Marazion Angling Club (the
Club) - Privacy and Data Protection Policy
The Club is committed to protecting and respecting the privacy
of its members The Club uses Clubmate https://clubmate.fish to administer its membership. This requires
members/prospective members to have an email address and provide information
online. As Clubmate is the data controller, it is imperative that all members
read Clubmate’s privacy statement found here https://clubmate.fish/privacy/?v=79cba1185463 and their software will store
and process the data for the Club. The Club is responsible for ensuring the
data is used in a fair, lawful, secure and transparent way and is registered
with the Information Commissioner’s Office, as is required under UK law.
How does the Data Protection
Act 2018 affect the records kept by the Club?
The Data Protection Act 2018 controls
how your personal information is used by the organisation. Everyone responsible
for using collecting and using personal data has to follow strict rules called
the “Data Protection Principles”. They must ensure the information is:
·
Used fairly,
lawfully and transparently.
·
Used for
specified, explicit purposes.
·
Used in a way
that is adequate, relevant and limited to only what is necessary.
·
Accurate and,
where necessary, kept up to date.
·
Kept for no
longer than is necessary.
· Handled in a way that ensures security, including protection against unlawful or unauthorised processing, access, loss, destruction or damage.
Under the Data Protection Act 2018, you have the right to find out what information the organisation stores about you. These include the right to:
· Be informed about how your data is being used.
·
Access personal
data.
·
Have incorrect
data updated.
·
Have data erased.
·
Stop or restrict
the processing of your data.
·
Object to how
your data is processed in certain circumstances.
What type of information does the Club collect?
The
information you give us, via Clubmate, may include your name, date of birth,
address, e-mail address, phone number and gender. Your membership page on
Clubmate will allow you to control your personal data.
You
may also give us information about yourself by corresponding with us by
telephone, e-mail or otherwise. This includes information you provide when you
apply for membership of the Club or elect to join the Club’s membership waiting
list. The Club will not retain any personal information, this will be stored on
Clubmate, entered by yourself or a club member.
As
members will be paying for membership online, Clubmate will also require
certain financial information, which includes bank account and payment card
details. The Club has no access to this information. Clubmate uses Stripe, an
internet payment system, who are fully regulated by the Financial Conduct Authority (FCA), to transfer monies to the
Club’s bank account and to do this your financial information is shared with
Stripe. The Club receives payments from Stripe and no individual’s information
is shared in this process. Stripe’s privacy statement can be found here: stripe.com
To
protect members’ data Clubmate have in place physical, electronic and
managerial procedures to safeguard and secure data at all times. All member
information is stored and maintained with multi-layered security provided by
Microsoft Azure across physical data centres, infrastructure and operations.
And when data is transferred between the Clubmate server and the member’s
computer it uses the same SSL technology as banks and financial institutions to
ensure it remains protected. No sensitive financial information (bank details,
debit or credit card information) is ever seen, stored or transmitted by the
Club or Clubmate. This data is always held securely by their payment
partner Stripe.
The Club also uses CCTV Systems to
record images to assist in the provision of a safe and secure environment, and
for the protection of our property.
The Club, or Clubmate, will notify you
promptly in the unlikely event of any breach of your personal data which might
expose you to serious risk.
Where a member suspects a breach of data
protection has arisen, the member must immediately bring this to the attention
of the Secretary.
Why does the Club collect personal information?
The reason the Club
needs your personal data is to be able to administer your membership and
provide the membership services you are signing up to when you register with
the Club. The Club’s lawful basis for processing your personal data is that it has
a contractual obligation to you as a member to provide the services you are
registering for.
Reasons the Club needs
to process your data include:
·
Maintaining current and accurate
membership records.
- Maintenance of the Club’s membership
waiting list and issuing invitations for membership.
- Processing of membership forms,
applications and payments.
- Issuing membership cards and
associated club information.
- Circulation of Club notices and
newsletters, including membership renewal information.
- General member communications relevant
to the running of the Club, maintenance of the Club’s fisheries and
Club-related information of interest to members.
- Corresponding with an individual
member – for example in the event of a breach of Club rules.
- Analysing anonymised data to monitor
Club membership trends.
and monitoring of CCTV Systems helps the Club to:
·
maintain public safety;
·
maintain the security of its property;
·
assist in the prevention of crime;
·
reduce the fear of crime and offer reassurance; and
·
facilitate the apprehension and prosecution of offenders in relation to
crime.
·
The
Club considers the processing of personal data for these purposes to be in its
legitimate interests.
From time to time the
Club may share with members information received from third parties when such
information is considered by the Club Committee to be relevant to the interests
of the club and its members.
How does the Club store my information?
As Clubmate is the data
controller, the following is their statement on data retention:
“We will only retain
your personal data for as long as necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, accounting, or
reporting requirements.
To determine the
appropriate retention period for personal data, we consider the amount, nature,
and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other means, and the applicable legal requirements.
