WORLD RUGBY PASSPORT PRIVACY STATEMENT
World Rugby Limited together with its associated companies, World Rugby Tournaments Limited, World Rugby Development Limited, World Rugby Strategic Developments Limited and Rugby World Cup Limited, each of which has an address at World Rugby House, 8-10 Lower Pembroke Street, Dublin 2, Ireland ("World Rugby", “us”, “our”, or “we”) take your privacy seriously and are committed to protecting your personal information. This privacy statement relates to each of the informational and educational sites maintained by World Rugby which you access (whether via web browser or mobile app) via your “World Rugby Passport” login, namely:
World Rugby Limited acts as the controller of your personal information. Our data protection officer is Liam McKenna and you may contact our data protection officer by emailing [email protected] or by writing to our postal address at World Rugby House, 8-10 Lower Pembroke Street, Dublin 2, Ireland and marking your envelope “Data Protection Officer”.
This privacy statement sets out an explanation of what personal data we collect from you when you use the sites, how and why we collect and use that data, who your information is shared with and a description of your rights with respect to your information.
In order to access all of the informational and educational content on the sites, you must first register with World Rugby Passport and set up a user profile. If you use the sites without registering with World Rugby Passport, we will not collect your registration data or education and accreditation data but we may still collect aggregated and anonymised statistical data (as described below). If you do not provide the registration data, we will not be able to provide you with the World Rugby Passport service.
What information do we collect?
In order to register you on World Rugby Passport and set up your user profile, we collect the following information (which you provide us via a registration form):
- Your Name;
- Your email address;
- Your gender;
- The nature of your involvement in rugby;
- Your country of residence;
- Your choice of password (for you to use for log-in purposes once your user profile has been set up),
If you do not provide the registration data, we will not be able to provide you with the World Rugby Passport service.
Information about you will also be collected when you contact us (e.g. by keeping a record of that correspondence), request particular information or subscribe to our newsletter services or other services that may be available on the sites (“correspondence data”).
Education and Accreditation Data
As the sites provide you with access to online training courses and modules and provide you with information on training courses and events which you can attend in person and assessments which you can sit for further accreditation, we also collect the following information about you:
- When you partake in any online training courses provided on the site, a record that you took part in that online training course and any accreditation you achieved (including the course name and date of accreditation);
- Details of your attendance in person at “offline” face-to-face training courses and events – your attendance at such courses and events will be logged by way of an electronic sign-in at the relevant course or event and subsequently uploaded by us to the World Rugby Passport site;
- Details of any assessments which you sit (whether online or in person), your assessment transcript and the results you achieved in such assessments; and
- Where you seek accreditation as a World Rugby Educator or Trainer, we will keep a record of such accreditation and will request a photograph of you in order to issue you with your educator/trainer accreditation Licence. We will also request your home address in order for us to send you “World Rugby Workforce” branded kit.
(the “education and accreditation data”).
We may also collect information about your interaction with the sites and the services on the sites. This may include information about your computer and, where available, your IP address operating system and browser type. World Rugby performs statistical analysis of user behaviour and characteristics in order to measure interest in and use of the various areas of the sites and to ascertain the number of users that have visited particular web pages (“statistical data”). This is done on an aggregated and anonymous basis. In performing statistical analysis, parts of the sites use Google Analytics (a web analytics service provided by Google, Inc.) to capture and analyze sites statistics. For more information on Google Analytics please see www.google.com/analytics/learn/privacy.html
Posted Content Data
World Rugby Science Network Data
Where you have applied for membership of the World Rugby Science Network, in addition to your Registration Data and Contact Data, we will also collect details relating to your affiliated club, team or Union, the institution with which you are affiliated, your role within your organisation, the highest qualification you hold and the year such qualification was gained, your biography (where you choose to provide one) and your preferences as to whether you wish appear in the list of members, whether you are happy for your email address to be include d in the list of members and whether you wish to receive the World Rugby Science Network quarterly email digest (if available).
Goggles Trial Data
If you wish to participate in our World Rugby Goggles Trial, you will need to register an account with the sites and provide Registration Data (see above). Once you have registered, if you would like to participate in the Goggles Trial, you will be asked to provide further personal information pursuant to the Goggles Trial terms and conditions. This personal information will be processed in accordance with our Goggles Trial Privacy Statement which is available here.
In addition, we may also collect personal information through the submission to us of confidential reports of approaches, suspicions or actual or potential breaches of our integrity or anti-corruption regulations via our Integrity site (integrity.worldrugby.org). We use personal information collected in connection with such reports in accordance with our Confidential Reporting Policy, which is accessible here.
