1.     INTRODUCTION AND PURPOSE

The FAI Football Management System, “FAI Connect”, is provided by the Football Association of Ireland (“FAI”) to enable players, player parents/guardians, clubs, leagues, affiliated associations, and the FAI to input, store and process certain information about you pertaining to your FAI Connect record and the regulatory governance function of the FAI and its affiliates.

It is a mandatory requirement under the FIFA Regulations for the FAI to implement and use an online electronic information system with the ability to record the registration and transfer of all players under the jurisdiction of the FAI. The FAI has therefore implemented FAI Connect.

The FAI also collects data directly about your use of FAI Connect for its own site administration. The FAI is committed to achieving the highest standards of accountability and excellence in respect of data collection and data usage.

Reference to your personal data in this document will include reference to any personal data relating to your children that you may provide to us.

For the purpose of this document, any reference to we, our or us shall be deemed to be a reference to the FAI via any channel or platform as accessed by you and provided by the FAI.  References to ‘you’ or ‘your’ are references to you in your personal capacity as an individual or in your capacity as a representative where your own personal data has been shared or that of the person you are representing.

Please note that this Privacy Notice is a non-exhaustive reference document outlining the FAI’s collection and use of personal data on FAI Connect, should clarity be sought please contact us directly by emailing datamanager@fai.ie.

This privacy notice aims to give you information on how the FAI collects and processes your personal data through the FAI Connect.

If you are an administrator and are adding or amending data on behalf of an individual, you must make sure that they are aware of this privacy notice. Your club, league, association and the FAI may all be data controllers in respect of data belonging to you that is stored on FAI Connect. Each of those entities will have specific data protection privacy notices to explain in more detail how they will process your personal data. If you would like more information on how your club, league, affiliate association uses your data then you should contact them directly.

It is important that you read this privacy notice together with the FAI Privacy Notice and 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.

Our Websites 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.

Should you wish to contact us in relation to this Privacy Notice we have a designated email to receive and action any requests for information or clarity and please contact datamanager@fai.ie.

At any stage you have the right to make a complaint to the Data Protection Commissioner’s Office (www.dataprotection.ie) being the supervisory authority for data protection issues.  We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner’s Office so please contact us directly in the first instance.

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, any such changes can be reported to us via datamanager@fai.ie

This privacy notice may be updated periodically and without prior notice to you to reflect changes in our practices or relevant laws.

This version was last updated on 14 March 2023

2.     THE DATA WE COLLECT ABOUT YOU

Personal Data

Personal 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 as follows:

• Identity Data includes first name, last name, your photograph, username or similar identifier, title, marital status, date of birth, gender, country of birth, club membership or affiliation.
• Contact Data includes home address, billing address, delivery address, email address, telephone numbers, next of kin contact details.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, courses or programmes booked and attended.
• Device Data includes the type of mobile device you use, a unique identifier for example, your devices IMEI number, the MAC address of the devices wireless network interface, the type of browser you use, type of the mobile phone.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes username and password, purchases or orders made by you, your interests, participation history / statistics, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences and consents.
• Engagement Data includes, but is not limited to, your membership and registration details; identification documents; immigration documents; recruitment information; records and information on participation, ranking, ratings, playing details, history, competition results; attendance and performance; performance data; accreditations, qualifications, experience in current and previous employment; disciplinary and grievance information; information inputted on to the FAI’s game management system; CCTV footage and other information obtained via electronic and digital means, including footage of football matches in which you have participated.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories
“Special categories” of particularly sensitive personal information require higher levels of protection (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). We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

• In certain circumstances, with your explicit written consent.
• Where necessary to carry out our legal obligations.
• For the safeguarding of children and individuals at risk.
• Anti-doping in sport.
• Standards and behaviours in sport.
• When required for the public interest, such as for equal opportunities monitoring.
• Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
• In particular we may request medical or health information in order to ensure you or your child’s safety and suitability when participating in certain FAI events.   You are not obliged to provide this information but if we are not made aware of any relevant medical issues we will be unable to take appropriate measures to ensure your or your child’s safety.
• In other instances we may collect information about other special categories such as ethnicity for statistical purposes or to assist us with achieving intercultural and diversity aims. The provision of such information is optional.

FAI Connect and System Provider

Analyticom is the third party service provider that hosts the FAI Connect system. Analyticom will be able to access the system and your data for technical support purposes. Analyticom is not entitled to use your data for their own purposes unless you agree to them doing so.

All data captured via the system will be stored in Analyticom’s data centre in Germany. Your  registration information may be entered into the FAI Connect system by a club official at your current club, although the data will initially be collected from you.

