Albion in the Community Privacy Policy

Albion in the Community is a company limited by guarantee registered in England and Wales (Company No: 5122343) and is a charity registered with the Charity Commission (Charity No: 1110978) whose registered address is American Express Community Stadium, Village Way, Brighton BN1 9BL (“AITC”; “We”; “Us”; “Our”; “They”). AITC is the data controller and takes your privacy very seriously. We ask that you read this privacy policy carefully as it contains important information about what to expect when AITC collects personal information about you and how AITC will use your personal data.

AITC needs to keep certain information about users of its services and website to allow it to perform services and supply goods to you, to monitor performance and satisfy health and safety obligations, for example. It is also necessary to process information so that AITC can satisfy its legal obligations to funding bodies, government agencies and in respect of its operational issues. Data includes information held in written records and not just data held on computers. It is a legal requirement that personal data as defined in the Data Protection Act 1998 (“the Act”) must be used fairly, stored safely and not disclosed to any other person unlawfully. To do this, AITC must comply with the eight Data Protection Principles to ensure that personal data held is:

  • obtained and processed fairly and lawfully and shall not be processed unless certain conditions are met;
  • obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose;
  • adequate, relevant and not excessive for those purposes;
  • accurate and kept up to date;
  • not kept for longer than is necessary for that purpose;
  • processed in accordance with the data subject’s rights;
  • kept safe from unauthorised access, accidental loss or destruction, or damage;
  • not transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data.

AITC and all staff or others who process or use any personal information on AITC’s behalf must ensure that they follow these principles at all times.

The information we collect about you 

Personal Information

When you do business with us/register for our service or contact AITC, we collect the following personal information from you:

  • Name, postal address, email address and telephone number, and (if collecting funds from you) your payment details.

 

Sensitive Personal Data

AITC also collects the following sensitive personal data (as defined under the Act), (e.g. from course booking forms), which requires express consent to be obtained: a person’s health (such as allergies to particular forms of medication, or any conditions such as asthma or diabetes), school attending, criminal convictions, age, gender, disability, learning difficulties, sexual orientation, ethnicity, religion or faith.

AITC asks you to give express consent to us to use sensitive personal data for the protection of your health and safety and in the event of a medical emergency. Sometimes your consent to AITC processing sensitive personal data is a condition to the provision of our services, for example, the acceptance of a student onto a course. Course places and our services may be withdrawn if you refuse to provide express consent to AITC, without good reason.

 

How AITC may collect information from you

AITC may collect and process personal data about you and members of your family from a number of different sources:

  • Information that you provide by manually filling in forms.
  • Information that you provide by filling in forms on the relevant section of the website www.albioninthecommunity.org.uk (“the Website”). This includes information provided at the time of registering to use the Website, subscribing to an AITC service, posting material or requesting further services.
  • Information you supply to AITC when discussing matters over the telephone.
  • If you contact AITC, they may keep a record of that correspondence (including emails).
  • Details of transactions you carry out either through the Website, by email, over the telephone or by post and of the fulfilment of your orders or request for services / courses.
  • Details of your visits to the Website and the resources that you access.
  • Via your individual IP location and through cookies – see point 5 for more information.

 

How we will use the information about you

AITC may use information held about you in the following ways:

  • To ensure that content from the Website is presented in the most effective manner for you and for your computer.
  • To provide you with information, products or services that you request from AITC or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To carry out AITC’s obligations arising from any contracts entered into between you and AITC, or between AITC and any other third party to allow AITC to provide its services to you.
  • For monitoring and evaluation purposes using third party software.
  • To allow you to participate in interactive features of any AITC service, when you choose to do so.
  • To notify you about changes to an AITC service or goods.
  • We will use sensitive personal data to ensure that we provide you with services appropriate for your needs and in the case of administering first aid in the event of a medical emergency. Details about ethnicity are collected in order to report back to funding or governing bodies about target participant groups and inclusivity. This information will be held in accordance with the Act.
  • We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

 

Marketing

We may also wish to provide you with information about special features of our Website or any other services or products we think may be of interest to you. If we have provided services to you in the past, then we will only send such information to you (by email) that is similar to the services which were the subject of a previous service or arrangement with you, although you will be given the opportunity to opt-out of receiving future emails from us by clicking on the relevant link in that email. If you would like to receive information and you are not an existing user of our services, then, please tick the relevant consent box to receive such communications where required to do so. If you agree to us providing you with marketing information, you can always opt out at a later date by sending an email to: dataprotection@albioninthecommunity.org.uk.

 

Our use of cookies and other information-gathering technologies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve the Website and to deliver a better and more personalised service. Some of the cookies we use are essential for the Website to operate. You may delete and block all cookies from the Website, but parts of the Website may not work.

You block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit the Website.

 

How we protect your information

AITC will use all reasonable efforts to ensure that:

  • Any personal data (including any sensitive personal data) which we hold about you is kept securely;
  • Personal information is not disclosed, either orally or in writing, or accidentally or otherwise, to any unauthorised third party.

We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the internet.

