FC Genius Legal Centre

Privacy Policy

Privacy Policy – FC Genius

Version 1.0 · Last updated: 5 July 2026
Data Controller: Global Sport Professionals Ltd, United Kingdom · Contact: contact@globalsportprofessionals.co.uk

1. Introduction

This Privacy Policy explains how FC Genius ("we", "us", "our") collects, uses, stores, and protects personal data when children aged 6 to 15 ("Players") use our football training application ("the App").

Because our users are children, we apply enhanced protection in line with the UK GDPR, the Data Protection Act 2018, and the ICO Children's Code.

A parent or legal guardian ("Parent") must provide verifiable consent before any child can use the App.

2. Who We Are

Global Sport Professionals Ltd
United Kingdom
Email: contact@globalsportprofessionals.co.uk
Phone: +44 7304 345225 · +44 20 3932 2232

We act as the Data Controller for all personal data processed through the App.

3. What Data We Collect

We collect only the data necessary to provide football training, analytics, and communication features.

A. Child Profile Data

• Name
• Age and date of birth
• Gender (optional)
• Club/team (if applicable)

B. Performance & Training Data

• Training metrics (speed, agility, accuracy, etc.)
• Match statistics
• Skill assessments
• Progress reports
• Coach feedback

C. Photos & Videos (Optional)

• Uploaded training videos
• Match footage
• Profile photos (only processed with separate parental consent)

D. Technical Data

• Device type
• IP address
• App usage logs
• Cookies (where applicable)

E. Communication Data

• Messages between coaches and parents
• Notifications and feedback logs

We do not collect unnecessary or intrusive data such as precise GPS location unless explicitly required and consented.

4. How We Use Personal Data

We process data to:

• Provide personalised football training
• Track player development over time
• Generate analytics for coaches
• Enable communication between coaches and parents
• Improve app performance and features
• Ensure safety and compliance
• Maintain secure access and prevent misuse

5. Legal Basis for Processing

A. Parental Consent (Article 6(1)(a))

Required for: creating a child account, processing performance data, sharing data with coaches, and uploading photos/videos.

B. Legitimate Interests (Article 6(1)(f))

For: app security, fraud prevention, and service improvement.

C. Legal Obligations (Article 6(1)(c))

For: safeguarding, and responding to lawful requests from authorities.

6. Sharing of Data

We only share data when necessary and with strict controls. We may share data with verified coaches, club administrators, safeguarding officers, and technology providers (e.g., cloud hosting, analytics tools).

We never sell children's data, share data with advertisers, or share data with unverified individuals. All third-party providers are bound by data processing agreements.

7. Safeguarding & Child Protection

We follow NSPCC and UK safeguarding standards: restricted access to child data, staff background checks where required, monitoring for inappropriate behaviour, reporting mechanisms for concerns, and secure handling of photos and videos.

If a safeguarding concern arises, we may share relevant data with appropriate authorities.

8. International Data Transfers

If data is transferred outside the UK, we ensure adequacy regulations apply, or Standard Contractual Clauses (SCCs) are in place. We only use providers that meet UK GDPR standards.

9. Data Retention

• Active accounts: data retained for service use
• Inactive accounts: deleted after 12 months
• Upon parental request: deleted within 30 days
• Safeguarding records: retained as legally required

10. Your Rights (Parent & Child)

Parents and children have the right to access personal data, correct inaccurate data, request deletion ("right to be forgotten"), withdraw consent at any time, restrict processing, object to processing, request data portability, and file a complaint with the ICO.

To exercise rights, contact: contact@globalsportprofessionals.co.uk

11. Parental Consent

Before a child can use the App, the Parent must create or approve the child's account, verify their identity, provide explicit consent for data processing, and provide separate consent for photos/videos. Consent can be withdrawn at any time.

12. Security Measures

We use industry-standard security, including encrypted data storage, secure servers, access controls for staff and coaches, regular security audits, and data minimisation practices.