How we use your information
Registration data and correspondence data - purposes of processing and legal basis
We collect and process your registration data and correspondence data for the purposes of administering your registration with and access to World Rugby Passport and to address any requests or correspondence you send to us. We collect gender and country-of-residence information to enable us to monitor engagement with the game of rugby across different gender and location demographics to ensure that we can further our legitimate interests in ensuring growth in the numbers of women participating in rugby and ensuring that people can engage with the game of rugby across all regions.
Our legal basis for collecting and using this personal data is our legitimate interests in administering a series of websites which facilitate participation by you (and other Passport users) in the game of rugby and in making educational and informational content regarding the game of rugby available and accessible to the widest possible range of people.
Education and accreditation data - purposes of processing and legal basis
We collect your education and accreditation data to keep a record of the educational modules and courses you have undertaken and the accreditations you have achieved. Our legal basis for these activities is our legitimate interests in ensuring that people who are involved in the game of rugby (e.g. as a coach, medic, trainer, educator, match official, etc.) have access to, and receive, an appropriate level of education in respect of the game of rugby (including in relation to the laws of the game, coaching and officiating best practice, anti-doping, integrity, player welfare and risk management). This also enables us to ensure that people participating in the game of rugby at higher levels meet minimum educational and accreditation requirements.
We use statistical data collected from your use of the sites to make ongoing improvements to the structure and content of the sites, to give you a better service, and to provide you with information you request, including information about World Rugby, its events, the Game of Rugby Union and/or the World Rugby Passport.
Posted Content Data
World Rugby Science Network Data
Where you have requested to receive the World Rugby Science Network quarterly digest, we process your data to send you this digest on the basis of your express consent. You may withdraw your consent by editing your preferences on your World Rugby Science Network profile, or by contacting us (see “Marketing Communications” and “How to contact us” below).
Automated Decision Making
Where you partake in an online assessment linked any of our online learning modules, your personal data will be subject to automated decision making, as an automated process is used to determine whether your answers to the assessment questions are correct (by comparison against the designated correct answer). Where you answer all questions correctly you will be issued with certification in respect of the relevant module. The purpose of this process is to ensure that module certification is only issued where the module assessment has been successfully completed.
Children under 16
We understand that extra considerations must be taken when processing the personal data of children under 16, and have taken this into account in drafting this privacy notice, and in concluding that our legitimate interests can be relied on as the legal basis for our processing of children’s registration, correspondence, education, accreditation, and statistical data.
How your information might be shared
World Rugby in general only uses the personal data you provide within the World Rugby group of companies for the purposes described above (see “How we use your information”). However, we may share your personal information with companies, organisations or individuals outside of World Rugby in one or more of the following situations:
- We share your registration data and education and accreditation data with our Team of Regional Training Managers (engaged by our Regional Associations), who organise and administer regional educational courses. This is to enable our Regional Training Managers to understand the educational needs of rugby participants in their region and to organise appropriate educational courses.
- We may need to provide third party service providers with access to your information to enable us to obtain maintenance, administrative or technical support for the sites or to obtain other services (including the distribution of World Rugby Workforce kit for Licenced Trainers and Educators). These service providers are not authorised by us to use or disclose personal data except as necessary to perform services on our behalf or comply with legal requirements;
- We share your information with the Rugby Union in your country of residence and the Regional Association of which it is a member.
- World Rugby provides national Rugby Union bodies with statistical information on education and training participation levels in their country. This is done on an aggregated and anonymous basis so that no personal data is disclosed.
- If you are a rugby official, coach, medic or player the national Rugby Union body in your jurisdiction of residence, or in jurisdictions where you will engage in the game of rugby, may ask World Rugby to provide details of any World Rugby training and accreditation you have undertaken and achieved via World Rugby Passport. This information is needed by national Rugby Unions to ensure that rugby officials, coaches, medics and players have completed this important training. We will share this information (together with your name, email address; and country of residence) with a national Rugby Union body if requested to do such national body, and the national Rugby Union body will be required to comply with applicable data protection and privacy laws when using any personal data we give them for their purposes.
- We may also share your information with the organising committees of World Rugby tournaments if you are participating in any World Rugby tournaments as a player, coach, match official, manager, doctor or other medical staff, or team official to enable the organising committees to ensure that you have completed the necessary training and educational courses and achieved the accreditation that is appropriate to the capacity in which you are participating in the relevant tournament.
- Where you apply to become a member of the World Rugby Science Network, we will share your data with the editors of the World Rugby Science Network to enable them to assess your application for membership and to facilitate your membership of the network.
- Any posted content you provide to use via the Interactive Areas will also be available to other users of such Interactive Areas.
