Bassenthwaite Rotary Privacy Notice

DATA PROTECTION POLICY

INTRODUCTION

This Policy (“Policy”) sets out the 9 Data Protection Principles which the BASSENTHWAITE ROTARY CLUB (“Club”) commit to comply with when processing personal data in the course of its activities as a Rotary Club.  The Club may be contacted via the Secretary – Bassenthwaite Rotary, Chapels Hill, Greysouthen, Cockermouth CA13 0UF, email [bass.rotary@btinternet.com].

Other organisations having control of personal data jointly with the Club are Rotary District 1190, Rotary International in Great Britain and Ireland [RIBI General Secretary, Kinwarton Road, Alcester. B49 6PB, Tel: 01789 765411 Email: secretary@rotarygbi.org] (‘RIBI’) and Rotary International [contact.center@rotary.org] (‘RI’).  RI is based in the United States of America.

The Appendix contains a Glossary of the defined terms in this Policy.

COMPLIANCE WITH THIS POLICY

The Club will ensure the protection of personal data in accordance with this Policy by the Club and Suppliers.

A breach of data protection laws by the Club or any Supplier could result not only in monetary penalties awarded against the Club but also negative publicity which could affect the Club as well as the entire Rotary movement.

THE DATA PROTECTION PRINCIPLES

The Club shall comply with the following 9 Data Protection Principles when processing personal data.

The Club must provide a privacy notice to each Club member and Supplier to inform them of:

·         the identity of the Club as data controller;

·         the purposes for which their personal data are processed;

·         the legal basis for processing;

·         any legitimate interests pursued by the Club or a third party, if applicable;

·         the recipients or categories of recipients of the personal data, if any;

·       where applicable, the fact that the Club intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the relevant authority, or reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available;

·       the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;

·     the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;

·         the existence of the right to withdraw consent at any time, if applicable;

·         the right to lodge a complaint with a supervisory authority;

·      whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data; and

·     the existence of Automated Decisions, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

For example, such privacy notice should be given to any person applying to become a member of the Club.  In addition, the privacy notice can be made available on the Club website or in other appropriate and easily accessible form. If the notice is published on the website, a conspicuous link to the website or privacy notice should be included in the Club email footer or other Club stationery to bring the notice to the data subjects’ attention.

Where a Club member provides personal data of third party data subjects to the Club, no notice will have to be provided to those third party data subjects by the Club as the Club recognises that such information must remain confidential. Where appropriate, the Club should place a contractual obligation on each member and Supplier to ensure that such notice is provided to those third party data subjects on behalf of the Club.

Generally, personal data must not be processed without a legal ground. In the context of the Club, personal data are typically processed on the basis of:

·     processing is necessary for the performance of a contract to which the data subject (e.g. the member) or the Club is party or in order to take steps at the request of the data subject or the Club prior to entering into a contract;

·    processing necessary for the legitimate interests pursued by the Club, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. This ground may apply to the processing of the personal data of any third party data subjects whose personal data are provided by the member;

·      a legal obligation to which the Club is subject and where compliance with such obligation necessitates the processing of personal data by the Club;

·         data subject’s consent, where such consent is procured from the member; and

·         other legal grounds.

The Club will typically process:

·         the personal data of its members as required for the purposes of providing benefits of membership and the administration of its member relationships;

·         the personal data of its Suppliers as required for the administration of its  Supplier relationships, if applicable; and

·         the personal data of its members and Suppliers as is necessary in order to comply with its legal obligations.

The Club will generally not carry out any unsolicited electronic marketing, but to the extent it does, it will have to comply with the law.

The Club should will ensure that only the minimum necessary personal data is provided in connection with the administration of membership and the Club’s activities as a Rotary Club.

Where a member provides personal data that appears excessive in connection with the professional services sought, the Club will return such personal data to the member.

The Club should make it an obligation of membership that any personal data provided in connection with membership is accurate, complete and up to date.

