Tennis Integrity Unit Privacy Policy

Who are we and what is our 'Privacy Policy'?

The Tennis Integrity Unit ("TIU", "we", "us") is the dedicated anti-corruption unit for professional tennis and is charged with enforcing the sport's zero tolerance policy towards gambling related corruption world-wide.
We are an unincorporated association established and funded by: the International Tennis Federation ("ITF"), the Association of Tennis Professionals ("ATP"), the Women's Tennis Association ("WTA") and the Grand Slam Committee (together referred to as the "Governing Bodies").
This Privacy Policy sets out how we collect, use and share personal information. If we update our Privacy Policy, we will post any changes on our website: www.tennisintegrityunit.com (our "Website").

What personal data do we collect?

Preventing and detecting gambling-related corruption: We collect personal data about tennis players, courtsiders, gamblers and other individuals in the tennis community, including tournament officials, coaches, physiotherapists, match supervisors, umpires, media representatives and other individuals who have obtained accreditation for the purposes of attending a professional tennis match or other competition organised, sanctioned or recognised by any of the Governing Bodies as a player guest or as tournament support provider.

The personal data we collect is from a variety of sources and includes but is not limited to the following:

• Player information that is publicly available from Governing Body websites, for example player photographs and statistics;
• Information about players' match performance, physical fitness and ability;
• Personal data relating to individuals that are the subject of an allegation of corruption that we receive by email or other form of communication, including from anonymous sources;
• Names/contact details of players and match-related information requested from a match supervisor (and/or other tournament accredited personnel) including information relating to: (i) the scorecard; (ii) any potentially significant acts such as injuries/illness; (iii) a break in play; (iii) the names of a player's medical team; and (iv) details of any treatment provided;
• Name, date of birth, aliases, contact details and photographs of courtsiders, any reasons for their exclusion from tournament grounds and information about their presence at a particular match;
• Names/contact details of accredited persons and/or their behaviour/activities at a particular tournament;
• Names/contact details of banned players and whether or not they were excluded from a particular tournament;
• Account and/or other personal data provided by betting companies or the European Sports Security Association relating to players and/or gamblers with links or suspected links to a player;
• Information provided by players/witnesses in the context of an anti-corruption investigation, e.g. telephone records, bank details and credit card transactions or other personal data obtained from a recorded interview with players and/or witnesses or from the forensic investigation of a device surrendered by a player or other person covered by the Uniform Tennis Anti-Corruption Program;
• Players' disciplinary records provided by Governing Bodies;
• Personal data obtained from 'open source' media (e.g. Facebook, Twitter etc.) relating to players and other individuals of interest in the context of investigating alleged corruption.

'No-credentials' list: TIU operates (on behalf of itself and the Governing Bodies) a 'no credentials' list of individuals who are subject to exclusion from tournaments sanctioned or recognised by the Governing Bodies. In doing so, it processes details such as:

• Name, date of birth, alias and photograph of individuals who have engaged in, or have been suspected by Governing Bodies to be engaged in, 'courtsiding' activities (together with the reasons for their exclusion from a particular tournament);
• Name and alias information in relation to: (i) individuals that have been subject to a ban arising from a TIU investigation under the Uniform Tennis Anti-Corruption Program; or (ii) individuals that are known by TIU to have links to gambling syndicates.
  

Participation in TIPP: We process the following personal data in the context of administering TIPP:

• IPIN, player name, date of birth, nationality and email address;
• Details in relation to the registration for, and completion of, the TIPP training.

Other information: We process personal data relating to individuals who contact us (e.g. via email, via our Website, letter etc.). We also automatically collect some information about your computer when you visit our Website. For more information, please see our Cookies Policy, which tells you how we use cookies and other tracking technologies on our Website. From time to time, we hold information relating to the alleged harassment of players (e.g. relating to abusive or threatening Facebook messages or bogus social network pages) if we are concerned about the legal rights/safety of players.

Do we collect sensitive personal data?

Certain information is considered "sensitive" under European law and has special protection. Sensitive personal data includes information about an individual's racial or ethnic origins, political opinions, religious beliefs, trade union membership, health, sexual life and the commission or alleged commission of any offence. Some of the personal data that we collect may include sensitive personal data (e.g. injury information relating to players, information relating to the commission or alleged commission of gambling or fraud offences). We will process sensitive personal data only for the purposes outlined in this Privacy Policy.
As a "Covered Person" (as defined in the Uniform Tennis Anti-Corruption Program), you are giving us your express consent to: (i) the processing of your personal data, including sensitive personal as set out in this privacy policy; (ii) the recording of any interviews with you in connection with investigating alleged breaches of the Uniform Tennis Anti-Corruption Program; and/or (iii) the submission to us and forensic investigation by us of devices that we request for the purposes of investigating alleged breaches of the Uniform Tennis Anti-Corruption Program.

How do we use personal data?

We may use personal information:

• to prevent or detect corruption and/or other breaches of the Uniform Tennis Anti-Corruption Program;
• in connection with the detection or prevention of crime or the apprehension or prosecution of offenders;
• in connection with the operation of the 'no-credentials' list referred to above;
• to administer the TIPP;
• to defend the legal rights, property and/or safety of the TIU or others;
• to communicate with you generally (e.g. dealing with your inquiries, comments and requests); and/or
• as otherwise described to you at the point of collection.

With whom do we share personal information?

We may share personal information with third parties, including but not limited to:

• Betting companies to ascertain whether individuals subject to the Uniform Tennis Anti-Corruption Program have betting accounts and to obtain further information where required;
• Law enforcement agencies in connection with the prevention or detection of crime or the apprehension or prosecution of offenders;
• Governing Bodies and or Governing Body lawyers for the following purposes: (i) in connection with any investigation into a breach of the Uniform Tennis Anti-Corruption Program; (ii) for onward transmission to various tournaments in connection with protecting the intellectual property rights (i.e. the scorecard data) of the Governing Bodies at a particular event; and/or (iii) to report on whether a player has registered for/completed TIPP;
• United Kingdom's Gambling Commission and other gambling commissions in the event of an actual or suspected gambling offence under applicable laws;
• Our service providers and suppliers who provide services to us or on our behalf (e.g. translation service providers, forensic service providers, IT providers etc.); and
• Other bodies in connection with purpose specific data sharing activities consistent with the role of the TIU from time to time (e.g. Olympics committees).

We also may share your information in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; as otherwise required by law; when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities otherwise than in the context of the Uniform Tennis Anti-Corruption Program; and to protect and defend the rights, property, or safety of TIU and others. If we are organised or restructured to another organisation, we may transfer personal information we hold to that organisation.

Do we send personal data outside Europe?

In order to determine whether an investigation should proceed to the hearing stage, we disclose the relevant investigation file to the Professional Tennis Integrity Officers representing each Governing Body, two of which (i.e. the ATP and the WTA) are established in the US. We also send personal data to the ATP and WTA in the context of the operation of the 'no-credentials' list. In addition, we send personal data to betting companies located outside Europe to ascertain whether individuals subject to the Uniform Tennis Anti-Corruption Program have betting accounts and to obtain further information where required.
The data protection and others laws of countries outside the European Economic Area may not be as comprehensive as those in the United Kingdom, but we will take reasonable steps to ensure that personal data is protected.

How can you access your information or tell us about inaccuracies?

You have a right to access the personal information held about you. To obtain a copy of the personal information (for which we may charge a small fee) or to tell us about any inaccuracies in the personal data we hold about you, please contact us using the contact details provided below.

How to contact us

If you have any requests concerning your personal information or any queries with regard to our privacy practices please contact us at: info@tennisintegrityunit.com