By law we have to keep
basic information about our customers (including Contact, Identity, Financial
and Transaction Data) for six years after they cease being customers for tax
purposes.
In some circumstances
you can ask us to delete your data.
In some circumstances
we may anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes in which case we may use this
information indefinitely without further notice to you.”
The Club will hold your personal data electronically
within the Clubmate system for as long as you are a member of Clubmate 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. The Club will
review your personal data every year to establish whether it can continue to be
processed. If the Club decides that it cannot continue to allow it to be
processed,it will stop any processing of your personal data.
Inactive Clubmate accounts (i.e. no transactions)
for at least twelve months from the date they were opened will be closed and
all personal data held within them deleted. This does not apply to accounts on
the waiting list.
CCTV Camera Locations
CCTV
cameras are located at strategic points so as to provide coverage of activity
at our facilities. Where required by
privacy laws, signage is displayed at appropriate points to alert visitors that
CCTV surveillance is in use and to provide our contact details for further
information.
Control of CCTV Access
Access
to our CCTV Systems and any associated recorded images which contain personal
information ("Recorded Materials") is controlled and is limited to
those who need to have access in accordance with this policy.
Recorded
Materials may be used by us after an incident to assist in the identification
and detection of offenders or in the investigation of a security incident.
Any
Recorded Materials will not be placed in areas easily accessible by visitors
(other than those with requisite access rights), the public or be otherwise
distributed.
We
will take reasonable precautions necessary to protect Recorded Materials from:
a.
misuse, interference and loss; and
b.
unauthorised access, modification or disclosure.
Storage of CCTV footage
CCTV
images and Recorded Materials shall not be retained for any longer than is
required for the stated purpose. Ordinarily footage is only retained for as
long as is necessary to fulfil the stated purpose. Recorded Materials will be
deleted securely and promptly once the stated purpose has been fulfilled.
Is information passed to
third parties?
As Clubmate is the data
controller, they state:
“We will only use your
personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:
· Where
we need to perform the contract, we are about to enter into or have entered
into with you.
· Where
it is necessary for our legitimate interests (or those of a third party) and
your interests and fundamental rights do not override those interests.
· Where
we need to comply with a legal or regulatory obligation.
· Generally,
we do not rely on consent as a legal basis for processing your personal data
other than in relation to sending third party direct marketing communications
to you via email or text message. You have the right to withdraw consent to
marketing at any time by contacting us.”
Further information can
be found in Clubmates’ privacy statement (link above).
Your details may also
be passed via Clubmate, to Mailchimp, whose privacy policies can be found at Mailchimp Data Security and Privacy | Mailchimp, in order to send you membership related communications including
newsletters and club notices.
The
Club will not supply any personal data held on Clubmate to any third party for dissemination or sale to external parties for
marketing or any other commercial purposes.
Disclosure
of CCTV Recorded Materials will only be provided to third parties for the
purposes outlined above and in compliance with applicable data privacy laws.
The
police may require or be provided with access to any of the Club’s CCTV Systems
under the following circumstances;
·
emergencies or investigation of serious incidents;
·
identification of offenders; or
·
at our request (in accordance with this policy).
Match/Event results/records
The
Club will process any personal data collected for the purposes of any club
match in line with the club’s privacy/data protection policy. Where a person
participating in any club activity is not a paid-up member of the Club, the
persons explicit consent will be obtained from the person prior to the
individual’s personal information being used in relation to the promotion or
publicity of any such club match/event.
How to find out what data the
Club holds about you
As Clubmate is the data
controller, the following is their statement on data retention:
“Under certain
circumstances, you have rights under data protection laws in relation to your
personal data.
Request access to your
personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise
any of the rights set out above, please contact Clubmate.”
On
your personal page on Clubmate, you can modify your personal data at any time
and change your marketing preferences. As a data subject you are not obliged to
share your personal data with the Club, via Clubmate. However, if you choose
not to share your personal data with us, the Club may not be able to register
or administer your membership.
Members who choose not to access their own data through the member portal of
Clubmate, or require data not held by Clubmate, can request either verbally or
in writing to access their data and must be responded to within one month of
the request. All requests will be directed to the Secretary who will respond
within the timescale. A record will be kept for management purposes of each
request received.
As a data subject you
may have the right at any time to complain to the UK’s data protection
supervisory authority, the Information Commissioner’s Office about the
processing of your personal data.
You have the right to have your personal data erased
in certain circumstances (please note that if you elect to have your personal
data erased this will immediately terminate your membership at no cost to the
Club).
The Club reserves the
right to amend this Data Privacy Policy from time to time without prior notice.
You are advised to check our website or your Clubmate page regularly for any
amendments (but amendments will not be made retrospectively).
How to make a complaint
If
you think your data has been misused or has not been kept secure, please
contact the Club Secretary in the first instance. If you are not happy with the
response provided, please contact the Information Commissioners Office (ICO):
Information
Commissioners Office
Wycliffe
House Water Lane
Wilmslow
Cheshire
SK9
5AF
0303
123 1113