The Club will endeavour to keep an accurate record of personal data in relation to its members.

The Club will ensure that all Individual Rights Requests are correctly identified and appropriately responded to, subject to any applicable exemptions.

The Club will keep all records as long as required by applicable law or as may be necessary having regard to custom, practice or the nature of the documents concerned. Save for personal data included in records which must kept for a prescribed period or preserved permanently in compliance with any legal obligations to which the Club is subject, personal data shall be kept for no longer than necessary for the relevant purpose. For example, any membership details will be deleted no longer than 12 months following the termination of membership – except names, the period of membership and offices held in the Club and greater Rotary, which will be retained for historical reasons while the Club exists to maintain a proper record of the Club’s activities and responsibilities.  

The Club will adopt the following security measures:

Physical security measures

·                  -     ensure physical security of premises, e.g. Secure Private Residence

• reduce access privileges to only those needed;
• grant access to only those members who need access in connection with their legitimate Club activities;
• dispose of documents using a confidential bin or through a cross cut shredder; and
• other appropriate physical security measures.

Organisational security measures

• vet Suppliers on a continuing basis;
• implement non-disclosure agreements prior to entering into formalised agreements; and
• other appropriate organisational security measures.

Technical security measures

·         firewalls which are properly configured and using the latest software;

·         regular patch management and OS updates;

·         real-time protection anti-virus, anti-malware and anti-spyware software;

·         user access control management by, for example, the UAC functionality in Windows, adopting principle of least privileges;

•     unique passwords of sufficient complexity and regular (but not too frequent) expiry;
•    ensuring appropriate protection of the key data backup; and other appropriate technical security measures.

The Club will implement appropriate governance processes as set out in this Policy.

GOVERNANCE PROCESSES

In order to ensure that the Data Protection Principles are implemented the Club shall adopt the following governance processes. 

A.    Documented Policies

In order to ensure compliance with Data Protection Principle 9 (Accountability), the Club shall comply with this Policy and implement such other data protection policies and establish internal governance processes from time to time as may be required in order to operate the Club in compliance with data protection laws.

B.    Assurance

The Club will ensure, by way of training or otherwise, that officers of the Club and members carry out their Club activities in a way that will ensure compliance with data protection laws. Each member and each Supplier shall have access to this Policy and it shall have an obligation to comply with it.

Each Supplier will have to comply with data protection obligations in accordance with its service agreement including, where appropriate, a data processing agreement.

The Club shall periodically review this Policy and other policies to ensure that they continue to comply with the relevant legal requirements.

C.    Advice

Where necessary the Club shall seek advice in order to ensure that its processes comply with data protection laws.

D.    Third Parties

The Club shall comply with this policy in relation to appointing any third party contractor or supplier who will process personal data on behalf of the Club.

E.    Data Protection Impact Assessments

The Club shall implement a process so that any processing which is likely to result in a high risk to the rights and freedoms of individuals is subject to a documented Data Protection Impact Assessment (DPIA), to assess the risks associated with the proposed processing and identify any safeguards which should be put in place to mitigate those risks. The Club shall maintain a record of each DPIA.

F.    Record-keeping

The Club will implement a process to maintain an up-to-date documented record of its processing by way of adding relevant information in a Club register or by other appropriate means. This record should include a general description of the following:

G.    Privacy by Design

When implementing a new processing activity, tool or functionality involved in the processing of personal data, the Club will ensure, by contractual means or otherwise, that such activity, tool or functionality is designed and built in a way that allows it to comply with the Data Protection Principles.

H.    Complaint handling

The Club shall implement a process to receive and handle enquiries and complaints from individuals and the supervisory authorities concerning the processing of personal data.

The Club shall ensure that all enquiries and complaints are dealt with in a timely manner, in compliance with any applicable statutory deadlines.

Last updated 23 May 2018

APPENDIX: GLOSSARY 

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