Old Shirburnian Sailing

Privacy Policy May 2018

 Introduction

1.       In this policy we set out how the officers and members of Old Shirburnian Sailing (the “Club”) store and make use of personal data in carrying out the activities of the Club.

Contact

2.       Please contact Marcus Chavasse, Rear Commodore and Membership Secretary for any matters relating to data privacy at osss@myclubhouse.co.uk

Processing of data in relation to the Club’s formal Objects

3.       The Club’s Object is “to promote and encourage sailing, racing, cruising and good seamanship generally among Old Shirburnians”.  Membership includes members of the Old Shirburnian Society, former pupils of Sherborne School for Girls, Honorary and Associate members.  The Committee interprets the Object of the Club as including, but not limited to, understanding the interests of members and potential members, encouraging additional membership, promoting all forms of sailing and related activities, organising appropriate sailing and social events, and maintaining a historical record of the Club’s activities.

Principle

4.       Old Shirburnian Sailing processes data lawfully, fairly and in a transparent manner in relation to individuals.

Policy

5.       Members and other authorised users of the Club’s data are required to adhere to this privacy policy.

Bases for processing data

6.       We have taken a “layering” approach to the legal bases for processing personal data.  In any situation, more than one legal basis may apply.  The rights of individuals vary depending on the basis that applies in accordance with the legislation.

7.       Contract and Legitimate Interest: members of Old Shirburnian Sailing enter into a contractual relationship with the Club and personal data is processed in order to fulfil that relationship.  Equivalent relationships, for data processing purposes, exist in the case of those taking steps to become members and former members.

8.       Processing under the bases of Contract and Legitimate Interest includes processing of application forms and membership questionnaires. Club officials have access to personal data and may use this, for example, to contact members about their subscriptions, to promote sailing in accordance with the Club’s Object, to provide newsletters or to provide notification of events.

9.       We use a number of email distribution lists to contact members.  Emails are sent in compliance with the Club’s Rules and its Object of promoting sailing.

10.   Consent: we offer a number of services for which members provide specific additional consent.  These include, but are not restricted to, an online member directory (accessible by members only) and member to member messaging.

11.   Where “Consent” is the basis for processing, we ask individuals for consent at the time of first requesting the service.  Individuals have the right to withdraw consent.

12.   Historically, consents for additional services have been considered by the Committee to be part of the membership contract.  For new requests, we now ask members to provide consent when requesting or accessing these services for the first time in compliance with current legislation.

13.   Legitimate Interest: the club processes personal data in which it has legitimate interest in a number of further circumstances.  We hold personal data in relation to organisation of events and may share this with other organisations where necessary for the running of those events.  We hold personal data of individuals whom we consider may be prospective members.  We collect information on members’ sailing interests and other preferences.

14.   We hold such personal data where necessary to further the Objects of the Club.

15.   Vital interest: On occasion, we hold personal data, such as in relation to allergies or medical conditions, in order to allow safe organisation of events.

Sensitive Personal Data

16.   Sensitive Personal Data which relates to an individual and includes attributes such as: race, ethnic, political, religious, trade union, physical or mental health, sexual orientation, criminal proceedings or convictions. Such data requires additional attention to care in processing and confidentiality. For the Club this will predominately involve health data in relation to physical activity.

Rights of individuals

17.   Current legislation provides rights for individuals covering:

a.       The right to be informed

b.      The right of access

c.       The right of rectification

d.      The right of erasure

e.       The right to portability

f.        The right to object; and

g.       Rights in relation to automated decision-making and profiling.

18.   If you have any concerns about the data we hold or process, please be in touch with the Club contact listed at the beginning of this document.  Members may amend much of the data we hold through MyClubhouse on a self-service basis.  Please log on from time to time in order to keep your data up-to-date using https://myclubhouse.co.uk/osss

19.   Users may manage their consents online through MyClubhouse.

20.   We may require further proof of identity from any individuals requesting access to data.

21.   Individuals have the right to register a complaint with the Information Commissioner’s Office or successor organisations.

Photography and Videos

22.   Gathering photographs or video of events is in the legitimate interests of the Club and/or part of the membership contract.  The Club may publish photographs or videos of events or individuals.  The Club will endeavour to remove any photographic material on request.

Data retention

23.   We retain personal data for as long as is necessary for contractual purposes, for carrying out the Objects of the Club, for event organisation, and for historical record keeping purposes.  The retention period may be indefinite.

Minors

24.   The club does not normally have minors as members or hold the personal data of minors.  In situations where we do hold personal data of minors, we apply this privacy policy.

Location of data processing

25.   Simmetrics Limited, the “Data Processor”, carries out data processing under contract.

26.   All data processing is carried out within the United Kingdom or the European Union.

Sharing of information

27.   The Club does not routinely disclose members’ personal data to third party organisations nor does it undertake direct marketing on behalf of any such organisation.

28.   We share the information necessary for the organisation of events with other relevant parties.  We occasionally share data with other organisations related to Sherborne School or Sherborne Girls.

29.   On rare occasions, there may be a legal requirement to share data with the Police or other authorities legally authorised to request disclosure of personal data without the need to obtain consent from the individual(s) concerned.

Exclusion of social media sites

30.   Members from time to time make use of certain social media sites such as a Facebook group, a WhatsApp group and Sherborne Connect.  Users sign up individually and separately to such sites.  This Privacy Policy does not cover use of such social media sites.

Printed media

31.   We process personal data in accordance with this policy at the time of going to press and endeavour to minimise the incidence of inaccuracies.  Once printed, it may not always be possible to control circulation or to rectify errors if data subsequently prove to be inaccurate.

Updates

32.   We review and, if appropriate, update our privacy policy every two years or more frequently as required.

OSS Privacy Policy May 2018 v.003

Marcus Chavasse