1. About this Policy
1.1 This policy explains when and why we collect personal information about our members, how we use it and how we keep it secure and your rights in relation to it.
1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner's Office. (https://ico.org.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
2. Who are we?
2.1 We are Leeds & Harrogate IVC. We can be contacted at firstname.lastname@example.org or email@example.com.
3. What information we collect and why.
|Type of information||Purposes||Legal basis of processing|
|Member's name, address, telephone numbers, e-mail address(es).||Managing the Member’s membership of the Club. The Host contact details for IVC Events||Performing the Club’s contract with the Member. For the purposes of our legitimate interests in operating the Club.|
|Member's name, address, telephone numbers, e-mail address(es).||For one member e.g. an event organiser, to contact another member||To organise events. The member inquired about will be contacted for consent to pass contact details to another member.|
|Emergency contact details||Contacting next of kin in the event of emergency.||Protecting the Member’s vital interests and those of their dependants and / or next of kin|
|Numbers of membership||Reporting information to the AIVC.||For the purposes of the legitimate interests of the AIVC to satisfy diversity compliance required by law.|
|Photos and videos of Members||Putting on the Club’s website and social media pages and using in press releases.||Consent. People appearing on a photo or video will be asked to give consent before the photo or video is used. Permission can be withdrawn at any time.|
|The Member’s name and e-mail address, whilst a current member and for up to a year after ceasing to be a member of the Club||Passing to the AIVC for the AIVC levies and to conduct surveys of Members and former members of the Club. See paragraph 5.3 below.||For the purposes of our legitimate interests in operating the Club and / or the legitimate interests of the AIVC in its capacity as the national body|
|First name and surname initial, committee position e-mail address and telephone number of each Club Officer||Information published on Club’s website, in Club’s newsletter and other publications, in the Club’s marketing materials and made available to the AIVC, in each case as a point of contact at the Club||For the purposes of our legitimate interests in operating and promoting the Club.|
|First name and surname initial, committee position e-mail address and telephone number of each Club Officer||Information published on Club’s website||For the purposes of our legitimate interests in operating and promoting the Club|
4. How we protect your personal data
4.1 We will not transfer your personal data outside the EU without your consent BUT we will inform you if the Club’s hosted services, website and/or email server are outside of the EU and therefore your data is held outside of the EU.
4.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
4.3 Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
4.4 For any payments, which we take from you online, we will use a recognised online secure payment system.
4.5 We will notify you promptly in the event of any breach of your personal data, which might expose you to serious risk.
5. Who else has access to the information you provide us?
5.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where we are required to do so by law or as set out in the table above or in paragraphs 5.2 and 5.3 below.
5.2 We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). We do this for the purpose of our legitimate interests in operating the Club and for performing our contract with you. However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. It is possible that third parties may themselves engage others (sub-processors) to process your data. Where this is the case, third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own purposes.
5.3 We may also pass your personal data to the AIVC for the purposes of carrying out surveys when it is in the legitimate interest of the club and the AIVC to do so. The AIVC may use third parties to carry out the surveys but disclose only the personal data that is necessary for the third party to do so and will have a contract in place that require the third party to keep your information secure and not to use it for their own purposes.
6. How long do we keep your information?
6.1 We will hold your personal data on our systems for as long as you are a member of the Club and for as long afterwards as it is in the Clubs’ legitimate interest to do so or for as long as is
necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data
6.2 We will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
6.3 We will securely destroy all personal financial information (banking details) once we have finished using it and no longer need it.
7. Your rights
7.1 You have rights under the GDPR:
- (a) To access your personal data.
- (b) To be provided with information about how your personal data is processed.
- (c) To have your personal data corrected.
- (d) To have your personal data erased in certain circumstances.
- (e) To object to or restrict how your personal data is processed.
- (f) To have your personal data transferred to yourself or to another business in certain circumstances.
7.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner's Office.
- Web: https://ico.org.uk/concerns/
- Tel: 0303 123 1113.
- Information Commissioner's Office
- Wycliffe House
- Cheshire SK9 5AF
For more details, please address any questions, comments and requests regarding our data processing practices to our membership secretary or club secretary (firstname.lastname@example.org or email@example.com)