NORTH OF ENGLAND KEESHOND CLUB
General Data Protection Regulation (GDPR) Privacy Notice
1. Introduction
1.1. The NORTH OF ENGLAND KEESHOND CLUB is committed to protecting your personal information and respecting your privacy.
1.2. This Privacy Notice sets out the basis on which any personal data that we collect from or about you, or that you provide to us, will be processed by us.
1.3. For the purpose of the General Data Protection Regulation [the GDPR], the data controller is the NORTH OF ENGLAND KEESHOND CLUB.
1.4. We may update this Privacy Notice from time to time. Please check back regularly to see any updates or changes to this Notice.
2. Data Protection Contact
2.1. The contact details for our Secretary for any data protection queries are as follows:
2.1.1. Email secretary@north-of-england-keeshond-club.co.uk
3. Data Protection Principles
3.1. We will comply with data protection law. This says that the personal information we hold about you must be:
3.1.1. Used lawfully, fairly and in a transparent way.
3.1.2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3.1.3. Relevant to the purposes we have told you about and limited only to those purposes.
3.1.4. Accurate and kept up to date.
3.1.5. Kept only for as long as necessary for the purposes we have told you about.
3.1.6. Kept securely.
4. Particulars of processing
4.1. We process personal data about members, judges, ring stewards and competitors/exhibitors to our events. The categories of person about whom we process personal data are described in more detail in the Annex to this Privacy Notice.
5. Your rights as a data subject
5.1. The General Data Protection Regulation provides the following rights (subject to some exemptions):
5.1.1. The right to request access to the personal data that we hold about you;
5.1.2. The right to request rectification of the personal data that we hold about you;
5.1.3. The right to request erasure of the personal data that we hold about you;
5.1.4. The right to request restriction of processing about you;
5.1.5. The right to object to processing; and
5.1.6. The right to data portability.
5.2. If you wish to raise a complaint on how we have handled your personal data, you can contact our Secretary.
5.3. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO) full contact details for which can be found at https://ico.org.uk/global/contact-us/
6. How we will use information about you
6.1. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
6.1.1. Where we need to perform the contract which we have entered into with you.
6.1.2. Where we need to comply with a legal obligation.
6.1.3. 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.
6.1.4. We may also use your personal information in the following situations, which are likely to be rare:
6.1.4.1. Where we need to protect your interests (or someone else’s interests).
6.1.4.2. Where it is needed in the public interest or for official purposes.
6.2. We will generally process your personal data for contractual necessity in providing membership services and events. We may also use personal information for additional relevant and related purposes where you might reasonably expect us to do so, where the benefits of doing so are not outweighed by your own interests or fundamental rights or freedoms. This may include:
6.2.1. To maintain our records and other administrative purposes, including updating your details and preferences:
6.2.2. To assist with queries, complaints and dispute resolution;
6.2.3. For communications related to membership and invitations to participate in canine market research or canine health studies:
6.2.4. To assist with upholding our club constitution and taking action in cases where there may be a breach of the Club rules or Codes of Ethics.
6.3. We will ask for your direct consent IF we intend to use your personal data for marketing purposes. Where our processing of personal data is based on your having given consent, you have the right as a data subject to withdraw that consent at any time. If you wish to invoke this right, please notify the Secretary using the contact details set out in Section 2 above.
6.4. You have the right to lodge a complaint with a supervisory authority. In the United Kingdom, the supervisory authority is the Office of the Information Commissioner, full contact details for which can be found at https://ico.org.uk/global/contact-us/.
7. Recipients of Data
7.1. We may use service providers to help us provide you with our services. Personal data may be transferred to such service provider, who act for or on our behalf, for further processing in accordance with the purpose(s) for which the data was originally collected or may otherwise be lawfully processed.
7.2. Such third parties have contracted with us as data processors under the requirements in the GDPR. They are contractually bound to only use personal data for the agreed purpose(s). Relevant persons working for these third parties will have access to your personal data under the terms of the data processor contract, but only to the extent necessary to perform their services for us.
7.3. These data processors agree to implement reasonable contractual and technical protections, to keep your data confidential, not sell your personal data to third parties and to not disclose your personal data to third parties except as may be required by law, as permitted by us or as stated in this Privacy Policy.
7.4. In appropriate circumstances we may disclose data to authorised bodies as required by law.
8. Contact details
8.1. Please contact the Secretary if you have any questions or concerns about personal data and privacy matters.
ANNEX 1
Processing of Personal Data
This Annex sets out the NORTH OF ENGLAND KEESHOND CLUB’s processing of personal data relating to members (including committee members), judges and exhibitors/competitors at our events.
