Please send us questions at privacy@gaisf.sport and we will answer them on this page


How to respond to an access request ?

Detailed guidelines on how to handle an access request have been drafted for GAISF members by Kellerhals Carrads lawfirm. Click here to download the Memorandum

A template letter to answer an access request has also been drafted.  Click here to download the template letter


As a sport organisation, do I need to hire a DPO ?

Art. 37 of the GDPR require the designation of a DPO in three specific cases

  • where the processing is carried out by a public authority or body;
  • where the core activities of the controller or the processor consist of processing operations, which require regular and systematic monitoring of data subjects on a large scale; or
  • where the core activities of the controller or the processor consist of processing on a large scale of special categories of data7 or8 personal data relating to criminal convictions and offences.9

Various elements of this article haven’t been precisely defined: “large scale”, “systematic monitoring”, …
The EU Working Party produced guideline to help in the interpretation of Art 37 .  Click here to download guidelines.

Two principles of these guidelines are specifically relevant :

  • Even when it is not certain that a DPO is mandatory, the WP recommends to hire a DPO
  • Unless it is obvious that an organisation is not required to designate a DPO, the WP29 recommends that controllers and processors document the internal analysis carried out to determine whether or not a DPO is to be appointed, in order to be able to demonstrate that the relevant factors have been taken into account properly.


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