Data Protection and Privacy Policy
DATA PROTECTION AND PRIVACY POLICY
THE OLD HONITONIANS CLUB
Introduction
The Old Honitonians Club (‘the Club’) respects the privacy of its members (‘OHs’) and is committed to protecting their personal data. This privacy notice is to inform OHs as to how we look after their personal data and tells OHs about their privacy rights and how the law protects them.
This privacy notice deals with the specific areas set out below:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
11. COOKIE POLICY
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how the Club collects and processes your personal data from old school records (where they still exist) of Allhallows School and Allhallows College, information that as an OH you have previously furnished to the Club and through your use of this website. The only information that the Club maintains on its OH database is the name, postal address and email addresses of its members. (Principal Data – see below)
By submitting material to ‘Aunt Agatha’ OHs are deemed to give their consent to have the information published on the ‘Aunt Agatha’ page of the Club’s web site and in the Club’s magazine.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
The Club Secretary is the Controller and responsible for your personal data.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Controller using the details set out below.
Contact details
Our full details are:
Full name of legal entity: The Old Honitonians Club
Email address: OHClub@thebirminghams.com
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.
Changes to the privacy notice and your duty to inform us of changes
The data protection law in the UK changed on 25th May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your period of membership.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
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.
As a Club, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Principal Data includes your full name, home address, telephone number and email address
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes financial or bank account details or 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.
If you fail to provide personal data
Where we need to collect personal data in order to fulfil the functions of the Club and you fail to provide that data when requested, we may not be able to provide the full facilities of the Club to you (for example, post to you copies of the Club Magazine or send you Newsletters and updates).
3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:
Principal Data. Your full name and home address originally taken from old school records from Allhallows School or Allhallows College and subsequently voluntarily updated by you.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies.
Third parties or publicly available sources. We may receive Technical Data from analytics providers such as Google based outside the EU.
Usage Data includes information about how you use our website.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your data (a) 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, and (b) where we need to comply with a legal or regulatory obligation.
The types of lawful basis that we will rely on to process your personal data are set out below.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending out hard copies of the Club magazine, newsletters and other communications from the Club. You have the right to withdraw such consent at any time by contacting the Controller.
Purposes for which we will use your personal data
The Club is committed to protecting your privacy. Set out below is an explanation of how we use your information.
a. We will never use your Personal Data for any purpose other than for sending to you hard copies of the Club magazine, newsletters and other communications from the Club.
b. We may use your Technical Data to administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. Such use would be necessary for our legitimate interests (for running our business, provision of administration and IT services, to prevent fraud and in the context of a business reorganisation exercise), and to comply with a legal obligation.
c. We may use your Usage Data and Technical Data to deliver relevant website content to you and measure or understand the effectiveness of the content. Such use would be necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform market strategy).
d. We may use your Usage Data and Technical Data to use data analytics to improve our website, services, marketing, customer relationships and experiences. Such use would be necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes. If you give us your express opt-in consent, you can ask us or third parties to stop sending you marketing messages at any time by contacting the Controller.
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. 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
We may have to share your personal data with third parties.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our 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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. 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 the Club’s Officers and other third parties who have a business and need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as you remain a member of the Club.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under the data protection laws in relation to your personal data. Your rights are listed below, and more detail can be found in the glossary below:
- 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 the Controller.
No fee required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
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.
10. GLOSSARY
Legitimate Interest means the interest of the Club in conducting and managing the business of the Club in order to enable the Club to give OHs the best service and the best and most secure experience. 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 by law).
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External third parties
- Service providers acting as processors based in the UK who provide IT and system administration services.
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 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 local 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides 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 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 or where we used information to perform a contract with you.
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 provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
11. COOKIE POLICY
Like many websites, the Old Honitonians Club website uses cookies – small text files, typically of letters and numbers – to capture limited information about the site’s users. The information is transferred by the website to the cookie file of the browser on the hard drive of the user’s computer.
This site uses Google Analytics cookies. These allow us to measure the number of visitors, to see how visitors navigate the site and to see which resources they access. This helps us to develop new content and to improve the way the website works. These cookies do not enable us to identify individual users. Google provides further information about Analytics.
To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On.
For general information about cookies please visit www.allaboutcookies.org.
This policy was updated: June 2020