Connaught Club’s Privacy Notice for members

1. What is the purpose of this document?

1.1 The Connaught Club (the Club) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being provided with a copy of this privacy notice because you are applying for membership of the Club. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment and contracting exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

 

2. Data protection principles

2.1 We will comply with data protection law and principles, which means that your data will be:

(a) Used lawfully, fairly and in a transparent way.

(b) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

(c) Relevant to the purposes we have told you about and limited only to those purposes.

(d) Accurate and kept up to date.

(e) Kept only as long as necessary for the purposes we have told you about.

(f) Kept securely.

 

3. The kind of information we hold about you

3.1 In connection with your membership application, we will collect, store, and use the following categories of personal information about you:

(a) The information you have provided on our application forms, including name, title, address, telephone number, personal email address, and date of birth.

(b) Your bank account details.

3.2 We may also collect, store and use the following “special categories” of more sensitive personal information (see below), specifically:

(a) information about your health, including any dietary requirements.

 

4. How is your personal information collected?

4.1 We may collect personal information about candidates from the following sources:

(a) You.

(b) From third parties who are, for example, your lodge secretary or central database.

 

5. How we will use information about you

5.1 We need all the categories of information in the list above primarily to allow us to source roles for you, perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

(a) Checking you are eligible to join the club.

(b) Contacting you to ensure membership is paid and contacting you via our mailing list.

(c) Updating our central database to record membership.

(d) Business management and planning, including accounting and auditing.

(e) Making decisions about your continued engagement.

(f) Making arrangements for the termination of your membership.

(g) Complying with health and safety obligation.

(h) To prevent fraud.

(i) Education, training and development requirements.

(k) To conduct data analytics.

5.2 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

 

6. If you fail to provide personal information

6.1 If you fail to provide information when requested, which is necessary for us to consider your application, we will not be able to process your application successfully.

 

7. Change of purpose

7.1 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

7.2 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

8. How we use particularly sensitive personal information

8.1 “Special categories” of particularly sensitive personal information require higher levels of protection. We have put in place appropriate safeguards which we are required by law to maintain when processing such data however we need to have further justification for collecting, storing and using this type of personal information. With this in mind we may process special categories of personal information in the following circumstances:

(a) In limited circumstances, with your explicit written consent.

(b) Where we need to carry out our legal obligations or exercise rights in connection with employment laws.

(c) Where it is needed in the public interest.

8.2 Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about candidates or former candidates in the course of legitimate business activities with the appropriate safeguards.

8.3 We will use your particularly sensitive personal information in the following ways:

(a) We will use information about your health, namely dietary requirements, to consider whether we need to provide appropriate adjustments to dining, for example whether adjustments need to be made.

 

9. Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

 

10. Automated decision-making

10.1 You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

 

11. Data sharing

11.1 We may have to share your data with third parties. We require these third parties to respect the security of your data and to treat it in accordance with the law.

 

12. Why might you share my personal information with third parties?

12.1 We will only share your personal information with the third parties for the purposes of arranging events, dining arrangements and verifying your eligibility to join the Club.

12.2 The “third parties” referred to above also includes third-party service providers (including contractors and designated agents). All our third-party service providers and other entities to whom we provide your data are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

13. Data security

13.1 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

13.2 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

14. Data retention

14.1 We will retain your personal information for a period of 1 years from the date:

  • of termination of your membership.

14.2 After this period, unless separately legally required to retain the information, we will securely destroy your personal information in accordance with our data retention policy and the applicable laws and regulations.

14.3 If we wish to retain your personal information on file for a period beyond the above, we will write to you separately, seeking your explicit consent to retain your personal information for a further fixed period on that basis. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

 

15. Rights of access, correction, erasure, and restriction

15.1 Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

(a) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

(b) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

(c) Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

(d) Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

(e) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

(f) Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our data protection officer (DPO) in writing as set out below.

15.2 Right to withdraw consent

When you apply for membership of the Club, you provide consent to us processing your sensitive personal information for the purposes membership. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact our DPO as set out below. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

 

16. Data protection officer

16.1 We have not appointed a data protection officer (DPO). If you have any questions about this privacy notice or how we handle your personal information, please contact Jack Thornborough by email on secretary@connaughtclub.org. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

 

Version Control

Version Number Who / Date Amendment
1.0 24 May 2018 Jack Thornborough