Update* 22nd May 2020
Update* 3rd June 2020 - We have now spoken to the ICO, who have confirmed our interpretation below is correct!
In response to the email sent to all league administrators by Table Tennis England today.
The GDPR statements, when taken in context with the rest of the letter read as if returning to TT365 would in some way put a league in breach of data protection law. Before
making our proposal we considered the implications of GDPR on all parties and followed official guidelines on the Information Commissioner’s Office website (the same resource
Table Tennis England refer to in the letter) and we determined that there would be no reason a league cannot move back to TT365 and bring their data with them.
We will now qualify our position, referencing quotes from their communication and the ICO website.
data from our membership platform (TT Memberships) and our league management platform (TT Leagues) cannot be shared with other league providers.
Table Tennis England
The word 'shared' in the context they are using it would assert the data will be used by the third party for their own purposes.
When your league last used TT365, there was a data protection agreement in place, where it defined your league as a data controller and TT365 as a data processor. Please see the official guidelines on the ICO website, that lists the key definitions that form our position.
If you don’t have any purpose of your own for processing the data and you only act on a client’s instructions, you are likely to be a processor – even if you make some technical decisions about how you process the data.
Information Commissioner’s Office website
A data processor has no rights to use the data for their own purposes, it merely stores and processes that data in accordance with GDPR on your behalf. So, to say you would be sharing that data with TT365 is a poor choice of words, you are merely entrusting us to hold it and process it on your behalf.
downloading data from TT Leagues or TT Memberships to provide to third parties would be a breach of the General Data Protection Regulations (GDPR).
Table Tennis England
This statement entirely depends on the purpose under which you provide the data, but as you are providing it to TT365 for the purpose of processing and governed by a data protection agreement to that effect, it should not apply.
It is your responsibility to ensure that all individuals within those leagues have given permission for their data to be shared with any third parties.
Table Tennis England
You should have a clause in your league rules or tick box on the registration form, that requires the player to give consent to your league to hold their data, for the purpose of running the league. When you used TT365 there was a data protection agreement in place between you and Table Tennis England, and it was called a data controllers-in-common agreement, which loosely translates to joint ownership. If you read the official guidelines and refer to joint-controllers, you can see that this is the most appropriate definition of your relationship with Table tennis England, in the context of personal member data. On the basis that you are a joint-controller, you have every right to take your data and put it into any GDPR compliant 3rd party system for a 'permitted purpose'. FYI: TT365 is fully GDPR compliant.
When you import your data into TT365 you are not sharing (giving it to us to use freely) it with us, you are just moving it to a different platform. If GDPR prevented
organisations from moving their data to different service providers everyone would be stuck with the provider they were using when GDPR came into force.
Some common-sense must be applied here.
While recognising that other league management platforms are available and leagues are free to use them, TT Leagues will remain the only platform with links into the TT Memberships system.
Table Tennis England
They point out that TT Leagues is the only system that will be able to link to the TTE membership system. This is not a technical limitation, this is a choice. They do say you are free to use any system you like but clearly they don't want you to and they are going to use every means that their disposal to force you to stay.
We are extremely disappointed in Table Tennis England, who should know all of the above and not require us to educate them, at minimum they should have sought advice on the exact position before sending such an influencing letter to every league administrator in the country.
We should expect and demand a higher standard from our governing body and we now challenge them to prove our position wrong and if they cannot do so, formally retract their statement and set the record straight with everyone.
The founder of Table Tennis 365.
Table Tennis 365 to become free to all
League Manager, including its membership, email and ranking functionality will become free to all UK leagues and clubs, in perpetuity, as of 1st August 2020.
Leagues that migrated to TT Leagues can come back to the TT365 family and benefit from the full functionality of our sophisticated software easily. Do not worry about the results from last season; we have already extracted all your data from TT Leagues and it is ready to import into TT365, with zero work from you; it will be like you never left.
Membership management within TT365 has been updated to provide an import/export feature which consumes the Sport 80 membership data export. You will be able to use League Manager with up to date membership data, meaning no more manual checks on player eligibility.
Your league or club can benefit financially from some of the adverts that are displayed on your website, because as of next season every sale made with TeesSport that originates from your website will earn you 5% commission. We calculate that for an average sized league this could be worth several hundred pounds per season.
Our first-class support service will ensure a smooth and painless start to next season and our commitment to be the best table tennis focused league management system has not waivered.
