Privacy Notice
General Data Protection Regulations
Privacy Notice
May 2018
Purpose
Upton Mens’ Club is a social group for men living in the Upton area in Chester, no longer in full time employment, who meet together on a regular basis for social discussions on a wide range of topics.
The Group also arranges social events to which partners of members and widows of previous members are invited.
The Group is led by a President who is elected by the membership on an annual basis.
Membership
Membership is freely open to all men. Members pay a weekly subscription on attendance to meet the cost of refreshments, the hire of the meeting room in the United Reform Church, Upton, and the occasional donation to visiting speakers.
Data Protection
To facilitate the operation and management of the club, a database is maintained of contact details for members and widows. This information consists of:-
Name
Partner’s Name
Postal Address
Telephone Number
Email address
Attendance dates
Contact details are held to facilitate contact with members and widows about Club activities. The partner’s name is held to assist with telephone contact. Attendance dates are held to enable the Treasurer to maintain the financial records.
No data is shared with any external parties. All data is held by the Treasurer on a secure database, with access available to the President and any member.
General Data Protection Regulations (GDPR)
The GDPR allows for six lawful bases for processing personal data. These are:-
Consent
Contract
Legal Obligation
Vital Interests
Public task
Legitimate interests
It is considered that Legitimate Interests represents the most appropriate basis for processing this data. In accordance with the GDPR requirement, this paper includes a Legitimate Interest Assessment.
Legitimate Interest Assessment
The basis for Legitimate Interests is defined as “the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests”. A three-part test is required to establish this basis.
Purpose (are you pursuing a legitimate interest?)
The data is held for the following purposes:-
to allow the members to remain in contact with each other and with the widows of past members,
to allow the President, or other members, to advise the members of events of interest,
to allow the Treasurer to retain a record of the members attending for the purpose of preparing a set of annual accounts.
Necessity (is the processing necessary for that purpose?)
It is considered that the data held is the minimum required in order to fulfil the objectives of the club.
Balancing (do the individual’s interests override the legitimate interest?)
It is considered that the social nature of the club, to provide an environment to promote friendship, discussion and mutual activities, justifies processing the data in the way described. No sensitive personal data is held. If the widows of past members no longer wish to receive notification of club events, they may advise the President who will remove them from the database.
Prepared by Gary Nye