Important: This is general information, not legal advice or a determination that any club or person is compliant. Check current legislation and your governing body's rules.
Short answer: assess total responsibility, not just subscription price. An internal system gives the club control, but the club must design, secure, maintain, document and hand over that system. A purpose-built service can supply workflow and maintenance, but the club still retains its own safeguarding and data-controller responsibilities.
Questions for an internal build
- Who owns the requirements and updates them when NGB policy changes?
- How are individual access, authentication, backups and security testing handled?
- Can changes and verification decisions be reconstructed?
- Who maintains it when the volunteer who built it leaves?
- How will retention, corrections, exports and deletion be managed?
Questions for a supplier
- Does the contract clearly divide controller and processor responsibilities?
- Does the feature set match the club's documented process?
- What data should not be uploaded?
- How does the club retrieve its data and remove access?
- Does the supplier make unsupported claims of legal compliance?
The DPC recommends that organisations inventory their data, assess risk and evaluate processors' security. ClearCheck's terms state that the club remains the controller for roster and compliance records and remains responsible for its legal and safeguarding decisions.
Official and primary sources
- Data Protection Commission — Data Security Guidance
- Data Protection Commission — Guidance for SMEs
- Data Protection Commission — Accountability
- ClearCheck — Terms of Service
- ClearCheck — Data Processing Agreement
Sources were accessed and checked on 12 August 2026.