Information about you may be shared amongst Leagues, Provincial Associations, the FAI and other Football Associations for football administration purposes. Information relating to your disciplinary record and any misconduct charge will be provided by a referee or disciplinary authority directly into FAI Connect. This information will be shared with the Disciplinary Committee and where necessary, any Appeals Committee. Where you are a club official, information may initially be entered into the system by the FAI or by another club official. Information about training or usage checks may also be provided by a third party.

Further information

We may provide you with further specific information about the type of data and purpose of it at the point of data capture.  Should you have any queries in relation to your data and how we may use it please contact us at datamanager@fai.ie.

3.     HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

Direct interaction; You may give us your Identity, Contact, Engagement and Financial Data by filling in forms (in writing or electronically) on the FAI’s football management system or by submitting any other applications to the FAI or by corresponding with us by post, phone, email or otherwise. This includes but is not limited to personal data you provide when you :

• apply to enrol for a course, training programme or event on FAI Connect;
• create an account or profile on FAI Connect;
• register as a player, coach, staff member, match official, Club/League/Affiliate Association official, or Football Agent on the FAI’s football management system;

• give us some feedback.

Automated technologies or interactions; As you interact with our website or mobile applications, 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 policy for further details.

Third parties or publicly available sources; We may receive personal data about you from various third parties who we are partnered with as set out below:

• FAI affiliated club or team in which you or your child are a member;
• FAI Affiliated Members;
• Leagues administered by FAI Affiliate Members;
• FIFA/UEFA, Sport Ireland or any other sports governing body that controls data about you;
• Other stakeholders including law enforcement or statutory bodies.

4.     HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when we have a lawful basis under the legislation to do so. With respect to FAI Connect, we may use your personal data in the following circumstances:

• To respond to your enquiry;
• To administer the relevant competition;
• To perform any contract we may enter into with you;
• To track your activity on FAI Connect;
• To create a profile on FAI Connect;
• To personalise and improve your experience on FAI Connect;
• Other reasonable purposes for which you have provided information;
• For playing record purposes on the FAI Connect mobile application;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where required to comply with a legal or regulatory obligation.

The section below sets out the types of lawful basis that we will rely on to process your personal data.  Generally we do not rely on consent as a legal basis for processing your personal data (save where consent is lawfully required e.g. for sending electronic marketing purposes). If consent is used as a legal basis for processing your data, you have the right to withdraw consent at any time by contacting datamanager@fai.ie.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of the main purposes for which we process your personal information together with the legal basis we rely upon to do so. We have also identified what our legitimate interests are where appropriate.

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. Please contact datamanager@fai.ie should you require details about the specific legal ground on which we rely to process your personal data where more than one ground has been set out in the table below.

The lawful basis of processing that we use include;

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting datamanager@fai.ie
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Change of purpose
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 you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact datamanager@fai.ie.

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.

Opting Out
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of Garda Vetting applications, course participation, membership registration or other transactions or use of FAI Connect.

6.     DISCLOSURES OF YOUR PERSONAL DATA 

We may have to share your personal data with the parties set out below for the purposes set out above.

Internal Third Parties.
Other members of the FAI corporate group.

External Third Parties

• FAI Affiliated Associations.
• Leagues that are administered by the FAI Association.
• Football Clubs under the jurisdiction of the FAI.
• FIFA, UEFA, Sport Ireland and other governing bodies for football who may reasonably require your personal data for the administration of football.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, payroll, banking, legal, insurance and accounting services.
• Individual or bodies appointed by the FAI including, but not limited to, LOI Department, Competitions Department, Referee Committees, Disciplinary Committees and Appeal Committee members (or independent arbitration services) or independent Club Licensing committee.
• Statutory authority or agency as appropriate.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

7.      INTERNATIONAL TRANSFERS  

We may transfer the personal information we collect about you and stored within FAI Connect outside the EU in order to comply with our legal and regulatory obligations to UEFA, FIFA or any other appropriate body involved in the governance of football in Ireland or elsewhere or for the purposes of an International Transfer Certificate.

8.     DATA SECURITY  

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.

9.     DATA RETENTION

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.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Information stored for disciplinary purposes may be stored and retained indefinitely in order to administer the FAI’s regulatory function and maintain a record of the game.

10.  YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You may

• Request access to your personal data.
  This is commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.  For more information on our subject access request policy please contact datamanager@fai.ie .

• Request correction of your personal data.
  This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data.
  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data.
  You may object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

• Request restriction of processing your personal data.
  This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer of your personal data to a third party.
  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you

• Right to withdraw consent.
  Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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.

For further information on your rights in respect of your personal data please visit www.dataprotection.ie and should you wish to exercise any of the rights set out above, please contact datamanager@fai.ie with your specific query or request.