GDPR : What are the implications for LMS systems ?

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Nick Grey
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Re: GDPR : What are the implications for LMS systems ?

Post by Nick Grey » Sat Feb 10, 2018 7:54 pm

Consequences of Brexit are huge but I doubt there are any consequences on chess LMS systems.

I'm quite happy for my games to be published. Particularly any amusing ones. It can give everyone a laugh.
Not particularly happy if date of birth is published to the wider world.
And if ECF, Fide or a tournament organiser has my date of birth. It will nice if they sent a card or e-card on my birthday but not disclose it to the wider world.

Funnily enough I have never seen John's terms and conditions, and never passed onto leagues, or clubs to pass onto very oid players without computers, or new. And we have not got any small print in our agreements as members of a club. But make them aware of league rules.

Actually Surrey implemented a very good one on conduct of players, rather than just club officials, and it ought to be implemented far more widely.

Had plenty of annual agreements with players as a football club secretary - as it is part of FA rules, Surrey FA rules, and helps run the game the right way. And bans those that need to be kicked out of the game.

As long as LMS are not going to charge leagues, clubs or Individuals more money that is fine by me. Though on any voting I would go for one system for the ECF and expect them to carry out the appropriate legal and financial checks. Is your system work not for profit. I doubt it? Any of my chess voluntary work is free.

I'd want one source of input so that the ECF can sort out grading themselves without 3rd or 4th parties. And rather not have it too frequently.

John - Be very nice please and change my age to grumpy old git if it appears on your system or any links to your system. :lol:

Roger de Coverly
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Re: GDPR : What are the implications for LMS systems ?

Post by Roger de Coverly » Mon Feb 12, 2018 5:27 pm

The ECF considered this issue at their December board meeting, the Minutes for this have recently been published.

http://www.englishchess.org.uk/wp-conte ... r-2017.pdf
13.
Data Protection: Changes to legislation coming into May 2018 (GW)
New legislation is coming into place in May 2018. GW is to attend a training course,
and will update the board as appropriate. The biggest impact is likely to be on leagues and congresses, who will need to obtain permission in some instances to submit game results to the ECF. The situation is exacerbated by leagues in particular not having access to individual players’ contact details.
The bigger question is that given it's not just chess as every amateur sports or social organisation is likely to be affected, not just in the UK but across Europe is "Why are government agencies acting in this manner"?

If it affects the submission of results to the ECF for grading, it must also affect the submission of results to FIDE for international rating.

NickFaulks
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Re: GDPR : What are the implications for LMS systems ?

Post by NickFaulks » Mon Feb 12, 2018 6:29 pm

Roger de Coverly wrote:
Mon Feb 12, 2018 5:27 pm
"Why are government agencies acting in this manner"?
Because they can.

Neill Cooper
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Re: GDPR : What are the implications for LMS systems ?

Post by Neill Cooper » Tue Feb 13, 2018 11:24 am

I think the ECF grading database storing the dates of birth of sixty thousand people, mainly inactive players, and then circulating them to all graders in a readable form, is a GDPR issue. How many of these people have given permission to the ECF to store and circulate their dates of birth?

Roger de Coverly
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Re: GDPR : What are the implications for LMS systems ?

Post by Roger de Coverly » Tue Feb 13, 2018 11:32 am

Neill Cooper wrote:
Tue Feb 13, 2018 11:24 am
How many of these people have given permission to the ECF to store and circulate their dates of birth?
Not just the ECF, FIDE as well. Perhaps even more so, as supplying a date of birth is a condition of gaining a FIN and being allowed to play in a FIDE rated event. But that's an issue that applies to all countries in the EU, unless, that is, the UK has uniquely gold plated the Directives.

There's a standard phrase which at least some Congresses include on their entry forms, namely
By entering, players agree to their grading information being published on the ECF website.

John Upham
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Re: GDPR : What are the implications for LMS systems ?

Post by John Upham » Tue Feb 13, 2018 11:33 am

Neill Cooper wrote:
Tue Feb 13, 2018 11:24 am
How many of these people have given permission to the ECF to store and circulate their dates of birth?

I have so that is one to start with.

Neill Cooper
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Re: GDPR : What are the implications for LMS systems ?

Post by Neill Cooper » Tue Feb 13, 2018 3:32 pm

Roger de Coverly wrote:
Tue Feb 13, 2018 11:32 am
There's a standard phrase which at least some Congresses include on their entry forms, namely
By entering, players agree to their grading information being published on the ECF website.
Which does not give permission to the ECF to store and circulate their date of birth, as that is not amongst the info on the ECF website. What is more my understanding is that under GDPR it is up to the ECF to ensure that it has the permissions by contacting those on its lists. However, many have not played chess for years.

Roger de Coverly
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Re: GDPR : What are the implications for LMS systems ?

Post by Roger de Coverly » Tue Feb 13, 2018 3:39 pm

Neill Cooper wrote:
Tue Feb 13, 2018 3:32 pm
What is more my understanding is that under GDPR it is up to the ECF to ensure that it has the permissions by contacting those on its lists.
It could always blank out the dates of birth for inactive players, or at the very least not circulate them to graders. Dates of birth are part though of the system for identifying players, including returning ones. Before it took such action, I would hope that it would, along with the thousands of other organisations potentially affected ask for a clear statement from government that this was parliament's intention when passing GDPR into law.

