Data Protection Notice - World Rugby Training and Education Sites

The purpose of this notice is to provide users with details on the personal data which World Rugby Limited collects and processes in connection with the operation of the services provided by World Rugby’s training and education websites (whether accessed via web browser or mobile app), including passport.world.rugby and iris.world.rugby (each as such URLs may be updated from time to time) (the “Sites”).

World Rugby Limited is the data controller of the information about you which is collected through the Sites. World Rugby Limited has an address at World Rugby House, 8-10 Lower Pembroke Street, Dublin 2, Ireland

For any queries relating to this notice, or relating to the personal data which we process in connection with the Sites, World Rugby Limited can be contacted using the contact details specified below. World Rugby Limited’s Data Protection Officer is Liam McKenna and you may contact the Data Protection Officer using the contact details specified below.

Further details on World Rugby Limited’s privacy practices and policies, as well as further details on how World Rugby Limited give effect to data subject rights, can be viewed here: https://www.world.rugby/privacy-policy.

What information do we collect?

Registration Data

We collect the following data about Site users in order to enable users of the Sites and to register their user accounts with the Sites:

  • First name;
  • Last name;
  • Email Address;
  • Year of birth;
  • Your gender;
  • The nature of your involvement in rugby;
  • Your country of residence;
  • The role that you are fulfilling when accessing the Sites (e.g. whether you are a member of the World Rugby Training and Education “Workforce” or not); and
  • Details of your preferences and consents in relation to you receiving marketing messages.

If you do not register and create an account with the Sites, you will not be able to access the official training and educational content and courses available on the Sites.

We also use your email address to send you certificates, accreditations and licences, and to provide you with details of up-coming face-to-face courses in your country/region which you may be interested in attending in furthering your education in rugby.

The account which you create in order to access the Sites may, where appropriate to your involvement in rugby or your role in your organisation, be used to provide you with access to other World Rugby platforms pursuant to Single-Sign On protocols.

Education and Accreditation Data:

As the Sites provide users with access to online training courses and modules and provide users with information on training courses and events which they can attend in person and assessments which they can sit for further accreditation, the following information about users will also be collected:

  • When users partake in any online training courses provided on the site, a record that they took part in that online training course and any accreditation achieved (including the course name and date of accreditation);
  • Details of user attendance in person at “offline” face-to-face training courses and events – user attendance at such courses and events will be logged by way of an electronic or manual sign-in at the relevant course or event and subsequently uploaded by the event administrator to the Iris site(s);
  • Details of any assessments which users sit (whether online or in person), assessment transcripts and the results achieved in such assessments; and
  • Details of any certificates, licences and accreditations earned by you following completion of World Rugby’s official training and education courses (or any other courses recognised by World Rugby as being equivalent to such official courses). This includes details of “Workforce” licences and accreditations and mandatory certification required to be held by any individual seeking to act as a team or tournament doctor at elite levels of rugby.

We will collect education and accreditation data to keep a record of the educational modules and courses undertaken, the accreditations achieved, and accreditations, certificates and licences issued in accordance with good educational and academic practice.

Additional data for members of “Workforce”

Where you are a member (or are seeking to become a member, or were formerly a member) of the World Rugby Training and Education “Workforce” (i.e. a licensed and accredited educator, trainer, master trainer or national or regional education manager), in light of the additional responsibilities you have as a member of the Workforce, we also collect the following information about you:

  • A record of all trainer or educator accreditations achieved by you;
  • Details relating to your trainer and educator licence (including the scope of such licence and its expiry date);
  • a photograph/headshot for inclusion on the educator/trainer accreditation licence we issue to you;
  • your home address so that we can issue you with “World Rugby Workforce” branded kit;
  • Logging and recording the data which you have submitted to the Sites (e.g. in relation to face-to-face courses which you have delivered), and when this was submitted, so that this can be checked and verified in the event that any queries subsequently arise the data you have submitted;
  • Logging of your interactions with the system in accordance with good logging, monitoring and auditing practices for systems of this nature in the interests of assuring the security of the system and the access and privilege controls and restrictions that are in place.

Your status as a member of the “Workforce” may be shared with other “Workforce” members to enable you to liaise with each other on good educational practice, educational priorities for face-to-face assessment and for peer review and interaction purposes.

Marketing Data

Where you indicate via your registration with the Sites, or by adjusting your preferences on your Site account that you consent to receiving marketing messages, we will send you promotional offers, rewards, discounts and other information from carefully selected commercial partners of the Sites.

Where you consent to receiving marketing communications from World Rugby, we will send you such communications.

