Privacy Policy of
The Moulton Bicycle Club
1st May 2018
Scope
This privacy policy explains how we use any personal information we collect about you when you use our services.
Glossary of Terms
What is personal data?
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
- Names and contact information ie emails and telephone numbers
- National Insurance Numbers
- Employment history
- Employee numbers
- Credit History
What is sensitive personal data?
Sensitive personal data refers to the above but includes genetic data and biometric data. For example:
- Medical conditions
- Religious or philosophical beliefs and political opinions
- Racial or ethnic origin
- Convictions
- Biometric data (eg photo in an electronic passport)
What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
The data controller is Simon Jones, 5 Davies Road, Moreton in Marsh, Gloucestershire. GL56 0HR
What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the controller.
What is Data Processing?
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
What do we mean by Business to Business?
PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.
What do we mean by Business to Consumer?
Private clients, sole traders, unincorporated partnerships, trusts and foundations.
What Information do we Collect About You?
The Moulton Bicycle Club, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).
You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services and for other related purposes including;
- Updating and enhancing client records
- Analysis for management purposes
- Legal and regulatory compliance
- Crime prevention.
How Will We Use the Information About You and Why?
At The Moulton Bicycle Club we take your privacy seriously and will only use your personal information to provide the Services you have requested from us and as we have identified above. We will only use this information subject to your instructions, data protection law and our duty of confidentiality.
For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.
For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” eg to supply goods and services you have requested, or to fulfil obligations under an employment contract. This also includes steps taken at your request before entering into a contract.
Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
We will not share your information for marketing purposes with companies so that they may offer you their products and services.
Transferring Your Information Outside of Europe
As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU. Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing. Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.
If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.
Security Precautions in Place About Data Collected
When you give us personal information, we take steps to make sure that it’s treated securely.
Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access data transmitted to you, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Profiling
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.
How Long Will We Hold Your Data For?
Contracted Services: We will hold your hard copy printed data for 7 years and will hold digital data indefinitely unless you ask for it to be held for only 7 years as in the case of hard copy printed.
Access to Your Information, Correction, Portability and Deletion
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you.
If you would like a copy of some or all your personal information, please write to us at the following address: Simon Jones, 5 Davies Road, Moreton in Marsh, Gloucestershire. GL56 0HR
If you would like a paper copy of the club’s data policy, please write, enclosing an SAE to: Arthur Smith 22b Westhampnett Road Chichester PO19 7HW.
We will respond to your request within one month of receipt of the request.
We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by writing to the above address.
Objections to Processing of Personal Data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.
Data Portability
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
(a) The processing is based on consent or on a contract, and
(b) The processing is carried out by automated means.
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you, please send your request in writing to: Simon Jones, 5 Davies Road, Moreton in Marsh, Gloucestershire. GL56 0HR
Complaints
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office.
Changes to our Privacy Policy
We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 1st May 2018 and the Version number is 1.1.18 and is in line with the new GDPR guidelines.
How to Contact Us
Please contact us if you have any questions about our privacy policy or information we hold about you, by writing, enclosing an SAE to: Arthur Smith 22b Westhampnett Road Chichester PO19 7HW.