Rotary Club of Bishops Stortford Privacy Notice

Welcome to the Rotary Club of Bishop's Stortford’s Privacy Notice.
 
We respect data privacy and are committed to protecting individuals’ personal data, and in keeping with our commitment to Rotary principles and practices. In particular, we respect the confidentiality of any personal information you share with us.
 
This Privacy Notice tells you how we collect, look after and use your personal data provided to us and tells you about your privacy rights and how the law protects you.   This version was last updated in May 2018.
 
We confirm that  we seek to adhere to the the Privacy Notice of Rotary International in Great Britain and Ireland (RIBI) in relation to those sections of that Notice applicable to our Club. 
 
The Glossary below may assist you to understand the meaning of some of the terms used in this Privacy Notice.
 
1.  IMPORTANT INFORMATION AND WHO WE ARE 
 
CONTROLLER 
 
We are a data controller for the purpose of the General Data Protection Regulation(GDPR) and Data Protection Act 2018 (DPA 2018) and are responsible for personal data.
 
If you have any questions about this, please contact us on robert.whitaker@teeslaw.co.uk
  
PLEASE KEEP US UPDATED ABOUT YOUR DETAILS
 
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes, including, in particular, your address, telephone number(s) and email address.
 
2.  THE DATA WE COLLECT ABOUT YOU 
 
For the purposes of this privacy notice personal data, or personal information, means any information about an individual from which that person can be identified.
It does not include data where the identity has been removed (anonymous data).
 
We may collect, store, use, and and (from time to time), transfer different kinds of personal data about you which we have grouped together as follows:
 
• Identity Data which can includes all or any of the following, namely your full name, marital status, title, date of birth and gender. 
 
• Contact Data which can includes email and postal addresses and telephone numbers.
We do not envisage we will collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In the event that we process any special category data we will do so in circumsatnces where it this is lawful and in accordance with the requirements of the GDPR.
 
Interact, Rotakids and under 18’s data
 
We do not collect information from under 18’s.
 
Our Interact Clubs are managed through the identified Rotarian member contact, currently Rotarian Richard Hartley.
 
3.  HOW IS YOUR PERSONAL DATA COLLECTED? 
 
We use different methods to collect data from and about you including through Direct interactions - You may give us your Identity and Contact Data by telephone, email or otherwise.
 
4.  HOW WE USE YOUR PERSONAL DATA 
 
We will only use your personal data when the law allows us so to do. Most commonly, we will use your personal data in the following circumstances:
 
• 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. The exception to this is Rotary members’ spouses and partners whose names and contact details we will publish in our Rotary materials from time to time, in particular membership cards and handbook. We will seek non-members’ consent to do so.
 
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 
 
The main purposes for collecting, storing and using your data is in order to keep in touch with you and to enable members of our Club (and their spouses and partners) to keep in touch with each other.
 
OPTING OUT 
 
Please contact us if you wish to opt out of any messages or messages in relation to particular iniitiatives activities or subjects at any time.
 
CHANGE OF PURPOSE 
 
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
 
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us so to do so.
 
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 
5.  DISCLOSURES OF YOUR PERSONAL DATA 
 
Subject to the below we do not envisage many occasions (if any) when we would need to share your data with third parties. If we need to share your information with third parties we will require those third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow any third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
 
Data Sharing
 
Our service/host providers
 
In the course of our legitimate activities, we may share, or give access to, your personal data to third parties that enable us to provide our avenues of service or host our applications/software that you may access, for instance:
 
• Banking organisations – those that provide our banking/payment services
• MailChimp
• The Rotary organization, comprising:  Rotary International, The Rotary Foundation (TRF), Rotary International in Great Britain and Ireland, the Rotary Foundation United Kingdom (RFUK) and the RIBI Donations Trust
• In the course of the Club's relationship with third parties, e.g. schools, golf day supporters, charitable causes.
 
We will ensure that data processing agreements, compliant to GDPR, are in place before sharing with any third party, as appropriate.
 
We also refer you to the RIBI’s Privacy Notice regarding data sharing.
 
6.  DATA SECURITY 
 
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
 
In addition, we limit access to your personal data to  other members of our Club and selected third parties such as local schools and charitable bodies on a need to know basis. They are in turn subject to a duty of confidentiality and obligations under the GDPR and DPA 2018.
 
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 
As a Club member you have a responsibility to support the Club’s commitment to data privacy. If you believe that there has been a data breach in relation to your personal data or that of a third party, please inform Robert Whitaker of the Club without undue delay.
 
Please be aware that communications over the internet, including via email, are not secure unless they have been encrypted. 
 
7.  DATA RETENTION 
 
HOW LONG WILL YOU USE MY PERSONAL DATA FOR? 
 
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it 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.
 
Details of retention periods for different aspects of your personal data are available upon request from us.
 
8.  YOUR LEGAL RIGHTS 
 
Under certain circumstances, you have rights under data protection laws in relation to your personal data (see also our glossary, below).
 
If you wish to exercise any of these rights, please contact robert.whitaker@teeslaw.co.uk
 
NO FEE USUALLY REQUIRED 
 
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
 
WHAT WE MAY NEED FROM YOU 
 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 
TIME LIMIT TO RESPOND 
 
We try to respond to all legitimate requests within 28 days. Occasionally it may take us longer than this if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
 
CONTACT DETAILS 
  
Email address: robert.whitaker@teeslaw.co.uk
 
Postal address: Parkview House, Victoria Road South, Chelmsford, Essex, CM1 1NG
 
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 (www.ico.org.uk). We would, however,appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
 
10.  GLOSSARY 
 
LAWFUL BASIS 
 
Legitimate Interest means our interest in conducting and managing our affairs to enable us to maintain contact with all members of our Club, to enable members to contact each other and to deliver our avenues of service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us robert.whitaker@teeslaw.co.uk 
 
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
 
YOUR LEGAL RIGHTS 
 
You have the right to:
 
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
 
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
 
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with the law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
 
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
 
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
 
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.
 
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to keep in touch with you.  We will advise you if this is the case at the time you withdraw your consent.

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