So that we can provide a Golf Club and course suited to the best interests of its members and other course users, we have to collect information. This information may include details of members, guests, visitors, current, past and prospective employees and suppliers.
Canterbury Golf Club is committed to the correct treatment of personal data. We fully appreciate the underlying principles of the Data Protection Act and support and adhere to its provisions. The Act uses the term "Personal Data” which essentially means any recorded information held by us and from which a living individual can be identified.
We are committed to complying with the Data Protection Act Principles which are:
Personal data shall be processed fairly.
Personal data shall be obtained only for one or more specified lawful purposes and shall not be further processed in any manner incompatible with that purpose or those purposes.
Personal Data must be adequate, relevant and not excessive.
Data is accurate and kept up to date.
Data is not kept longer than is necessary.
Data shall be processed in accordance with the individual’s rights.
Data will be secure.
Data will not be transmitted abroad without adequate protection.
We confirm we will not process data unless one or other of the following conditions apply:
The Data Subject has consented to the processing.
It is necessary for the performance of a contact with the individual.
It is required under a legal obligation.
To protect the interest of the individual.
It is for the purpose of carrying out public functions, including complying with legal obligations.
It is necessary to pursue our interests and those of third parties.
Sensitive personal data will not be processed unless one of the following pre-conditions are met:
The individual has consented.
The information is required by law for employment purposes.
It is for the protection of the individual or another person.
It is required to be processed by operation of law.
Individuals have the right of access to data held about them. If a request for information is made we will reply within 40 days, subject to any fee payable.
We will only process data necessary . . .
To establish, maintain membership or support.
To provide or administer activities for people who are members of the organisation or who have regular contact with it
Unless it is necessary, to share with people and organisations to carry out the organisation’s activity.
Only keep the information whilst the individual is a member or supporter or as long as it is necessary
1.1 Canterbury Golf Club is committed to the principles of equality and diversity throughout its workforce, throughout its membership base and customers.
1.2 Canterbury Golf Club considers that everyone should play their part in making golf inclusive and aims to ensure that all people, irrespective of their background, ability or Protected Characteristics, have a genuine and equal opportunity to work at the club, become a member or participate in club life.
1.3 Canterbury Golf Club will embed these values within all areas of its work.
1.4 Canterbury Golf Club will not disadvantage any individual, whether they are participants, contractors, players, parents, coaches, officials, and volunteers by imposing any conditions or requirements which cannot be justified in the provision of its services.
1.5 Canterbury Golf Club is also committed to supporting the rights and interests of those who it employs. Details of its commitment to equality matters relating to its staff are set out in the staff handbook
1.6 This policy will be reviewed at least every 3 years by the Management, any amendments shall be effective from the date stated.
2.1 The purpose of this Policy is to:
2.1.1 Outline the obligations of those upon whom this Policy is binding;
2.1.2 Promote fairness, equality, diversity and respect for everyone working, volunteering, or participating in the sport of golf, or otherwise using the services at Canterbury Golf Club.
3. LEGISLATIVE FRAMEWORK
3.1 Canterbury Golf Club is committed to complying with all relevant legislation enacted or amended from time to time which underpins the principles of equality, diversity, and inclusivity, including but not limited to:
· The Equality Act 2010;
· The Protection from Harassment Act 1997;
· The Employment Act 2002;
· The Part Time Workers (Prevention of Less Favourable Treatment) Regulations 2000;
· The Fixed Term Employees (Prevention of Less Favourable Treatment) Regulations 20002; and
· The Human Rights Act 1998. 2
This Policy shall apply to, and be binding upon Canterbury Golf Club, its Board of Directors, staff, volunteers, contractors, squad players, agents, and representatives working or acting for or on behalf of Canterbury Golf Club.
5. POLICY IMPLEMENTATION
5.1 Canterbury Golf Club will:
5.1.2 Encourage the involvement of all people regardless of background, ability, or any Protected Characteristic, in golf;
5.1.3 Ensure that all competitions, events and activities administered by Canterbury Golf Club are carried out in a fair and equitable way (except where specific situations and conditions prevent this, and except where Positive Action is necessary);
5.1.4 Monitor and review all Canterbury Golf Club policies and procedures to ensure that they comply with the requirements of this Policy;
5.1.5 Monitor the diversity of its members, participants, players and volunteers in order to better understand the diversity that currently exists within Canterbury Golf Club. All such monitoring of personal data shall be undertaken in compliance with England Golf’s Data Protection Policy and the Data Protection Act 2018.
