Sutton Coldfield Angling Society
Privacy Policy




Data Protection policy

 Introduction

Sutton Coldfield Angling Trust (the Club) is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the Club's commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of members and former members, referred to as HR-related personal data.

The Club has appointed Andy Hales, Secretary, as the person with responsibility for data protection compliance within the Club. He/she can be contacted at secretaryscas47@gmail.com  Questions about this policy, or requests for further information, should be directed to him.

Definitions

"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

Data protection principles

The Club is committed to the principles of the GDPR and processes personal data in accordance with the following data protection principles:

  • The Club processes personal data lawfully, fairly and in a transparent manner.
  • The Club collects personal data only for specified, explicit and legitimate purposes.
  • The Club processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
  • The Club keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
  • The Club keeps personal data only for the period necessary for processing.
  • The Club adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

The Club tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

Where the Club processes special categories of personal data to perform obligations or to exercise rights in employment law, this is done in accordance with the requirements of the GDPR and the provisions set out in this policy.

The Club will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the memberships is held in the individual's personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which the Club holds HR-related personal data are for as long as they remain members.

The Club keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, the Club will tell him/her:

  • whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
  • to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
  • for how long his/her personal data is stored (or how that period is decided);
  • his/her rights to rectification or erasure of data, or to restrict or object to processing;
  • his/her right to complain to the Information Commissioner if he/she thinks the Club has failed to comply with his/her data protection rights; and
  • whether or not the Club carries out automated decision-making and the logic involved in any such decision-making.

The Club will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

To make a subject access request, the individual should send the request to secretaryscas47@gmail.com. In some cases, the Club may need to ask for proof of identification before the request can be processed. The Club will inform the individual if it needs to verify his/her identity and the documents it requires.

The Club will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the Club processes large amounts of the individual's data, it may respond within three months of the date the request is received. The Club will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, the Club is not obliged to comply with it. Alternatively, the Club can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the Club has already responded. If an individual submits a request that is unfounded or excessive, the Club will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require the Club to:

·         rectify inaccurate data;

  • stop processing or erase data that is no longer necessary for the purposes of processing;
  • stop processing or erase data if the individual's interests override the Club's legitimate grounds for processing data (where the Club relies on its legitimate interests as a reason for processing data);
  • stop processing or erase data if processing is unlawful; and
  • stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override the Club's legitimate grounds for processing data.

To ask the Club to take any of these steps, the individual should send the request to secretaryscas47@gmail.com.

Data security

The Club takes the security of HR-related personal data seriously. The Club has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where the Club engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Data breaches

If the Club discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The Club will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

Individual responsibilities

Individuals are responsible for helping the Club keep their personal data up to date. Individuals should let the Club know if data provided to the Club changes, for example if an individual moves’ house or changes his/her bank details.

Individuals who have access to personal data are required:

  • to access only data that they have authority to access and only for authorised purposes;
  • not to disclose data except to individuals (whether inside or outside the Club) who have appropriate authorisation;
  • to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
  • not to remove personal data, or devices containing or that can be used to access personal data, from the Club's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
  • not to store personal data on local drives or on personal devices that are used for work purposes.