- We may also share your personal information with third parties:
- when required by law or in response to legal process;
- in response to a request from law enforcement relating to a criminal investigation;
- to protect our rights, privacy, safety or property, or that of the public;
- to analyse our data, conduct mobile analytics services or to maintain and improve our services (subject to confidentiality agreements as appropriate);
- to permit us to pursue available remedies or limit damage that we may sustain;
- if the rights or safety of another individual might be violated or in threat; and
- where you otherwise consent to us doing so.
We may also share aggregated or de-identified information about the users of the sites with our worldwide partners, tournament sponsors and official suppliers.
Will your information be transferred abroad?
In connection with the sharing of your information described above, depending on your country of residence and/or where you engage in the game of rugby, we may share your information with Regional Training Managers , national Rugby Union bodies, Regional Associations, tournament organising committees or service providers that are located in jurisdictions outside of the European Economic Area (“EEA”) where the level of protection afforded to personal data is not as high as that in the EEA. If we transfer personal data to such locations, we will ensure that appropriate measures are in place to comply with our obligations under applicable law in respect of such transfers. Such measures may include entering into ‘standard contractual clauses’ in the form approved by the European Commission or, in respect of transfers to the USA, ensuring that the transfer is covered by the EU-US Privacy Shield framework. If you would like further details of the measures that we have taken in this regard, please contact us using the contact details set out below (see “How to contact us”).
How long do we keep your information?
We will keep your registration data and education and accreditation data for as long as you maintain your registration with World Rugby Passport, to enable us to keep a complete log of your educational and training activities. Inactive World Rugby Passport accounts are reviewed on a periodic basis and are deleted where there has been no login to the account for more than 2 years, save where there is an active educator or trainer license/accreditation, or any face-to-face or online course accreditations or attempts logged on the account (whether such courses are completed or not) (as these details need to be retained as a permanent log of education/accreditation records).
You have the right to prevent marketing information being sent to you. If you prefer not to receive marketing information from us please ensure that you do not tick the "opt in" box which appears where you are submitting your personal information. If you wish, at any time, to be removed from our newsletter list, please send an email with "unsubscribe" in the Subject line to [email protected]
The security of the information you provide is very important to us and we try to provide secure transmission of your information.
While we strive to protect your personal information, we cannot guarantee the security of any data transmission over the Internet. Once we receive your information, we take technical and organisational security measures that we believe are reasonably appropriate to protect it from loss, misuse, unauthorised access, disclosure, alteration and destruction to ensure the data's integrity. We use a combination of technological, physical, administrative and organisational controls as well as non-disclosure or confidentiality agreements as we deem appropriate to protect your information.
We urge you to take precautions to protect your personal information when you are on the Internet. Keep any passwords safe and make sure you use a secure browser. In addition, you should take reasonable precautions when using a computer that is not your own or in a public setting.
Your rights to access, correct, modify and/or remove your personal information
You can access and review your registration data and education and accreditation data by reviewing your World Rugby Passport profile once you log on to the sites. You will be able to update and correct some of your personal information by editing the information that appears on your World Rugby Passport profile.
In addition, you also have the following rights under applicable law, although your ability to exercise these rights may be subject to certain conditions:
- the right to receive a copy of and/or access, correct, and/or modify the personal data that we hold about you, together with other information about our processing of that personal data;
- the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete;
- the right, in certain circumstances, to request that we erase your personal data; and
- the right, in certain circumstances, to request that we no longer process your personal data for particular purposes, or object to our use of your personal data or the way in which we process it.
Please note that if you request the erasure of your information or object to our processing information, we may not be able to verify the training and education you have taken, which may have an impact on your ability to participate as a player, coach, manager, medical officer, official or match official in certain rugby tournaments.
In order to exercise any of these rights, please write to us using the contact details specified below. To enable us to address your request, we may need to request further information from you so we can satisfy ourselves as to your identity.
If you have any queries in relation to this privacy statement, or if you would like to contact us in relation to your rights, please write to our us at [email protected] or World Rugby House, 8 – 10 Lower Pembroke Street, Dublin 2.
If you are not happy with the way that we have used your information or address your rights, you have the right to make a complaint to the Irish Data Protection Commission by emailing [email protected]
Changes to this Privacy Statement
We reserve the right to change our security and privacy policies at any time. Accordingly, we recommend that you check this page periodically in order to review our current policies.
Links to other World Rugby websites, or other third party websites
The sites may contain links to other websites whose privacy and information practices may be different to ours, including other World Rugby websites and/or third party websites. We are not responsible or liable for the content or privacy policies of websites other than World Rugby websites. You should be aware of this when you leave the sites and we encourage you to read and familiarise yourself with the privacy policies and/or notices on other websites you visit.
This privacy statement was last updated on 24/09/2018.
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