Introduction
The Professional Squash Association (PSA) needs to gather, store and use certain information about individuals. This may include players, promoters, customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

The policy describes how this personal data is collected, handled and stored to meet the company’s data protection standards, and to complete with the law.

Why the policy exists
This data protection policy is in place to ensure PSA:

• Complies with data protection law and follows good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

General Data Protection Regulation (GDPR)
From May 2018, the EU General Data Protection Regulation (GDPR) comes into place. Now EU residents will have greater say over what, how, why, where, and when their personal data is used, processed, or disposed, we will keep you informed of any changes we make regarding our privacy policy. The PSA has a dedicated team to assess - and amend where necessary - all data processes.

We will comply with the data protection law, including the six principles of GDPR which are:

• to process data lawfully, fairly and in a transparent manner;
• to collect data for specified, explicit and legitimate purposes, and not process it in a manner that is incompatible with these purposes;
• to ensure that data is adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed;
• to ensure that data is accurate and, where necessary, kept up to date and accurate;
• to ensure that data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed;
• to ensure that data is processed in a manner that ensures appropriate security of the data, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage.

Policy scope
This policy applies to:

• The head office of the Professional Squash Association
• All branches and subsidiaries of the Professional Squash Association
• All staff and volunteers of the Professional Squash Association
• All contractors, suppliers and other people working on behalf of the Professional Squash Association

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR brought into effect in May 2018. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Date of birth
• And any other information relating to individuals

Data protection risks
This policy helps to protect the Professional Squash Association from some very real data security risks, including:

• Breaching of confidentiality. For instance, information being given out inappropriately or without consent.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities
Everyone who works for or with the Professional Squash Association has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

Those that have key areas of responsibility are:

• The Chief Executive Officer
• The Data Protection Officer
• The board of directors is ultimately responsible for ensuring that the Professional Squash Association meets its legal obligations

The data protection officer is responsible for:

• Keeping the board updated about data protection responsibilities, risks and issues
• Reviewing all data protection procedures and related policies, in line with an agreed schedule
• Arranging data protection training and advice for the people covered by this policy
• Handling data protection questions from staff and anyone else covered by this policy
• Dealing with requests from individuals to see the data the Professional Squash Association holds about them (also called ‘subject access requests’)
• Checking and approving and contracts or agreements with third parties that may handle the company’s sensitive data

The IT manager (Rabb-IT) is responsible for:

• Ensuring all systems, services and equipment used for storing data meet acceptable security standards
• Performing regular checks and scans to ensure security hardware and software is functioning properly
• Evaluating any third-party services the company is considering using to store or process data. For instances, cloud services.

The Marketing Manager is responsible for:

• Approving any data protection statements attached to communications such as emails and mailings
• Addressing any data protection queries from journalists or media outlets
• Working with the data protection officer to ensure visibility of the Professional Squash Association’s commitment to data protection

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work.
• The Professional Squash Association will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared [see PSA’s password policy / guidance]
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data protection officer.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people can see them, such as on a printer.
• Data printouts containing personal data should be shredded of and disposed of securely when no longer required.
• When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
• Data should be protected by strong passwords that are changed regularly and not shared between employees.
• If data is stored on removeable media (like a CD, DVD or portable hard-drive), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers and only be uploaded to an approved, secure cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly.
• Computers and devices should all be encrypted.
• Data should never be saved directly to laptops or other mobile devices, like tablets or smartphones.
• All servers and computers containing data should be protected by approved security software and a firewall.

Data use
Personal data is of no value to the Professional Squash Association unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should not be sent by email if this is not encrypted.
• Data must be encrypted before being transferred electronically.
• Employees should not save copies of personal data to their own computer, unless the device is encrypted in case it is breached and can be wiped centrally

Data collection
The Professional Squash Association aims to be clear and transparent with regards to the data it is collecting and how it may be used.

Informed consent is when:

• An individual clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data
• And then gives their consent.

The Professional Squash Association will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form. When collecting data, the Professional Squash Association will ensure that the individual:

• Clearly understands why the information is needed
• Understands what it will be used for and what the consequences are should the individual decide not to give consent to processing
• As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
• Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
• Has received sufficient information on why their data is needed and how it will be used
• Understand how they are able to opt out or retract consent

Data accuracy
The law requires the Professional Squash Association takes reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort the Professional Squash Association should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by
• confirming a customer’s details when they call.
• The Professional Squash Association will make it easy for data subjects to update the information the Professional Squash Association holds about them. For instance, via the company website.
• Data should be updated as inaccuracies are discovered. For example, if a customer can no longer be reached on their stored email addresses, it should be removed from the database.

Subject access requests
All individuals who are the subject of personal data held by the Professional Squash Association are entitled to:

• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, it is called a subject access request.

Subject access requests from individuals should be made in writing via post to PSA, Top Floor West, 46 The Calls, Leeds, LS2 7EY, United Kingdom or via email addressed to the data controller at office@psaworldtour.com and state clearly the data being requested.

It is the Professional Squash Association’s policy that individuals will not be charged for the subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, the Professional Squash Association will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board company’s legal advisors where necessary.

Providing information
The Professional Squash Association aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company. This available on the company’s website.

Data retention
The time that documents are retained will depend on what the document is and also any current legislation regarding the retention period, which the Professional Squash Association are committed to adhering to. Where there is no specific legislation, the Professional Squash Association’s policy on retention of data is that it shall not be kept for longer than is necessary.

February 2022