Ross-on-Wye Angling Club (the Club) is committed to protecting and respecting the privacy of its members. From the 2021 season onwards the Club will be using Clubmate https://clubmate.fish to administer its membership. This will require members/prospective members to have an email address and provide information online. As Clubmate is the data controller, it is imperative that all members read Clubmate’s privacy statement found here https://clubmate.fish/privacy/?v=79cba1185463 and their software will store and process the data for the Club. The Club is responsible for ensuring the data is used in a fair, lawful, secure and transparent way.
What personal data we hold on you
The information you give us, via Clubmate, may include your name, date of birth, address, e-mail address, phone number and gender. Your membership page on Clubmate will allow you to control your personal data.
You may also give us information about yourself by corresponding with us by telephone, e-mail or otherwise. This includes information you provide when you apply for membership of the Club or elect to join the Club’s membership waiting list. The Club will not retain any personal information, this will be stored on Clubmate, entered by yourself.
As members will be paying for membership online, Clubmate will also require certain financial information, which includes bank account and payment card details. The Club has no access to this information. Clubmate uses Stripe, an internet payment system, who are fully regulated by the Financial Conduct Authority (FCA), to transfer monies to the Club’s bank account and to do this your financial information is shared with Stripe. The Club receives payments from Stripe and no individual’s information is shared in this process. Stripe’s privacy statement can be found here: stripe.com
To protect members’ data Clubmate have in place physical, electronic and managerial procedures to safeguard and secure data at all times. All member information is stored and maintained with multi-layered security provided by Microsoft Azure across physical data centres, infrastructure and operations. And when data is transferred between the Clubmate server and the member’s computer it uses the same SSL technology as banks and financial institutions to ensure it remains protected. No sensitive financial information (bank details, debit or credit card information) is ever seen, stored or transmitted by the Club or Clubmate. This data is always held securely by their payment partner Stripe.
We
will notify you promptly in the unlikely event of any breach of your personal
data which might expose you to serious risk.
Where a member suspects a breach of data protection has arisen, the member must immediately bring this to the attention of the Membership Secretary.
Why we need your personal data
The reason we need your personal data is to be able to administer your membership and provide the membership services you are signing up to when you register with the Club. Our lawful basis for processing your personal data is that we have a contractual obligation to you as a member to provide the services you are registering for.
Reasons we need to process your data include:
· Maintaining current and accurate membership records.
- Maintenance of the Club’s membership waiting list and issuing invitations for membership.
- Processing of membership forms, applications and payments.
- Issuing membership cards and associated club information.
- Circulation of Club notices and newsletters, including membership renewal information.
- General member communications relevant to the running of the Club, maintenance of the Club’s fisheries and Club-related information of interest to members.
- Corresponding with an individual member – for example in the event of a breach of Club rules.
- Analysing anonymised data to monitor Club membership trends.
From time to time the Club may share with members information received from third parties when such information is considered by the Club committee to be relevant to the interests of the club and its members.
Who we share your personal data with
As Clubmate is the data controller, they state
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· 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.
· Where we need to comply with a legal or regulatory obligation.
· Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Further information can be found in Clubmates’ privacy statement (link above).
The Club will not supply any personal data held on Clubmate to any third party.
How long we hold your personal data
As Clubmate is the data controller, the following is their statement on data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
The Club will hold your personal data electronically within the Clubmate system for as long as you are a member of the Club and for as long afterwards as it is in the Clubs’ legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether it can continue to be processed. If we decide that we cannot continue to allow it to be processed, we will stop any processing of your personal data.
Information held for members who don’t renew their membership will be deleted from the Clubmate database 12 months following their lapsed membership, with any direct communication with the Club also appropriately and securely destroyed.
Inactive Clubmate accounts (i.e. no memberships added and paid for) for twelve months from the date they were opened will be closed and all personal data held within them deleted. This does not apply to accounts on the waiting list.
Your rights regarding your personal data
As Clubmate is the data controller, the following is their statement on data retention
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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 Clubmate.
On your personal page on Clubmate, you can modify your personal data at any time and change your marketing preferences. As a data subject you are not obliged to share your personal data with the Club, via Clubmate. However, if you choose not to share your personal data with us, we may not be able to register or administer your membership.
Members who choose not to access their own data through the member portal of Clubmate can request either verbally or in writing to access their data and must be responded to within one month of the request. All requests will be directed to the Membership Secretary who will respond within the timescale. A record will be kept for management purposes of each request received.
As a data subject you may have the right at any time to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office about the processing of your personal data.
You have the right to have your personal data erased in certain circumstances (please note that if you elect to have your personal data erased this will immediately terminate your membership at no cost to the Club).
We reserve the right to amend this Data Privacy Policy from time to time without prior notice. You are advised to check our website or your Clubmate page regularly for any amendments (but amendments will not be made retrospectively).