set out below, in table format, descriptions 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.
The initial table is applicable to all individuals whose personal data is processed by the CPG. We have also included some additional tables to cover specific scenarios where we process your personal data.
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. If you need more details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below then please do not hesitate to contact us.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you or your company as a new supplier to the CPG. | (a) Identity (b) Contact (c) Financial |
Performance of a contract with you |
| If you purchase good/services from the CPG to process and deliver your order including:
(a) Manage payments, fees and charges |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how individuals use our services, to develop them and grow our business) |
| To enable the CPG to administer and protect our business (including organising tournaments and issuing coaching certifications) and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how individuals use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define our audience, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
If you are a Member Country of the CPG, the following table will also apply to your personal data which is processed by the CPG.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a Member Country of the CPG | (a) Identity (b) Contact (c) Financial |
Performance of a contract with you |
| To manage our relationship with you which will include:
(a) Renewing your Membership with the CPG |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (f) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To enable the CPG to administer your Membership including necessary training records | (a) Identity (b) Contact (c) Profile |
(a) Performance of a contract (b) Necessary for our legitimate interests (for running of our business, including ensuring Members are complying with their Membership responsibilities) |
| To deliver relevant content, bulletins and advertisements to you about your region or about new Member Country PGA and individual PGA Professionals benefits | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop the services which we deliver, to keep you informed and to grow our business) |
If you are a student of the CPG, enrolled in an activity such as Initial Professional Education [IPE] or Tutor Training, the following table will also apply to your personal data which is processed by the CPG.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To enrol you in a CPG training/education programme | (a) Identity (b) Contact (c) Profile |
Performance of a contract with you |
| To manage your relationship with us, the relevant Universities, Members and golf clubs and other employers | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how assistants use our services) |
| To administer the qualifications awarded and maintain consistency across the training process | (a) Identity (b) Contact (c) Usage (d) Profile |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to maintain consistency of the qualifications) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or in the case of Member Country PGAs or individual Member PGA Professionals in relation to benefits available to individuals, and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the CPG. We will share Members’ personal information with legitimate third-party organisations, such as partners and benefits providers, who are involved with or support the CPG, unless you have opted out of receiving such information.
You can ask us or third parties to stop sending you marketing messages at any time by accessing your email preferences available by clicking the ‘update your preferences’ link within communications or directly by following the ‘unsubscribe from this list’ link on any marketing message sent to you or by contacting us at any time.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 3 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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 will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, 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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 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 a number of requests. In this case, we will notify you and keep you updated.