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February 2019

Do Your Customers Need Some Privacy?

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By Jared Williams
Managing Director, GOLF USA TEE TIME COALITION

One thing I hear very often when talking about best practices for working with third parties involves making sure you collect customer data of your golfers, regardless of the channel through which they booked the reservation. I get it. It makes sense. We all have heard the hackneyed (yet completely accurate) phrases:

Take back control of your tee sheet.

They’re at your facility and it’s your job to make sure those working the counter collect the email addresses and all relevant contact information on those golfers.

Data is king.
It’s a tried and true best practice that we must do a good job of collecting customer data. But one thing we may be glossing over is what we need to do after collecting the customer data to ensure that we protect our customers’ sensitive information.

Yes, one best practice begets another. Golf courses (and any business for that matter) in the business of collecting customer data, should have a privacy policy. A privacy policy is a legal document or notice that discloses a website owner’s practices for collecting, using, maintaining, protecting and/or disclosing the information it gathers through its website from website visitors, users and customers.

Golf course owners and operators, more often than not, are collecting personal information of customers through POS systems and tee sheets and your policy needs to be displayed digitally and/or in front of your counter. Wherever you are collecting customer information, you need to make your customer aware of your intended use for it and promise to protect their information.

The Federal Trade Commission (FTC) recognizes that security breaches sometimes still happen even when a company has taken reasonable precautions like enacting a comprehensive privacy policy. However, the FTC takes the position that if a company’s privacy policy includes statements regarding the company’s information sharing practices, it must comply with them. This includes situations where the privacy policy states that the company will not rent, sell or otherwise disclose personal information to third parties.

HOW TO MANAGE CUSTOMER DATA WHEN DEALING WITH VENDORS:

Make sure you request a copy of any vendor’s privacy policy prior to entering into any agreement with them.

Review their policy and make sure you understand its terms. You need to know what third parties intend to do with your customer’s information.

Include any pertinent parts of your vendor’s privacy policy in your own privacy policy.

Make sure that customers know what your third-party vendors may be doing with their sensitive information as well.

Limit the amount of vendor access given to your customer data to what they need to know in order to perform their service, if possible.

We’re always interested in hearing your thoughts on issues involving the marketing and distribution of tee times. What do you see as the solution here? Do you have a privacy policy? Do your vendors have one? Do they mirror each other? Are any of these policies made available and/or visible to your customers? I want to hear from you, contact me at jwilliams@teetimecoalition.org.

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