Additional Anti-Doping and Anti-Corruption Education Data

Where you are involved in elite or national representative rugby, taking World Rugby’s official anti-doping and anti-corruption educational courses (or courses delivered by other organisations that World Rugby  recognises as being equivalent to such official courses), your personal data will be subject to additional processing in the following ways:

  • We may collect further identifiers relating to you such as your date of birth and the specific national representative team that you are a member of, in order to more specifically identify you and your educational history and to ensure that your education needs (and those of your team) are being met by World Rugby, your national Union and your National Anti-Doping Organisation;
  • We may collect data about your pre-existing levels of knowledge prior to taking our anti-doping or anti-corruption courses and how difficult you find questions on online courses (e.g. by measuring questions answered incorrectly/drop-off points/time taken to answer questions). This is for the purpose of verifying the effectiveness of current educational content, ensuring that you receive the education on anti-doping and anti-corruption that you need and allowing any specific knowledge gaps to be identified and addressed at a team level;
  • To provide you with the opportunity to opt-in to participate in research or surveys relating to anti-doping or to becoming an anti-doping ambassador with World Rugby.

Data on licensed agents

If you are an authorised and regulated agent under World Rugby Regulation 5, we may keep a record of your continuing education and professional development learning, and, in the interests of transparency, details of your status as an authorised agent under World Rugby Regulation 5 may be published on the Sites or elsewhere by World Rugby.

Posted Content Data

We use your posted content data, when you provide such data to us, for the purposes of enabling and facilitating discussion of ideas and the sharing of content in the Interactive Areas and for ensuring that users of the Interactive Areas comply with the Terms of Use applicable to such Interactive Areas.

Correspondence Data

Information about you will also be collected when you contact us (e.g. by keeping a record of that correspondence), for example in connection with any aspect of your use of the Sites.

Other Functional and Usage 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.

Cookies

We may track your activity on the Sites via the use of cookies in accordance with our Cookies Policy.

Uses of your data and lawful basis

The below table sets out the uses which we make of your data, and the lawful basis on which each use is grounded:

Category of Data

Uses

Lawful Basis

Registration Data

To register you on the Sites and enable safe, secure and effective authentication of your account each time you visit the Sites, and ensure that your access privileges are commensurate with your role in accessing the Sites in accordance with standard authentication, user management, access control, registration and security processes.

 

This is necessary in order for us to perform our contract with you and your Authorised Organisation regarding access to the Sites as set out in the Terms of Use for Sites.

Education and Accreditation Data

To keep a record of the educational modules and courses undertaken, the accreditations achieved, and accreditations, certificates and licences issued in accordance with good educational and academic practice.

 

To enable our Member Unions and Regional Associations record and monitor education and accreditation data for rugby participants active within their governed territories.

 

 

This is necessary in our legitimate interests as the global governing body of rugby 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. This also enables us (and our Member Unions and Regional Associations) to ensure that people participating in the game of rugby at higher levels meet minimum educational and accreditation requirements.

Additional Workforce Data

To enable us to monitor and verify the credentials, accreditations and competencies of all Workforce members who have been licensed to deliver training and education content (and who may be provided with privileged access to the Sites).

 

To log the data being submitted to the Sites, and when and by whom is was submitted, so that any queries in relation to the data being submitted can be addressed and followed-up on.

 

To log and monitor user activity for security and access control reasons in accordance with good logging, monitoring and auditing practices.

 

To confer on Workforce members the privileges and benefits associated with such membership.

This is necessary in our legitimate interests in conferring the benefits of Workforce membership on licensed trainers and educators, ensuring the appropriateness of all licensed members of the Workforce, ensuring the accuracy of the data being submitted to the Sites and in resolving queries regarding such data, and in our legitimate interests in assuring the security of the Sites and the data held thereon in accordance with good information security practice.

Marketing Data

To send you communications, promotions and offers, and/or to enable commercial partner(s) of the Sites to send you offers, promotions and rewards, in accordance with the preferences and consents you communicate to us.

 

Your consent to receive such communications.

Additional Data Regarding Anti-Doping and Anti-Corruption Education

We use this data to more specifically identify you and your educational history, to verify the effectiveness of current educational content and to ensure that your education needs (and those of your team) are being met by World Rugby, your national Union and your National Anti-Doping Organisation.

 

 

 

 

 

To provide you with an opportunity to opt-in to partake in anti-doping research or surveys, or to become an anti-doping ambassador.

This is necessary in our legitimate interests in ensuring that elite participants in rugby receive effective education in the areas of anti-doping and anti-corruption regulation and that a coordinated approach across different regulators in this area (including Member Unions and National Anti-Doping Organisations) is taken.