 

Overseas transfers

The information you provide may be transferred to, and stored at, a destination outside the European Economic Area (‘EEA’) (although this is unlikely). Your information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Again, although this is unlikely, we will take all steps reasonably necessary to ensure your information is treated securely and in accordance with this privacy policy. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information you consent to these transfers for the purposes specified above. Page 6 AITC Privacy Policy V3

 

Access to your information and updating and correcting your information

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to: dataprotection@albioninthecommunity.org.uk or send a letter to Data Protection Officer, Albion in the Community, Brighton & Hove Albion FC, American Express Stadium, Village Way, Brighton, BN1 9BL. We may make a small charge of up to £10 to meet our costs in providing you with details of the information we hold about you.

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to AITC changes, for example if you change your email address, name or payment details, or if you wish to cancel your registration, please let us know the correct details by sending an email to: dataprotection@albioninthecommunity.org.uk or by sending a letter to Data Protection Officer, Albion in the Community, Brighton & Hove Albion FC, American Express Stadium, Village Way, Brighton, BN1 9BL. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which you believe to be inaccurate.

 

Links to other websites

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

Your consent

By submitting your personal information you consent to the use of that information as set out in this policy.

 

Changes to privacy policy

We keep our privacy policy under regular review. If we change our privacy policy we will post the changes on our Website, so that you may be aware of the information we collect and how we use it at all times.

 

How to contact AITC

We welcome your views about our Website, services and our privacy policy. If you would like to contact us with any queries or comments please send an email to: dataprotection@albioninthecommunity.org.uk or send a letter to Data Protection Officer, Albion in the Community, Brighton & Hove Albion FC, American Express Stadium, Village Way, Brighton, BN1 9BL.

 

Review

This policy will be reviewed on an annual basis.

 

Albion in the Community Equality Policy

Statement of Commitment                                                     

Brighton & Hove Albion Football Club celebrates and values the diversity brought by employees, potential employees, casual workers, potential casual workers, players, potential players, applicants, supporters, participants on community programmes and customers and believes the Club benefits from engaging with everyone from a variety of backgrounds, thus allowing it to meet the needs of a diverse population within a multi-cultural society.

We share and are committed to the standards, values and expectations set by the Premier League, The Football Association, the EFL and Kick it Out, who each asserts that football is for everyone and that it belongs to, and should be enjoyed by anyone who wants to participate in it, whether as a player, official, staff member or spectator.

We vow to treat everyone with respect and dignity, and seek to provide a positive environment  for all of our stakeholders, free from discrimination, harassment, victimisation or abuse. Our aim is to create a positive, inclusive ethos which will work towards the elimination of discrimination, harassment, victimisation and abuse whether overt or covert.

Our aim is to confront and eliminate discrimination whether by reason of age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, sex, sexual orientation, religion or belief. These are known as ‘protected characteristics’ under the Equality Act 2010.

We, the Club’s Board of Directors, together with the Club’s Executive Committee, are fully committed to promoting inclusion and believe all forms of prejudice and discrimination are unacceptable.

Our chief executive, has been given responsibility to champion and lead on equality and anti-discrimination and set standards for the club.

The head of HR, is the club’s designated senior lead on the development and implementation of equality and inclusion measures at the club. Her responsibility is to report all matters pertaining to equality and anti-discrimination to the board and be part of the equality working group responsible for attaining the Premier League Equality Standard.

Two board directors have been nominated as the club’s equality champions and are responsible for advising the board on all matters relating to equality.

ABOUT THIS POLICY

A          Application

This policy applies to all people connected with the activities of Brighton and Hove Albion FC (“BHAFC”, the “Club”), Brighton & Hove Albion Women’s Football Club (BHAWFC) and Albion in the Community (“AITC”) including permanent, part-time and fixed term employees and workers, board members, volunteers, customers, fans, participants, suppliers and contractors.

B          Defined terms

Throughout this policy “we” “our” and “us” means the Club, BHAWFC and AITC. Throughout this policy, “BHAFC” or “Club” also includes AITC and BHAWFC.

 

  1. Introduction

1.1       Brighton & Hove Albion Football Club (BHAFC) and Albion in the Community (AITC) celebrates and values the diversity brought to the Club and AITC by staff, players, matchday fans, board members, participants in outreach programmes, customers and other people engaged with the club’s activities, for example suppliers and corporate partners.

1.2       We are committed to encouraging equality and diversity and providing an environment in which rights, dignity and individual worth are respected in all operations, activities and services.

1.3       We share and are committed to the standards, values and expectations set by football authorities, including the Premier League, the FA, UEFA and FIFA, who assert that football is for everyone and should be enjoyed by anyone who wants to participate in it, whether as a player, official, staff member or spectator.

1.4       For our employees, we are committed to providing a workplace that values equality and equal opportunities and which is supported by the Club’s Team Brighton values:

  • Treat people well – the club is committed to taking a professional, helpful and approachable attitude towards their supporters, visitors, colleagues and the community.
  • Exceed expectations – the club is dedicated to achieving success by setting high standards and measuring its performance in critical areas
  • Aim high – the club strives to be the absolute best it can be, and will not give up
  • Make it special – the club encourages a warm and friendly environment, making Brighton & Hove Albion Football Club a great place to visit and to work

1.5       We will provide a positive working and learning environment, free from discrimination, harassment, victimisation, bullying or abuse whether overt or covert.

