1. Who We Are Birmingham City Football Club Limited/Birmingham City Women Football Club Limited (“we”, “us”, “our”) processes personal data relating to external job applicants, candidates, agency workers, and individuals involved in recruitment processes. This privacy notice applies to all individuals whose personal data we process as part of recruitment and hiring activities. We are committed to protecting personal data and ensuring compliance with UK GDPR, including fair recruitment, safeguarding, and lawful processing of personal data.
Data Controller: Birmingham City Football Club Limited/ Birmingham City Women Football Club Limited Address: St Andrews @ Knighthead Park, Cattell Road, Birmingham, England, B9 4RL Data Protection Officer: dpo@bcfc.com
2. What Personal Data We Collect We collect and process personal data as part of our Record of Processing Activities (Article 30 UK GDPR). a. Identification & Contact Data
a. Identification & Contact Data
Name, date of birth, nationality
Address and contact details (email, telephone)
Right-to-work information
b. Recruitment & Application Data
CVs, application forms, covering letters
Employment history, qualifications, and experience
Skills, competencies, and suitability for the role
Interview notes and selection decisions
References and referee details
Cookies
IP Address
c. Assessment & Selection Data
Interview recordings & interview Notes(where applicable)
Psychometric or aptitude testing
Skills assessments and work samples
d. Background & Pre-Employment Checks
Right-to-work verification
DBS checks (where required)
Qualification and employment verification
e. Communication Data
Emails and correspondence including Whatsapp
Candidate queries and engagement history
f. Agency & Third-Party Data
Candidate profiles provided by recruitment agencies
Notes, recommendations, and availability details
3. Special Category Data (Where Relevant) Where necessary and proportionate, we may process special category data, including:
Health or medical information (e.g. reasonable adjustments)
Equality, diversity and inclusion data (e.g. ethnicity, disability, religion)
Criminal conviction data (e.g. DBS checks, where required)
Such data is processed only where permitted under UK GDPR and the Data Protection Act 2018 and subject to appropriate safeguards, including:
Restricted and role-based access
Data minimisation
Enhanced security controls
4. How We Use Your Data We process personal data for the following purposes:
Recruitment & Selection
Assess suitability for roles
Shortlist, interview, and select candidates
Make hiring decisions
Candidate Evaluation
Compare candidates against role requirements
Assess qualifications, experience, and competencies
Conduct structured interviews and assessments
Pre-Employment & Compliance Checks
Verify identity, right to work, and qualifications
Conduct DBS or background checks where required
Equality & Diversity Monitoring
Monitor fairness and non-discrimination
Support inclusive recruitment practices
Communications
Provide updates on applications
Respond to candidate queries
Issue outcomes and feedback where appropriate
To book in interviews, calls or meetings
Compliance & Legal Obligations
Meet employment, safeguarding, and regulatory requirements
Maintain records for audit and legal defence
AI & Profiling We may use limited automated tools to support recruitment, such as:
CV screening or candidate matching
Safeguards include:
Human oversight in decision-making
No solely automated decisions
Ability to request explanation or challenge outcomes
5. Lawful Bases for Processing
We rely on the following lawful bases:
Article 6(1)(b) Contract – steps prior to entering employment
Article 6(1)(c) Legal obligation – right-to-work checks, safeguarding requirements
Article 6(1)(a) Consent – optional processing (where applicable)
For special category data:
Article 9(2)(b) – employment obligations
Article 9(2)(g) – substantial public interest (safeguarding)
Article 9(2)(h) – health data (reasonable adjustments)
Article 9(2)(a) – explicit consent (where required)
6. Who We Share Data With Internal
HR and recruitment teams
Hiring managers
Safeguarding leads (where applicable)
Senior management
External
Recruitment agencies and applicant tracking systems
Background check providers (e.g. DBS services)
Legal advisers and auditors
Regulators or law enforcement where required
Technology providers supporting recruitment systems
Approved data processors who provide: (All processors operate under written data processing agreements in accordance with Article 28 UK GDPR.)
