INTRODUCTION
Bishopsgate Ward Club is an unincorporated association which has existed since 1790 to represent the interests of those who live, work and have other connections with the Bishopsgate Ward within the City of London. It organises events of various types to bring these members together, in return for an annual membership subscription payment.
Membership of the Club is a form of contract where Members pay a subscription in return for which Members receive benefits and services provided by the Club. The Club asserts that it is a lawful processor by virtue of this relationship and does not need to obtain specific consent to process data. The Club has identified a Data Protection Officer which is the Honorary. Secretary.
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TYPES OF DATA COLLECTED AND STORED
The Club is committed to recording accurate personal data which consists of the information on the Membership Application Form, supplemented by other information provided by members during the course of their membership (e.g. emails, event bookings, surveys completed).
No bank account details are recorded by the Club itself, however, if provided to us, your bank account details may be stored within our Internet Banking service, credit/debit card processor or our Direct Debit service bureau. They may also be requested by the Hon. Treasurer to process a refund to a Member, and in that case the information may be given by telephone, email or post.
The Club does not collect sensitive personal data such as genetic, biometric or health data nor information on race, ethnicity, religion, political persuasion, or sexual orientation. Such sensitive data is known in GDPR (General Data Protection Regulation 2018) as special category data. The Club may verify the information supplied in the Membership Application Form but does not store additional personal information when considering an application. If information is published (i.e. in the public domain) about a Member, e.g. personal, professional or civic honours, the Club is likely to add such information to your record.
In the event of there being a data breach impacting on your personal data, the Club undertakes to inform you (as well as the Information Commissioners Office) within 30 days of the Club becoming aware of the breach. The Club does not believe that the data it holds give rise to any need to report a breach to the Information Commissioner within 72 hours but it is conscious of the possible need to do so. Paper records are also held securely.
TRANSFER AND SHARING OF DATA
The Hon. Secretary is the data controller and principal processor of your data. The Club’s Officers may also wish to look at Member data from time to time and have the right to access it provided this is done with appropriate security measures in place, and securely deleted after use.
The Club uses a secure online membership administration system (currently MyClubHouse.com from Simmetrics Limited) which is provided on a ‘Software As a Service’ basis. This means that your personal data is stored by us within this system, but we retain overall responsibility as data controller for its security and taking such security measures as we think appropriate to the sensitivity of the data held, in conjunction with Simmetrics Limited which acts as data processor on our behalf.
The Club uses Mailchimp, an online contact system, to send emails to the members. For this purpose your name and email address are maintained on this system.
In order to preserve a good history of the Club, copies of past membership lists are sent to the archives at the Bishopsgate Institute; the agreement with Bishopsgate Ward Club specifies that the Institute then becomes responsible for safe storage and control of access to these paper archives and must seek Club approval for access by third parties. The files are stored in the Institute’s archive area, accessible by authorised personnel only.
When you attend functions or events organised by the Club the venue and caterer will normally, for security and practical reasons, want a list of names and dietary or other requirements. The Club does not share your data with any other third party apart from its legal advisers in the event of a legal dispute.
PUBLICATION OF DATA
The Club recognises that an important aspect of membership for some people is being able to contact other members directly, and as such is committed to making lists of basic contact information available to other members, either in the form of a paper/PDF directory or an online lookup facility on its website. However, members will be given the opportunity to individually opt-out of such publication at the time of applying for membership, or any time subsequently, and these requests will be honoured as soon as practicable.
RETENTION OF DATA
The Club intends to hold your data throughout the period of your Membership and applying the following post-Membership policies:
- In the case of resignation, for three years.
- In the case of exclusion, for eight years (in order that appropriate institutional memory exists of the circumstances).
- In the case of death, indefinitely, for archival purposes only, but the Club will consider requests for erasure from immediate family and/or executors.
YOUR RIGHTS
- To complain. Ideally the Club would wish to try to deal with complaints itself before recourse to any external authority and asks Members to submit complaints via email or post but it is open to Members to submit a complaint at any time to the Office of the Information Commissioner.
- To have correct data recorded by the Club. The Club will be happy to correct errors.
- To require the Club to erase data which it holds about a Member. The Club will fully respect the new legislation but reminds Members that the low-level information gathered by the Club is perceived by the Club as the minimum needed to provide Members with the benefits of Club Membership.
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All emails sent by the system contain a tracking pixel. This is used to track whether each email has been opened by the recipient, and when. This information can be viewed by those users of the system with permission to view email delivery reports. We do not display any information regarding the location of the recipient. Note that the tracking pixel is only activated if the recipient chooses to download images into their email client.
We, Bishopsgate Ward Club, make use of the myClubhouse software supplied by Simmetrics Ltd to process personal data we include on our myClubhouse website in accordance with our privacy policy set out above. Simmetrics Ltd processes your personal data on our behalf and they can only do so in accordance with our written instructions. You can find the details of our data processor’s privacy policy here: http://www.myclubhouse.co.uk/Home/PrivacyPolicy.