Despite safeguards, no system is 100% secure, but we take all reasonable steps to protect data.

13. Cookies & Tracking

If the App uses cookies or similar technologies, we will provide a cookie notice and allow opt-in for non-essential cookies. See our site-wide Cookie Policy for details.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Parents will be notified of significant changes.

DPIA

Data Protection Impact Assessment (DPIA)

Project: FC Genius – Football Training & Performance Analytics App
Organisation: Global Sport Professionals Ltd · Version 1.0 · Date: 5 July 2026
Completed by: FC Genius Product & Safeguarding Team · Reviewed by: Global Sport Professionals Data Protection Lead

1. Project Overview

FC Genius is a digital platform designed for children aged 6–15 to support football training, performance tracking, and communication with coaches. The app collects performance metrics, training data, and optional photos/videos to provide personalised insights and development analytics.

Because the app processes children's data, including potentially sensitive data (video, performance metrics), a DPIA is mandatory under UK GDPR and the ICO Children's Code.

2. Purpose of Processing

The app processes personal data to track football performance and development, provide personalised training insights, enable communication between coaches, parents, and players, generate analytics for clubs and coaching staff, improve training programmes, and ensure safeguarding and safe digital interactions.

The app does not use children's data for advertising, profiling, or automated decision-making.

3. Nature of Processing

Data Collected

• Child profile data (name, age, gender)
• Training and performance metrics
• Match statistics
• Coach feedback
• Photos and videos (optional)
• Device and usage data

Processing Activities

• Storage
• Analysis
• Sharing with verified coaches
• Display in dashboards
• Optional video analysis

Data Retention

• Active accounts: retained for service use
• Inactive accounts: deleted after 12 months
• On parental request: deleted within 30 days
• Safeguarding records: retained as legally required

4. Lawful Basis for Processing

A. Consent (Article 6(1)(a))

Used for: child account creation, processing performance data, sharing data with coaches, photos/videos, and optional features (leaderboards, competitions). Parental consent is required for all children under 16.

B. Legitimate Interests (Article 6(1)(f))

Used for: app security, fraud prevention, service improvement.

C. Legal Obligation (Article 6(1)(c))

Used for: safeguarding, responding to lawful requests.

5. Consultation

Internal Consultation

• Product team
• Safeguarding officer
• Data protection lead
• Technical team

External Consultation

• Football clubs (optional)
• Parents (optional)
• ICO guidance on children's data

6. Data Subjects

Children aged 6–15, parents/guardians, coaches, club administrators. Children are considered vulnerable data subjects, requiring enhanced protection.

7. Risks Identified

Risk table aligned with ICO DPIA standards.

8. Measures to Reduce Risk

Technical Measures

• End-to-end encryption
• Secure cloud hosting (UK/EU)
• Role-based access control
• Multi-factor authentication for coaches
• Encrypted backups
• Regular penetration testing
• Audit logs for all data access

Organisational Measures

• Staff safeguarding training
• Data minimisation policy
• Strict coach verification
• Mandatory parental consent
• Annual DPIA review
• Incident response plan
• Data processing agreements with all third parties

Child-Specific Protections

• Child-friendly privacy notices
• No advertising or profiling
• No dark patterns
• No public leaderboards unless consented
• No direct messaging between children

9. Data Sharing

Data is shared only with verified coaches, club administrators, safeguarding officers, and approved third-party processors (cloud hosting, analytics tools). All third parties must sign a Data Processing Agreement (DPA). No data is sold or shared with advertisers.

10. International Transfers

If data is transferred outside the UK: only to countries with adequacy decisions, or using ICO-approved Standard Contractual Clauses (SCCs).

11. Assessment of Necessity & Proportionality

The processing is necessary to provide personalised training, allow coaches to support player development, maintain safety and safeguarding, and deliver core app functionality. Data collected is proportionate and minimised.

