Privacy Policy

Phoenix Career Development Ltd · Company Number: 17265405

This policy is provided in compliance with UK GDPR, the Data Protection Act 2018 and the Data (Use and Access) Act 2025. Last updated: June 2026.

Phoenix Career Development Ltd is the data controller for the personal data we process.

Contact: felix@phoenixfoundation.com

What data we collect and why:

Players & Candidates:

We may collect:

  • Name, date of birth, contact details

  • Football academy history and playing background

  • Career aspirations and development information

  • Session notes, assessments, and progress records

  • Limited safeguarding or wellbeing information where necessary for duty of care, safeguarding, or support purposes

Lawful basis:

  • Contract (delivery of services)

  • Legitimate Interests (programme delivery, assessment, and development planning)

  • Legal Obligation (safeguarding and record-keeping requirements)

Where special category data is processed (e.g. safeguarding or wellbeing information), this is processed only where necessary and in line with UK GDPR Article 9 conditions, including safeguarding and substantial public interest where applicable.

Parents & Guardians:

We may collect:

  • Name and contact details

  • Relationship to the player

  • Communication records relating to support and safeguarding

Lawful basis: Contract, Legitimate Interests

Football Club Contacts:

We may collect:

  • Name, job title, organisation

  • Contact details

  • Records of communications relating to partnerships and player development

Lawful basis: Legitimate Interests

Employer & Coaching Contacts:

We may collect:

  • Name, organisation, role, contact details

  • Records of introductions, opportunities, and placement activity

Lawful basis: Legitimate Interests, Contract (where applicable)

Website & Enquiry Data:

We may collect:

  • Name, email address, phone number

  • Organisation name (if provided)

  • Enquiry content submitted via our website contact forms or email

Lawful basis: Legitimate Interests (responding to enquiries and business development), Contract (where services are requested or entered into)

How long we keep your data:

We retain personal data only for as long as necessary for the purposes for which it was collected:

  • Player and programme records: 6 years after programme completion

  • Safeguarding records: 10 years or until age 25, whichever is longer

  • Contract records: 6 years from contract end

  • Financial records: 6 years (HMRC requirement)

  • Enquiry data: up to 12 months from last meaningful contact, unless it leads to a contract

  • DBS administrative records: up to 6 months (certificate reference only; physical certificates are not retained)

Where data is no longer required, it is securely deleted or anonymised.

Your rights:

Under UK GDPR you have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request erasure where no lawful basis for retention applies

  • Object to processing based on legitimate interests

  • Withdraw consent where consent is used

  • Request restriction of processing

  • Data portability where applicable

To exercise these rights, contact:
felix@phoenixfoundation.com

We will respond within one month unless an extension is permitted under UK GDPR.

Who we share your data with:

We do not sell personal data.

We may share personal data where necessary and lawful for service delivery, including:

  • Football clubs and academy partners

  • Employers and organisations involved in opportunities, introductions, or placements

  • Safeguarding bodies or statutory authorities where there is a legal or safeguarding obligation

  • Professional service providers (e.g. cloud storage, email systems, CRM platforms, IT support) acting as data processors under written contracts

All third parties are required to process data securely and only in accordance with our instructions.

Data security:

We implement appropriate technical and organisational measures to protect personal data, including:

  • Access controls and role-based permissions

  • Password protection and secure authentication

  • Secure cloud-based storage systems

  • Confidential handling of safeguarding-related data

  • Limiting access to personal data to authorised personnel only

International transfers:

Some service providers may process data outside the UK. Where this occurs, we ensure appropriate safeguards are in place, such as:

  • UK adequacy regulations, or

  • Standard Contractual Clauses approved under UK GDPR

Cookies and website data:

Our website may use essential cookies and optional analytics tools to understand usage and improve performance.

Where non-essential cookies are used, consent will be requested via a cookie banner. Users can withdraw consent at any time via browser settings.

Contact & complaints:

If you have concerns about how we handle your personal data, please contact:

felix@phoenixfoundation.com

We will respond promptly and work to resolve any issues.

If you remain dissatisfied, you have the right to complain to the Information Commissioner’s Office (ICO):
https://ico.org.uk or 0303 123 1113