1.6       We will confront and eliminate discrimination whether by reason of: age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, sex, sexual orientation, religion or belief – known as ‘protected characteristics’ under the Equality Act 2010.

 

  • Implementation

2.1       Brighton & Hove Albion FC’s Chairman, the Club’s Board of Directors, AITC’s Board of Trustees and senior management of both organisations are responsible for the implementation of this policy and are fully committed to promoting inclusion. They believe that all forms of prejudice and discrimination are unacceptable.

  • A copy of this policy will be published on the Club’s website.

2.3       Suppliers of the Club will be given a copy of this policy and will be asked to commit to act in accordance with it.

 

  • Equal Opportunities 

3.1       The Club is committed to ensuring that the recruitment and selection of staff is conducted in a matter that is systematic, efficient and effective, and promotes equality of opportunity. The successful implementation of this policy will be vested in Human Resources.

3.2       All staff and players at Brighton & Hove Albion Football Club and AITC have a personal responsibility to uphold the Club’s Equality Policy and should abide and adhere to this Policy and to the requirements of the Equality Act 2010. All staff and players are required to treat fellow employees, prospective employees, casual workers, prospective casual workers, players, prospective players, job applicants and customers fairly and impartially.

3.3       All staff involved with recruitment, selection and promotion have a responsibility to ensure equality of opportunity. Specialist training in this area will be given to all staff involved with recruitment, selection and promotion.

3.4       All members of staff should ensure that they abide by this policy during the course of their employment. The EFL Playing for Inclusion workshop, cultural awareness, disability awareness and unconscious bias training will form part of the training programme for employees.

 

  • Positive Action

 4.1       As well as complying with legislation, the Club promotes equality by taking positive steps to counteract the effects of physical or cultural barriers – whether real or perceived – that restrict the opportunity for all sections of the community to participate equally and fully.

4.2       We will therefore seek to institute, support or contribute to appropriate measures or initiatives that enable access to our club, as well as require participation in associated activities by people from any group that is under-represented in the club or has difficulty accessing it.

4.3       We require all other codes of conduct, policies and procedures to consider and address equality and inclusion.

    

  • Complaints and compliance

5.1       Brighton & Hove Albion Football Club and AITC regard all of the forms of discriminatory behaviour, including (but not limited to) behaviour described in Appendix 1 as unacceptable. A zero-tolerance approach will be taken by the Club and appropriate action will be taken against any player, employee, Board member, participant in outreach programmes, matchday fan, and other people engaged with the club’s activities who is found, after a full investigation, to have violated the Club’s Equality Policy.

5.2       If a player or member of staff or volunteer believes they have been treated in such a way that is in direct conflict with this Equality Policy, the matter should normally be reported immediately to their line manager or a member of the HR team. Where a complaint is made, the Grievance or the Harassment Procedure will be followed. All allegations will be taken seriously and investigated promptly and impartially.

5.3       Matchday fans can use the Kick it Out reporting text line or contact the Club’s Safety Officer via the club’s anti-social hotline by texting details of the location affected, descriptions of offenders and the nature of the issue to: 07880 196 442.  Alternatively, they may report the behaviour to a matchday steward.

5.4       All individuals should feel able to raise any bona fide grievance or complaint related to such behaviour without fear of being penalised for doing so. Reports of allegations will be treated in a private and confidential manner. In doing so, we are working towards being legally compliant in relation to equality legislation. Any person against whom a complaint has been made will be informed of what is alleged and given the opportunity to present their side of the matter.

5.5       Where the violation of the Equality Policy by way of harassment, victimisation or discrimination amounts to a criminal offence, the appropriate authority will be informed.

 

  • Education & Training 

6.1       Brighton & Hove Albion Football Club will commit to a programme of raising awareness and educating stakeholders, campaigning, widening diversity and representation and promoting diverse role models, which we believe are all key actions to promote inclusion and eradicate discrimination within football.

6.2       The Club will provide a rolling training programme for players and employees which will include the elements detailed in section 3 of this policy.

 

  • Monitoring & Evaluation

7.1       The Club and AITC will implement regular annual equality audits of the board of directors/board of trustees, employees, volunteers, fans and participants/beneficiaries to assess the level of participation of different sections of the community in the club and will take account of the findings in developing measures to promote and enhance equality in the Club. The audit findings will be presented to the club and charity’s boards.

7.2       The Club and AITC will formulate a rolling equality action plan informed by the audit findings and this will include SMART targets.  

 

Summary

Brighton & Hove Albion Football Club and AITC will ensure that it treats everyone fairly and with respect and that it will provide access and opportunities for all members of the community to take part in, and enjoy, its activities. Every staff member, Board member, Trustee, official, spectator, fan and visiting team can be assured of an environment in which their rights, dignity and individual worth are respected, and in particular that they are able to work and watch football in an environment without the threat of intimidation, victimisation, harassment or abuse.

This Equality Policy will be reviewed and updated every two years or upon change in legislation or relevant incident.