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UK GDPR & ICO Children’s Code Certified

Privacy & Biometric Telemetry Policy

Scout11 treats athletic data with the highest clinical and statutory privacy standards. This policy explains how we collect, process, and secure athlete performance metrics, video match recordings, and GPS telemetry under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Data Controller: Scout11 Ltd • ICO Registration: ZB883902

01.Categories of Personal & Athletic Data We Process

In providing high-performance scouting software, we process specific categories of data tailored to athlete recruitment:

Biometric & Physical Telemetry

Top sprint velocity (km/h), high-speed running distance, heart rate deciles, VO2 max estimates, force plate jump kinetics, height, weight, and dominant foot orientation.

Video Footages & Optical Tracking

Broadcast match replays, Veo panoramic pitch footage, Hudl highlight clips, timestamp markers, and tactical scout event tags (passes, shots, defensive recoveries).

Scouting Dossier Observations

Scout evaluation notes, technical ratings (1-10 scale), recruitment shortlist tags, and Academy talent identification reports.

Safeguarding & Verification

Date of birth, parental/guardian emergency contact information, FA DBS verification status, and clinical/medical specialist licensing certificates.

02.Lawful Basis & Special Category Data (UK GDPR Article 9)

Under UK GDPR Article 9, biometric and health data (including continuous GPS cardiac and fatigue telemetry) constitutes Special Category Data. We process this data strictly on the basis of:

  • Explicit Consent (Article 9(2)(a)): Provided by adult athletes or the registered legal guardian of minor athletes at account onboarding.
  • Legitimate Interests & Contract Performance: Facilitating professional athletic evaluations, combine trial nominations, and injury rehabilitation programming.
  • Substantial Public Interest (Safeguarding): Ensuring minor protection and welfare compliance under Schedule 1 of the Data Protection Act 2018.

03.Compliance with the ICO Children's Code (Age-Appropriate Design)

Scout11 adheres strictly to the 15 standards of the Information Commissioner’s Office (ICO) Age-Appropriate Design Code:

  • High Privacy Defaults: Minor athlete profiles are shielded from public search engines. Only verified, DBS-checked club scouts can inspect dossiers.
  • Zero Geolocation Tracking: Live geolocation is disabled. GPS telemetry is imported post-match from wearable hardware and stripped of exact real-time coordinates.
  • Nudge Technique Prohibition: We never employ manipulative behavioral nudges to encourage excessive screen time or unchaperoned communication.

04.Data Retention, Storage Security & Encryption

All platform databases are hosted in ISO 27001-certified UK data centres (London Region). Data in transit is encrypted using TLS 1.3, and data at rest is secured via AES-256 encryption. Telemetry records are retained for the duration of the athlete’s active representation lifecycle and securely expunged upon account termination.

05.Your Statutory Rights (Access, Portability & Erasure)

Under UK data protection laws, athletes and legal guardians have the right to:

  • Request a complete copy of all scout notes, ratings, and biometric telemetry files (Right of Subject Access).
  • Export performance outputs in standardized machine-readable formats (JSON / CSV) for transfer to another club or training academy (Data Portability).
  • Request immediate permanent deletion of profile dossiers and match clips (Right to Erasure / Right to be Forgotten).

To exercise these statutory rights, submit a request to our Data Protection Officer at dpo@scout11.co.uk.

Scout11 Data Protection Office • London, UKRead Safeguarding Framework →