John Upham
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Re: GDPR : What are the implications for LMS systems ?

Post by John Upham » Tue Feb 13, 2018 3:52 pm

Neill Cooper wrote:
Tue Feb 13, 2018 3:32 pm
What is more my understanding is that under GDPR it is up to the ECF to ensure that it has the permissions by contacting those on its lists.
Would you hazard a guess as to the proportion of persons that are listed on the ECF Master List (let us say 130,000 ?) for which the ECF has up-to-date email addresses or other forms of contact information ?


Of course, a fair proportion are deceased.

David Gilbert
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Re: GDPR : What are the implications for LMS systems ?

Post by David Gilbert » Tue Feb 13, 2018 5:45 pm

John Upham wrote:
Tue Feb 13, 2018 3:52 pm
Neill Cooper wrote:
Tue Feb 13, 2018 3:32 pm
What is more my understanding is that under GDPR it is up to the ECF to ensure that it has the permissions by contacting those on its lists.
Would you hazard a guess as to the proportion of persons that are listed on the ECF Master List (let us say 130,000 ?) for which the ECF has up-to-date email addresses or other forms of contact information ?


Of course, a fair proportion are deceased.
It remains to be seen whether consent will be an issue for chess. Personal data can still be processed without consent where it’s necessary for the performance of a task carried out in the public interest. The relaying of results; the collection of grading information and the publication of a grading list; or the on-line publication of pairings and entry lists; could all be considered to be in the wider public interest for the chess community, as could the collection of age related data to identify players eligible for seniors events. Anyone will have the right to see what information is held about them and the right to correct any errors, furthermore they will have a legal right to be forgotten.

Alex Holowczak
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Re: GDPR : What are the implications for LMS systems ?

Post by Alex Holowczak » Tue Feb 13, 2018 11:26 pm

When the current system was set up, ECF officials were in contact with the ICO about the data they collect, and the way it was used. The ICO were satisfied, and so when the occasional person wrote to the ECF, we know that the ICO is aware of and satisfied with what the ECF is doing under the current legislation.

Clearly there are changes with the new legislation, but as David Sedgwick intimated some time ago in this thread, ECF officials are reviewing it.

Kevin Thurlow
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Re: GDPR : What are the implications for LMS systems ?

Post by Kevin Thurlow » Wed Feb 14, 2018 10:05 am

"When the current system was set up, ECF officials were in contact with the ICO about the data they collect, and the way it was used. The ICO were satisfied, and so when the occasional person wrote to the ECF, we know that the ICO is aware of and satisfied with what the ECF is doing under the current legislation."

So it's being done properly. Good.

Neill Cooper
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Re: GDPR : What are the implications for LMS systems ?

Post by Neill Cooper » Wed Feb 14, 2018 1:57 pm

Nick Grey wrote:
Fri Feb 09, 2018 8:08 pm
GPDR is something about Member States in EU which we are leaving?
It is UK law, passed by UK Parliament: "People to have more control over their personal data and be better protected in the digital age under new measures announced by Digital Minister Matt Hancock."
https://www.gov.uk/government/news/gove ... ection-law
"The Bill will bring the European Union’s General Data Protection Regulation (GDPR) into UK law, helping Britain prepare for a successful Brexit."

Mike Gunn
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Re: GDPR : What are the implications for LMS systems ?

Post by Mike Gunn » Wed Feb 14, 2018 5:14 pm

I learned today that the British Go Association (which used to store dates of birth for similar reasons to the ECF) that they now just store month and year of birth. While this is obviously personal data and could be subject to data privacy legislation there is the advantage that a leakage of data wouldn't lead to the actual DOB being used to crack (for example) a bank security system.

Nick Grey
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Re: GDPR : What are the implications for LMS systems ?

Post by Nick Grey » Wed Feb 14, 2018 5:54 pm

I'm fully aware of data protection and also Childrens' Services legislation, and a whole lot more. I must admit when those looking at data protection cannot understand that the records they are looking for may well be manual files it astounds me. I have Police and Criminal Evidence Act training as well.

I'm happy for Fide to show my birth year. I'm not particularly happy with them on lots of other grounds - supporting terrorism, excluding nations and their players, and as for governance and finances, the sort of grounds that we all ought to blow the whistle on.

I'll be happy for ECF to delete my date of birth as they know how old I am. I may take up that option on my next renewal. I'm clear ECF are doing their best on other issues. But I want any d.o.b. on any grading file or master membership list deleted. It is possible they had this information when I was at school but it was very unlikely it was computerised.

Perhaps I ought to go after CCF as I'm clear I signed the relevant box non-disclosure box on my application (get a fide rating tournament).

As for the bigger picture on Brexit for this country - it may solve the housing crisis but if we have significant movement away from London and surroundings then we will have a lot of empty school places with children and families leaving, as well as huge reductions in teachers and support staff. The new Education SoS will probably just have found out what a mess the civil servants have made on a new national funding formula.

That is without the economy and anything else being dreamed up by those leading on Brexit.

I believe the cost of playing chess is going to go up too over and above inflation for some of the items that the local government minister had to break promises on 19th December wif 1st April, and not very nice to know that my local Council is one of four most badly affected.

The cost of playing chess ought to go down for the ECF if implementing a single system which also has LMS capabilities, rather than let the various LMSs to charge leagues, unions, etc. Just choose the right one after a legal process.

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