12. Residual Risk

After mitigation, residual risks are low to medium, acceptable with ongoing monitoring. Reviewed annually or after major system changes.

Safeguarding

Safeguarding Policy – FC Genius

Version 1.0 · Date: 5 July 2026 · Organisation: Global Sport Professionals Ltd
Applies to: All staff, coaches, clubs, contractors, and users of the App

1. Policy Statement

Global Sport Professionals Ltd is committed to ensuring the safety and wellbeing of all children who use the FC Genius football training platform. We believe every child has the right to feel safe, every child has the right to protection from abuse, neglect, and exploitation, and that safeguarding is everyone's responsibility.

This policy outlines how we protect children aged 6–15 whose data and interactions occur within the App.

2. Scope

This policy applies to children using the App, parents and guardians, coaches and club staff, employees, contractors and volunteers, and third-party service providers. It covers online safety, data protection, communication, reporting concerns, and behaviour expectations.

3. Safeguarding Principles

We follow the principles of the Children Act 1989 & 2004, Working Together to Safeguard Children (UK), NSPCC Child Protection Standards, FA Safeguarding Policies, and UK GDPR & the ICO Children's Code.

Key principles: the welfare of the child is paramount; all children have equal rights to protection; safeguarding is a shared responsibility; concerns must be reported promptly.

4. Roles & Responsibilities

A. Provider (Global Sport Professionals Ltd)

• Acts as Data Controller
• Ensures platform safety and secure data handling
• Verifies parental consent
• Provides safeguarding training to staff
• Maintains reporting channels
• Investigates safeguarding concerns

B. Coaches & Clubs

• Must complete safeguarding training
• Must follow the Club/Coach Agreement
• Must communicate only through approved channels
• Must report concerns immediately
• Must not privately message children

C. Parents

• Supervise their child's use of the App
• Report concerns
• Manage consent and account settings

D. Children

• Use the App respectfully
• Report anything that makes them uncomfortable

5. Online Safety Measures

A. Restricted Communication

• No child-to-child messaging
• Coaches cannot privately message children
• All communication is visible to parents

B. Content Moderation

• Monitoring of uploaded videos/photos
• Automated detection of inappropriate content
• Manual review where necessary

C. Access Controls

• Coaches must be verified
• Role-based access to child data
• Multi-factor authentication for staff and coaches

D. Behaviour Monitoring

• Audit logs for all interactions
• Alerts for suspicious activity

6. Data Protection & Privacy

We follow UK GDPR and the ICO Children's Code: parental consent required for all children, separate consent for photos/videos, data minimisation, secure storage and encryption, no advertising or profiling, and no sharing with third parties except approved processors. Full details are in our Privacy Policy and DPIA tabs.

7. Acceptable Use Rules

For Coaches

• Communicate respectfully
• Provide constructive feedback
• Never request personal contact details
• Never meet a child alone through the App
• Never share screenshots or data externally

For Children

• Be respectful
• Do not share personal information
• Report anything that feels wrong

For Parents

• Monitor their child's activity
• Report concerns promptly

8. Recognising Abuse

Abuse may include emotional abuse, physical abuse, sexual abuse, neglect, bullying or harassment, grooming, and inappropriate communication.

Coaches and staff must be alert to signs of sudden behaviour changes, fear of certain individuals, disturbing messages or content, and withdrawal or anxiety.

9. Reporting Concerns

Anyone can report a concern.

When to Report

Immediately if: a child is at risk, inappropriate communication occurs, a child discloses abuse, or suspicious behaviour is observed.

External Reporting

We may escalate concerns to Local Authority Safeguarding Teams, the Police, or the NSPCC Helpline.

10. Responding to Concerns

We will acknowledge the report, assess the risk, take immediate protective action if needed, document all findings, escalate to authorities where required, and keep parents informed unless doing so increases risk.

11. Training & Awareness

We provide safeguarding training for staff, guidance for coaches, and clear in-app safety information for parents and children.