ATS & HR systems
Recruiters
Reference & Right to Work Platforms
DBS Checking Platforms
Finance and Administration Systems
Safeguarding Sharing Where necessary, data may be shared with:
Police and law enforcement
Local authorities (LADO)
Social services and safeguarding agencies
Governing bodies
6. International Transfers
Where data is transferred internationally, appropriate safeguards such as UK adequacy regulations, UK IDTA and the Addendum and/or EU Standard Contractual Clauses (SCCs) are in place.
7. Data Retention We retain personal data based on our Retention Policy as follows:
Unsuccessful candidates: up to 12 months after recruitment process
Successful candidates: transferred to HR records and retained typically for 7 years post-employment
DBS/safeguarding data: retained in accordance with legal and regulatory obligations
Data is securely deleted or anonymised when no longer required.
8. Data Security We protect data using:
Encryption and secure systems
Role-based access controls
Restricted access to safeguarding data
Data minimisation and retention controls
9. Your Rights You have the right to: Right to Be Informed You have the right to know how and why your personal data is used. This privacy notice explains what data we collect, how we use it, who we share it with, and how long we keep it.
Right of Access You have the right to request a copy of the personal data we hold about you (often called a “Subject Access Request”). This allows you to understand how your data is being used and check that it is being handled lawfully.
Right to Rectification You have the right to ask us to correct or update any personal data that is inaccurate or incomplete. For example, this could include incorrect contact details, medical information, or player records.
Right to Request Erasure (Where Applicable) You can ask us to delete your personal data in certain circumstances, for example:
Where the data is no longer needed
Where you have withdrawn consent (if consent was used)
However, this is not an absolute right. We may need to keep some data, for example for:
Safeguarding purposes
Legal or regulatory obligations
Ongoing academy operations
Right to Restrict or Object to Processing You have the right to:
Restrict processing – ask us to limit how we use your data in certain situations
Object to processing – where we rely on legitimate interests, you can object if you feel your rights outweigh our reasons for processing
We will consider your request and respond in line with data protection law.
Right to Data Portability Where applicable, you have the right to receive your personal data in a structured, commonly used format and request that it is transferred to another organisation. This typically applies where:
Processing is based on consent or contract
The data is processed electronically
Right to Withdraw Consent Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing carried out before consent was withdrawn. For example, you may withdraw consent for:
Email marketing communications
SMS marketing communications
Direct marketing communications
Personalised marketing activities
Participation in surveys or promotional activities
The use of photographs, videos, or other media content where consent is the lawful basis for processing
Other optional activities where consent has been provided
Once consent is withdrawn, we will stop processing your personal data for the relevant purpose unless another lawful basis applies. You can withdraw consent at any time by:
Updating your communication preferences within your account (where available)
Using the unsubscribe link included in marketing communications
Contacting us at dpo@bcfc.com Contacting the relevant Club department managing the activity concerned
We will action requests to withdraw consent as soon as reasonably practicable and in accordance with applicable data protection laws.
Right to Challenge Automated Decisions You have the right not to be subject to decisions based solely on automated processing (including profiling) that have significant effects on you. Where we use analytics or AI tools (e.g. for performance or scouting):
Decisions are not made solely by automated systems
Human oversight is always applied
You can request an explanation or challenge decisions
10. Data Sources We obtain data from:
Candidates directly
Recruitment agencies
Referees and background check providers
Public professional sources (e.g. LinkedIn)
Referrals
11. Categories of Individuals
Job applicants and candidates
Agency workers and contractors
12. Complaints & Subject Access Requests Complaints will be dealt with by the Data Protection Officer dpo@bcfc.com and will be responded to within 30 days. If you are not satisfied with the response, you should refer your complaint to the ICO https://ico.org.uk/concerns 13.Do We Use Cookies And Other Tracking Technologies? We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.
14. Updates This notice may be updated periodically.