What personal data do we process, why do we process it and what is the lawful basis?
Members
Name
Address
Email address
Telephone number
We process your personal data for the following purposes:
Provision of membership services including administration and transactional communications relating to membership – Contractual Necessity
Upholding the Club/Society Rules and Code of Ethics – Contractual Necessity
Compliance with Kennel Club Rules and Regulations – Contractual Necessity
Contacting you regarding newsletters, invitations and information about club events/meetings [etc.] – Contractual Necessity
Publication in the Members handbook/yearbook/information booklet or on the website – Legitimate Interests
Contacting you by email to provide related information and information /marketing communications (if any) – Consent
Judges
Name
Address
Email address
Telephone number
We process your personal data for the following purposes:
Administration and transactional communications relating to judging appointments – Contractual Necessity
Upholding the Club/Society Rules and Code of Ethics Contractual Necessity
Compliance with Kennel Club Rules and Regulations (including sharing relevant required information) – Contractual Necessity
Publication in the Club judges’ list and for appointments in the show/event schedules – Legitimate Interests
Exhibitors/Competitors
Name
Address
Email address
Telephone number
Dog information
We process your personal data for the following purposes:
Administration and transactional communications for exhibitors/competitors entering our events – Contractual Necessity
Provision of services relating to our events – Contractual Necessity
Upholding the Club/Society Rules and Code of Ethics Compliance with Kennel Club Rules and Regulations – Contractual Necessity
Contacting you regarding future events – Legitimate Interests
Publication of your name address and dog information in show/event catalogue [subject to the right to object] – Legitimate Interests
Publication of event results on our websites or in Newsletters and other Club publications – Legitimate Interests
We also process personal data for the Club’s legitimate interests as we have outlined in the main Privacy Notice (paragraph 4). Please be assured that we will always take account of your personal data rights in doing so.
Where do we obtain your personal data from?
Most of the above personal data is received direct from you (the data subject). However, information may be received from third parties (e.g. show printers, The Kennel Club website).
How long do we hold your personal data for?
Personal data will be retained in accordance with statutory requirements, Kennel Club requirements and recommendations and the club’s retention policy which is shown in Annex 2.
Are you obliged to provide us with your personal data?
You are not obliged to provide the personal data in question. However, if you do not provide the personal data, we will be unable to perform any contract we have with you for the provision of membership services, judging appointments or event services.
Recipients of your personal data
We disclose data to the following outsourced data processors [if applicable], in line with section 5 of our main Privacy Policy, for:
Kennel Club records
The Kennel Club will hold the personal data of officers of the Club/Society as a part of the implementation of Kennel Club Rules and Regulations.
We provide the Kennel Club with details of NORTH OF ENGLAND KEESHOND CLUB officers and Challenge Certificate winners at our events in order to meet requirements in the Kennel Club Rules and Regulations.
We provide show entrants’ data to our show printer for inclusion in the show catalogue.
Do we use your data for any automated decision-making?
No personal data is processed for automated decision-making
Any financial data arising from a transactional process will be held securely by the Club in accordance and compliance with all statutory and HMRC requirements.
ANNEX 2
Personal Data Retention Policy
“Data minimisation” is one of the overarching principles in the General Data Protection Regulation. It requires personal data to be retained only for so long as is necessary. Personal data should therefore only be kept as long as is strictly necessary and organisations should define time limits OR have criteria to determine when data should be disposed/deleted securely.
Retention Policy
The Club will only retain personal data for as long as necessary to fulfil the purposes for which it was collected it including for the purposes of satisfying any legal, accounting, or reporting requirements.
Personal data can be further processed and stored for archiving in the public interest and statistical and historical research purposes. When doing so we will consider: any link to the initial purpose, the context the data was collected in, the reasonable expectations of members/exhibitors/competitors/judges, the nature of the data, the consequences of further processing and the existence of appropriate safeguards. Also, whether such data can be ‘anonymised’ if being preserved for archives.
Membership Lists: Old membership lists may have some historical value and/or statistical value The Club will consider how long is practically useful.
Constitutions: Out of date constitutions come into the same category. Whilst details of changes will be included in AGM reports, there may be a historical interest in retaining original versions where possible, and which can be displayed as part of commemorative exhibitions.
Show Catalogues: Show catalogues can provide a gold mine of information and statistics, as well as forming an important historical record. Show entry forms must be retained for twelve months after the show.
Committee and AGM/SGM Minutes and Documents: Committee minutes and documents relating to AGMs and SGMs must be retained as the definitive record of all club business together with the decisions made and policies agreed. Also, as an information resource to resolve any procedural issues or disputes.