You now have a real free choice… We are the original and we believe we are still the best.
We encourage you to debate your options with your players and within your committees. You are welcome to confirm your commitment to use TT365 next season at any time, however, we are offering a £100 TeesSport voucher to the first 20 leagues that confirm their commitment to use TT365 as their primary website next season.
Is it really free?
Yes, the players pay nothing, the leagues pay nothing, and Table Tennis England contribute nothing. It is completely free! We are making a guarantee that it will remain free for the next 3 years, but it is our goal that it will remain free forever, all we need to make that happen is for you to use it.
How can you make this offer now?
We operated League Manager very successfully last season for over 50 leagues and what we found was that support usage was significantly lower than we expected. We now believe that maintaining our service to Table Tennis England used a disproportionate amount of our time and once removed we were able to continue to function on significantly less resource.
We also made some significant changes to our staffing and services procurement, which saved us a very significant percentage of our total annual expenditure.
Finally, we invested time and resource in to finding and building new revenue streams that will come online next season.
Is your offer sustainable?
Yes, we have changed our business model (for the better). We are no longer reliant on one single large client, instead (for the first time ever) income from different streams offers us a sustainable and robust future.
League Manager is still a flagship product, but we now see it as more of a lost leader, to ensure the TT365 brand remains strong and valued within the table tennis community.
Will you still be improving the Table Tennis 365 League Management platform?
Yes, however one lesson we have learned from the last 12 months is that for many leagues, what we already have exceeds their needs. So rather than continuing to tweak and make small minor changes, we will look for true innovation and where we find need, we will continue to invest in building world class IT systems for you to use.
How will the results from TT Leagues get into TT365?
We will do this for you once you have given us your commitment. We just ask you to confirm the final tables and averages are accurate before we archive them. We will be importing all results data, including fixture history and match cards, meaning all player archives and rankings will also be updated.
How will the TeesSport commission agreement work?
If you decide to take part, you will be required to complete a simple form that provides TeesSport with the basic information they will need to administer the scheme. Once TeesSport confirm you have been accepted, we will activate the appropriate facility on TT365, which will add a small graphic to your website that links through to a new page explaining how the scheme works, why it is beneficial for players to purchase via your site and finally a link to click. When a player clicks through some clever stuff takes place between TT365 & TeesSport and player purchases are attributed to your TeesSport account. There are zero privacy concerns as no data is shared back to TT365. At the end of the season TeesSport will deliver you a report that details the total spend by your site visitors and arrange a payment.
The scheme is free to join and requires an absolute minimum of work to set up. Once set up your only real task is to promote the use of the scheme to your players, so that you can benefit from each purchase. “Add up the cost of a couple of sheets of rubber, a dozen balls and maybe a new shirt, then multiply that by a couple of dozen players and work out your 5% commission. The commision very quickly adds up to a useful amount”. For clarity, we have been assured by TeesSport that the price paid by the player is in no way inflated, so there is no downside to the player purchasing via your website.
Free voucher offer.
We will give the first 20 leagues that commit to next season a £100 voucher for TeesSport: no strings attached. The voucher is subject to TeesSport terms and conditions. The voucher will be paid out towards the end of your season.
How will membership management work next season?
Table Tennis 365 is not linked with any TTE systems. However, the Sport 80 platform provides an export function that includes all the pertinent information about your members, including their TTE payment status. Our membership system provides a very simple way to import that file and bring your previous membership database up to date. An initial import will bring the 2 systems in sync with each other, and there is no limit on the number of times you can perform the import during the season. If TTE ever offer us the opportunity to link directly with Sport 80, then we can remove the need for importing the file, but in practice, it is very simple to do and takes less than a minute. Once done, you can use TT365 as you previously did.
What's the bottom line?
We are truly grateful to those leagues who stuck with us last season. It gave us the time we needed to re-think our business model and come up with this new offer. Thank you.
To those leagues that moved away (for many where it was not your preference), you can come back, if you want to. You won't lose this seasons data and going forward the debate over cost is nullified. We promise the move back will be painless.
For all leagues... You have a choice to make... You can evaluate all your options without cost being a factor. We fully expect many leagues to return, so if you want that £100 voucher, best get cracking.
Once again my most grateful thanks to all those leagues that stood by us.
The founder of Table Tennis 365.