5.1.6 Provide appropriate training and support to all staff, contractors, officials and volunteers to raise awareness of both the collective and individual responsibilities imposed by this Policy and the Key Concepts outlined in Paragraph 6 of this Policy.
5.1.7 Publish this Policy on its website.
6. KEY CONCEPTS
6.1 Direct and indirect discrimination is outlined in Appendix One;
6.2 Harassment is outlined in Appendix Two; 6.3 Victimisation is outlined in Appendix Three;
7.1 Canterbury Golf Club takes seriously all claims of inappropriate behaviour, bullying, harassment, victimisation and/or discrimination, whether direct or indirect, by a contractor, player, parent, coach, official or volunteer who works for, on behalf of, or represents Canterbury Golf Club.
7.2 Alleged breaches of this Policy shall be dealt with using the Club’s complaints, disciplinary or staff grievance procedure as appropriate.
3 APPENDIX ONE -The Equality Act 2010 and Discrimination
Every individual and organisation to whom this Policy applies must not act in a way which is directly or indirectly discriminatory and must make reasonable adjustments to avoid discriminating against anyone with a Protected Characteristic. Failure to do so will be considered a breach of this Policy, and may be a breach of the Equality Act 2010,
The Equality Act 2010 makes it unlawful to discriminate directly or indirectly against individuals or groups with certain “Protected Characteristics”. The “Protected Characteristics” are listed in section 4 of the Act:
· Gender Reassignment;
· Marriage and Civil Partnership;
· Pregnancy and Maternity;
· Religion or Belief;
· Sexual Orientation.
Direct Discrimination is defined at section 13(1) of the Equality Act 2010:
“A person (A) discriminates against another (B) if, because of a protected characteristic, A treats B less favourably than A treats or would treat others.”
For example, if an action or decision is taken by a club which treats females less favourably than males, this would be considered direct discrimination on the grounds of sex, which is a protected characteristic.
Indirect Discrimination is defined at section 19(1) of the Equality Act 2010:
“A person (A) discriminates against another (B) if A applies to B a provision, criterion or practice which is discriminatory in relation to a relevant protected characteristic of B's.”
Indirect discrimination occurs where less favourable treatment is not necessarily the main effect or objective of an action or decision. Since the nature of indirect discrimination is that the discriminatory effect an unexpected or unforeseen effect of a good faith decision, complaints of indirect discrimination should therefore be considered carefully and objectively, and not dismissed out of hand purely because the effect was not an expected or intentional one.
If, for example, a golf club introduces a rule that club competitions can only be played on Saturdays, this rule would prevent members with certain religious beliefs from taking part in the competition. Although it may not have been the intention of the golf club, the 4 effect of the rule is the less favourable treatment of members on the grounds of religion or belief, which is a protected characteristic. This is indirect discrimination.
Actions and Intentions
An action or decision will still be considered discriminatory even if the less favourable treatment is unintentional. It may not always be obvious to the perpetrator that their actions are discriminatory.
Indirect discrimination is often unintentional, but it is not a defence to an allegation of discrimination to say that the perpetrator did not mean to discriminate against a person or group.
Discrimination can arise out of actions and decisions, but can also arise out of omissions and failure to take actions or decisions.
Everybody to whom this Policy applies is under a duty to make reasonable adjustments to avoid discriminating against any individual or group with a Protected Characteristic. The duty is to make reasonable adjustments. It is not unreasonable for adjustments to cost time, money, or other resources.
However, an adjustment may not be reasonable if the cost is disproportionately high, or making the adjustment would be unfeasible.
It can be lawful to make decisions that discriminate on the basis of a Protected Characteristic in very limited and exceptional circumstances, if the discrimination is a ‘Positive Action’ taken in order to address an underrepresented group or Protected Characteristic.
Positive Actions must be reasonable, justifiable, and clearly linked to a legitimate aim. Examples In a golfing context, some examples of unlawful discrimination might include:
· Not allowing the use of golf buggies, as this increases the cost of maintaining the course;
· Restricting the number of tee times available to women during peak hours at a golf course;
· Not allowing competitions to be played on alternate days to accommodate for certain religious beliefs.
