Data Privacy Summary for Members
Dear Club Member,
We wish to advise you of the General Data Protection Regulation (‘the GDPR’) which comes into effect on the 25th May 2018. The GDPR applies across the European Union (EU) and aims to give individuals more rights, control and understanding of how their personal data is processed.
The GDPR will have no impact on your membership status of the Club however it does require the Fitzwilliam Private Members Club and our service provider, the Golden Horseshoe Limited, to keep you informed of the following:
✓The types of data we hold on you;
✓The purpose it is used for; and
✓Your rights in relation to how it is processed.
The Criminal Justice (Money laundering and Terrorist Financing) Act 2010 identifies Private Member Clubs providing ‘casino like services’ as a ‘designated person’. This legislation imposes an obligation on ‘designated persons’ to identify club members, and to verify the identity of club members. Typically we identify a club member at the time they apply to join the Club based on the information provided by them on their membership application form. In order to verify each member’s identity we seek a copy of government issued photo ID which is in date.
The type of information obtained for membership purposes includes, Name, Home Address, Postcode, Date of Birth, Nationality, contact details such as a mobile phone number and email address, occupation and source of funds. We will also retain information about any previous self-exclusions, seek confirmation that you are the beneficial owner of the funds you are playing with, indicate whether or not you are a PEP, and if so identified, we will retain further details about your occupation and source of funds. This information is required in order that the Club can discharge its legal obligations under AML legislation to the satisfaction of the regulatory authority, in the case of Private Member Clubs, this is the AMLCU in the Department of Justice. We are also required to keep this information accurate and up to date and appreciate your assistance in this regard.
We will also seek and retain information about how you heard about the Fitzwilliam Club and your preferred club activity for marketing purposes. Subject to you providing ‘explicit consent’ to being contacted about promotions in the Club we will use this information for marketing and internal reporting purposes. Your mobile phone number will be shared with our text messaging service provider. However your personal details will not be shared with any 3rd parties, unless legally obliged to do so.
The Club has an obligation to provide a safe environment for its members and a safe working environment for its employees. Any behaviours which may hamper our ability to provide a safe environment for our staff and customers will be recorded and retained for reference purposes to assist the management of the club in ensuring that a safe environment is maintained at all times.
While gambling is an enjoyable activity for most, there are some for which it can get out of hand. Problem gambling has been identified as a growing health problem in Ireland. In order to mitigate the instance of problem gambling in the Club, the Club operates a self-exclusion facility which enables members to suspend their membership for a period of time as they determine. In order to apply our self-exclusion facility in an effective manner, the Club retains any personal information provided by the individual club member themselves at the time of self-excluding, or a concerned family member, so that the club can prevent the individual from re-entering the Club at a later date. In the interests of clarity, a suspension of membership is not a cancellation of membership.
A club member may opt to cancel rather than suspend their membership. It is the Club’s policy to retain personal data for five years from the date of cancellation. However, where a member seeks to cancel their membership and has previously availed of our self-exclusion facility due to concerns of a gambling addiction, details of the self-exclusion will be retained to ensure that a Club member, who has previously identified themselves as having a problem gambling and self-excluded, cannot regain entry to the club and reignite their addiction.
As a provider of casino like services to customers engaging in significant cash transactions on a regular basis there is a heightened security risk. Accordingly the Club is obliged to capture extensive CCTV coverage of the premises and to retain these images for periods of time ranging up to 13 weeks for operational and security purposes. Voice recordings may also be captured alongside the photographic images. The images and voice recordings are reviewed from time to time to investigate mistakes, errors, and theft and can be used as evidence to exonerate or prosecute staff members, club members, or other 3rd parties as deemed necessary by the Club or its agents. The Club may also be required, upon application by the policing authorities, revenue authorities, or AML Inspectors to provide copies of any CCTV that is the subject of a legitimate data protection request.
Live video feed
The company also permits its business partner, Lyvegame (previously Dublinbet) to capture a live feed from a number of the Club’s gaming tables and to provide a live stream (including sound and images) for distribution via their business partners gaming technology platforms to online gaming service providers. Accordingly these sounds and images are available live over the internet via a number of website portals. The tables used to capture these ‘live feeds’ are clearly identified by signage. Staff members will also be able to advise customers which tables are so used if required. The Club does not have access to these recordings of sound or images. The Customers should be aware that while playing on these tables their activities are being broadcast live over the internet. Customers who venture close to these tables should be aware that they may be included in the live broadcast if they are in close proximity to the gaming tables from which the live feed is being captured. Lyvegame does retain an archive of the live stream for 30 days to facilitate reviews and investigations into any suspicious transactions or activities. Lyvegame has confirmed that the live stream is not used in any other forum for promotional purposes.
Live streaming from RFID poker table
The Club runs larger poker tournaments from time to time and operates an RFID table which facilitates a live broadcast of sound and images, subject to a time delay, over the internet onto ‘Youtube’/‘Facebook’. The live stream once downloaded onto Youtube/Facebook remains available on the Youtube/Facebook platform for viewing by any individual with access to the internet. While customers playing on the RFID table will be aware that their activities are being broadcast live over the internet, other customers should be aware that they may be included in the live broadcast if they are in close proximity to the table from which the live feed is being captured.
Contact for Marketing Purposes
For those members who opted to be kept informed about events and promotions in the Fitzwilliam Casino & Card Club we will continue to keep you informed through our monthly newsletter on areas such as competition/prize winners, leagues you may be competing in, tournaments you may be interested in, special offers at the restaurant and relevant club events at the Fitz. This is in line with your contact preferences previously indicated as an active member of the club and in accordance with the consent/legitimate interest provisions of the New GDPR Regulations.
If you have already elected to be on our mailing list and are in receipt of emails, for example our Club Newsletter, you can Unsubscribe from this at any time by clicking on the Unsubscribe link at the bottom of the email. You may also Opt Out of the company text alerts anytime by following the “Opt Out” instructions at the bottom of any of the text messages you may have received from us. Alternatively you can phone us on 01 611 4677 if you would prefer us to manually unsubscribe you from direct communications from the Fitzwilliam Casino & Card Club.
Your rights of access
If you would like to make a Data Access Request under the New GDPR Law from May 25th we are happy to assist you. Simply email us your request to firstname.lastname@example.org or write to us at Fitzwilliam Casino & Card Club, Clifton Hall, Lower Fitzwilliam Street, Dublin 2. We will endeavour to deal with your request in an efficient and timely manner. If the information you are seeking relates to a specific event or transaction, our endeavour to respond promptly will be greatly enhanced if you provide an approximate time and date. In all cases we will endeavour to respond within 40 days.
If you require assistance with making a Data protection request please do not hesitate to contact us as indicated above.