12. Photography & Video

Only allowed with parental consent. Only used for training and analysis. Never shared publicly without explicit permission. Stored securely and deleted when no longer needed.

13. Data Retention

Child data deleted after 12 months of inactivity. Photos/videos deleted upon parental request. Safeguarding records retained as legally required.

14. Policy Review

This policy is reviewed annually, after any safeguarding incident, and after major platform changes.

Club/Coach Agreement

Club / Coach Data Processing & Access Agreement

For use of FC Genius – Football Training & Analytics Platform · Version 1.0 · Date: 5 July 2026
Between Global Sport Professionals Ltd ("Provider") and the Club/Coach.

1. Purpose of This Agreement

This Agreement governs how the Club/Coach accesses and processes personal data of children aged 6–15 ("Players") through the FC Genius platform. The Club/Coach agrees to comply with UK GDPR, the Data Protection Act 2018, the ICO Children's Code, and NSPCC safeguarding standards.

The Club/Coach acts as a Data Processor when using the App.

2. Definitions

• Provider, the operator of the App and Data Controller.
• Club/Coach, the organisation or individual accessing Player data.
• Player, a child aged 6–15 whose data is processed.
• Parent, the child's parent or legal guardian.
• Personal Data, any information relating to a Player.

3. Data the Club/Coach May Access

The Club/Coach may access the following data only for legitimate coaching purposes: Player profile (name, age, team), training and performance metrics, match statistics, coach feedback history, photos/videos (if parental consent is provided), and communication logs.

The Club/Coach must not attempt to access any data not explicitly provided.

4. Responsibilities of the Club/Coach

A. Use Data Only for Coaching Purposes

Data may only be used to provide training, track development, give feedback, support safeguarding, and communicate with parents.

B. Maintain Confidentiality

The Club/Coach must keep all Player data confidential, not share data with unauthorised individuals, not export or download data unless permitted, and not store data on personal devices unless encrypted.

C. Follow Safeguarding Standards

The Club/Coach must complete safeguarding training, report concerns immediately, never privately message a child, and communicate only through approved channels.

D. Protect Access Credentials

Use strong passwords, enable multi-factor authentication, and never share login details.

5. Prohibited Actions

The Club/Coach must not use Player data for marketing; use Player data for profiling or automated decisions; share Player data with third parties; post Player photos/videos on social media without explicit parental consent; use Player data for personal or commercial gain; or attempt to re-identify anonymised data.

6. Provider Responsibilities

The Provider will act as Data Controller, obtain and verify parental consent, provide secure access to Player data, maintain audit logs, ensure data minimisation, provide safeguarding and data protection guidance, and notify the Club/Coach of any data breaches.

7. Data Security Requirements

The Club/Coach must use secure devices, keep software updated, use encrypted storage if downloading data, report lost/stolen devices immediately, and follow the Provider's security policies.

8. Data Retention & Deletion

The Club/Coach must delete any downloaded data when no longer needed, immediately delete data if a Parent withdraws consent, not retain data after leaving the club or role, and return or destroy all data upon termination of this Agreement. The Provider will enforce automatic deletion within the App.

9. Data Breach Reporting

If the Club/Coach becomes aware of unauthorised access, a lost/stolen device, accidental disclosure, or misuse of Player data, they must notify the Provider within 24 hours.

10. Monitoring & Audit

The Provider may monitor access logs, audit Club/Coach activity, suspend or revoke access for non-compliance, and report safeguarding concerns to authorities.

11. Termination

This Agreement may be terminated if the Club/Coach breaches data protection rules, safeguarding concerns arise, the Club/Coach leaves the club, or the Provider updates its policies. Upon termination, all Player data must be deleted.

12. Liability

The Club/Coach is responsible for misuse of Player data, breaches caused by negligence, and failure to follow safeguarding rules. The Provider is responsible for platform security, parental consent management, and compliance with UK GDPR.

13. Governing Law

This Agreement is governed by the laws of England and Wales.