5 APPENDIX TWO - Harassment
Harassment is defined in section 26(1) of the Equality Act 2010. Harassment occurs where a person engages in unwanted conduct related to a Protected Characteristic (outlined in the Equality Act 2010), which has the purpose of either:
· Violating the other person’s dignity; or
· Creates an intimidating, hostile, degrading, humiliating or offensive environment for the other person. In determining whether conduct amounts to harassment, regard is had to:
· The perception of the victim;
· Whether it is reasonable for the conduct to have the perceived effect; and
· The Wider circumstances of the matter.
Sexual harassment occurs where a person engages in unwanted conduct of a sexual nature, and the conduct has the purpose or effects outlined above.
One Off Incidents
A single, isolated, or one-off incident can still amount to harassment. The key consideration is the purpose or effect of the conduct.
Protection from Harassment Act 1997
Harassment can still occur even if it not based on a Protected Characteristic. The Protection from Harassment Act 1997 made it a civil, and sometimes a criminal, offence to carry out a course of conduct that amounts to harassment. Examples In a golfing context, some examples of unlawful harassment might include:
· Employees making unwanted or inappropriate contact with colleagues at a golf club or facility;
· Targeting disabled golfers using buggies and demanding to see proof of a disability;
· Disproportionate and public criticism or sanctioning of an individual’s behaviour by an organisation for irrelevant or personal reasons.
6 APPENDIX THREE - Victimisation
Victimisation is defined in section 27(1) of the Equality Act 2010.
Victimisation occurs where a person suffers a detriment because they do a protected act, or are believed to have done a protected act.
A protected act includes bringing legal proceedings or making a complaint under the Equality Act 2010 in relation to discrimination, harassment, bullying, or any other issue related to equality, diversity or Protected Characteristics.
A detriment can be any less favourable treatment, including direct acts such as suspensions, fines, sanctions, and verbal and physical aggression. It is not necessary to show that somebody is being treated less favourably than somebody else who did not do a protected act, only that they have been subject to a detriment because of a protected act.
Examples In a golfing context, some examples of unlawful victimisation include:
· Initiating disciplinary proceedings against a person as a result of making a protected act;
· Ignoring a person’s valid input into the management of a club or county after that person has made a protected act; De-selecting a player from a squad or team as a result of that person doing a protected act.
What information do we collect about you?
How will we use the information about you?
Access to your information and correction
How to contact us
What information do we collect about you?
We collect information about you when you register with us or book a tee time. We also collect information when you voluntarily complete entry forms, registration cards, provide feedback and participate in competitions. Website usage information is collected using cookies.
How will we use the information about you?
We collect information about you to process your booking/order, manage your account and, if you agree, to email you about other products, news and services we think may be of interest to you. We may use your information collected from the website to personalise your repeat visits to our website.
Canterbury Golf Club Limited will not share your information for marketing purposes with companies outside the Canterbury Golf Club Group.
In processing your order, we may send your details to, and also use information from credit reference agencies and fraud prevention agencies.
We would like to send you information about products and services of ours and other companies in our organisation which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of Canterbury Golf Club Ltd.
If you no longer wish to be contacted for marketing purposes, please email firstname.lastname@example.org
Access to your information and correction
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 email or write to us at the following address. We may make a small charge for this service.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.
For further information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
How to contact us
I, Roger Hyder, on behalf of Canterbury Golf Club, promises that we will:
1. Value the personal information entrusted to us and make sure we respect that trust;
2. Go further than just the letter of the law when it comes to handling personal information, and adopt good practice standards;
3. Consider and address the privacy risks first when we are planning to use or hold personal information in new ways, such as when introducing new systems;
4. Be open with individuals about how we use their information and who we give it to;
5. Make it easy for individuals to access and correct their personal information;
6. Keep personal information to the minimum necessary and delete it when we no longer need it;
7. Have effective safeguards in place to make sure personal information is kept securely and does not fall into the wrong hands;
8. Provide training to staff who handle personal information and treat it as a disciplinary matter if they misuse or don’t look after personal information properly;
9. Put appropriate financial and human resources into looking after personal information to make sure we can live up to our promises;
10. Regularly check that we are living up to our promises and report on how we are doing.