Privacy Policy
Last updated: February 2026
GrappleTrust is registered with the Information Commissioner's Office (ICO). We take your privacy seriously, especially given the sensitive nature of safeguarding data.
What Data We Collect
Safeguarding Reports
When you submit a safeguarding report, we collect:
- Your email address (required, used for status updates)
- Your phone number (optional)
- Your name (optional)
- The details of your report, including category, summary, and full description
- Whether the report involves a person under 18
Safeguarding Officer Accounts
When you register as a Safeguarding Officer, we collect:
- Your name and email address
- Your club affiliation
- Proof of safeguarding training (uploaded document)
Club Registration
When a club registers interest, we collect:
- Contact name and email address
- Club name and town/city
- Phone number (optional)
Technical Data
We use session cookies to keep you logged in. We do not use analytics cookies or third-party tracking.
Why We Process Your Data
We process personal data for the following purposes:
- Safeguarding reports: To receive, manage, and respond to safeguarding concerns in grappling and combat sports clubs. Our lawful basis is substantial public interest (safeguarding of children and individuals at risk) and legitimate interests.
- SO accounts: To verify and manage Safeguarding Officers who handle reports. Our lawful basis is legitimate interests and consent.
- Club registrations: To process requests from clubs wishing to join GrappleTrust. Our lawful basis is consent.
Who Has Access to Your Data
- Safeguarding reports are only visible to the assigned Safeguarding Officer (who will always be from a different club to ensure independence) and GrappleTrust administrators.
- Report summaries (without full details) are visible to approved Safeguarding Officers when selecting reports to handle.
- Your contact details are shared with the assigned Safeguarding Officer so they can follow up with you.
- We do not sell or share your data with any third parties for marketing purposes.
How We Store Your Data
Your data is stored securely in an encrypted database. Uploaded documents are stored in a restricted area of our server. Access is limited to authorised personnel only.
How Long We Keep Your Data
- Safeguarding reports: Retained in line with safeguarding best practice. Records may need to be kept for an extended period as safeguarding concerns can be relevant to future investigations.
- SO accounts: Retained for as long as the account is active. Data is removed upon request if the account is no longer needed.
- Club registrations: Pending registrations are kept until processed (accepted or rejected). Contact details for rejected applications are deleted within 30 days.
Your Rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you
- Rectification of inaccurate data
- Erasure of your data (subject to safeguarding retention requirements)
- Restrict processing in certain circumstances
- Object to processing based on legitimate interests
- Data portability of data you provided to us
Please note that safeguarding records may be exempt from erasure requests where retention is necessary for the protection of children or vulnerable adults.
Subject Access Requests and Safeguarding Reports
If a safeguarding report names or relates to you, that report contains your personal data. However, if you submit a Subject Access Request under UK GDPR Article 15, we may need to withhold or redact report content. UK GDPR allows restrictions on access rights where provided for by UK law, and the Data Protection Act 2018 sets out the following relevant exemptions:
- Where disclosure would reveal the personal data of another individual, such as the person who made the report (DPA 2018, Schedule 2, Part 3, Paragraphs 16-17)
- Where disclosure would prejudice the safeguarding of children or individuals at risk (DPA 2018, Schedule 2, Part 1, Paragraph 4)
- Where disclosure would prejudice the prevention or detection of crime
We will always acknowledge that we hold data about you and provide what we reasonably can, but the safety of reporters and the integrity of safeguarding processes take priority.
Contact Us
To exercise your rights or if you have any questions about how we handle your data, please contact us at:
Email: grappletrust@protonmail.com
Complaints
If you are unhappy with how we have handled your data, you have the right to complain to the Information Commissioner's Office (ICO):