 

Any data processed in relation to anti-doping research/surveys or in relation to becoming an ambassador will be based on your consent.

 

Licensed Agent Data

We use this data to ensure that appropriate training and professional development content is available for licensed agents and to make sure that the status of licensed agents is available to those affected by their work in a transparent manner.

 

This is necessary in our legitimate interests of ensuring appropriate regulation, training and transparency with respect to the work of agents who are licensed under World Rugby Regulation 5.

Posted Content Data

We use your posted content data, when you provide such data to us, for the purposes of enabling and facilitating discussion of ideas and the sharing of content in the Interactive Areas and for ensuring that users of the Interactive Areas comply with the Terms of Use.

This is necessary in order to provide the Interactive Areas to you pursuant to our Terms of Use.

Correspondence Data

To enable us to respond to and address any queries, questions or other issues you raise with us

This is necessary in our legitimate interests in addressing your queries, questions and concerns.

Other Functional and Usage Data

To monitor Site usage and to ensure that any functional issues with the Site are identified and remediated and that the Site is working as efficiently and effectively as possible.

This is necessary in our legitimate interests in ensuring the Academy is run on an effective and efficient Site and solving any functional issues encountered with respect to the Site.

Cookies Data

Information collected via statistical/analytical cookies

Where you have consented to us using such cookies in accordance with our cookies policy.

 

Sharing personal data

We may share personal data with certain third parties in connection with the above purposes:

  • With Dovetail Technologies, who support the Sites, in connection with the functioning, administration and maintenance of Sites and all data and functionality available on Sites;
  • We may share your personal data with other technology and IT service providers in connection with the analysis, processing and storage of data referenced above in connection with Sites;
  • We may also share your personal data with third party service providers who we engage in connection with certain services relating to the Sites (e.g. the distribution of World Rugby Workforce kit for Licenced Trainers and Educators). These third parties are liable to change from time to time and their activities will be subjected to contractual obligations;
  • Any posted content you provide to use via the Interactive Areas will also be available to other users of such Interactive Areas.
  • World Rugby shares information about Site users with national rugby Unions and Regional Associations in the following ways:
    • providing national Unions 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;
    • Data will be shared with nominated training and education managers in each national rugby union and each Regional Association affiliated to World Rugby regarding individuals who have completed any online modules or face-to-face training courses in their jurisdiction (in the case of national Unions), or their region (in the case of Regional Associations), to enable such managers to verify course completions, education status, accreditations, etc. of participants in rugby in the territory for which such Member Unions and Regional Associations are responsible;
    • If a user is a rugby official, coach, medic or player the national Member Union in jurisdictions where the user will engage in the game of rugby (e.g. at competitions), may ask World Rugby to provide details of any World Rugby training and accreditation such users have undertaken and achieved via the Sites. This information is needed by national Rugby Unions to ensure that rugby officials, coaches, medics and players participating in tournaments in their jurisdiction have completed this important training.
  • For participants in elite rugby, Additional Anti-Doping and Anti-Corruption Education Data may be shared with a Member Union and/or National Anti-Doping Organisation for the purposes described above.
  • We may also share personal data 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.

International transfers of personal data

In some of the circumstances described above, personal data may be transferred, accessible or visible to individuals and/or entities located outside of the European Union. Countries outside the European Union may not provide a level of legal protection for personal data as strong as the level of protection provided in the EU. Where we transfer your personal data to a recipient based outside the European Union, we will put in place a data transfer agreement with the overseas recipient of the information, protecting the information, in the appropriate standard form approved for this purpose by the European Commission (please contact us if you would like to see a copy of any of these agreements). The only exceptions are where we transfer information to member states of the European Economic Area or to countries outside the European Union which have been determined to provide an adequate level of protection by the European Commission, or where the transfer is legally justified on another basis.

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.

Right to Withdraw Consent

If you have given us your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes. You may withdraw your consent to receiving marketing communications from us by contacting us using the details below, or by availing of the unsubscribe option available to you in each communication.

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 the Sites, to enable us to keep a complete log of your educational and training activities. Inactive 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 nor) (as these details need to be retained as a permanent log of education/accreditation records).

Rights to access, correct, modify and/or remove your personal information

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.

If any such individual has any questions about this notice, or regarding the Site more generally, you can contact us at the contact details as set out below.

Contact details:

If you have any queries in relation to this privacy statement, or if you would like to contact World Rugby Limited in relation to your rights, please write to us at [email protected] or World Rugby House, 8 – 10 Lower Pembroke Street, Dublin 2.

You can contact our Data Protection Officer by emailing [email protected].

Complaints

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 using the following link: https://forms.dataprotection.ie/contact.