General Data Protection Regulation Privacy Notice
The Flatcoated Retriever Society (the “Society”) is committed to protecting your personal information and respecting your privacy.
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.
For the purpose of the General Data Protection Regulation, the data controller is The Flatcoated Retriever Society, whose registered office is 11 Harcourt Road, Kibworth, Leicestershire, LE8 0HP.
We may update this Privacy Notice from time to time. Any changes we make in the future will be posted on our website. Please check back regularly to see any updates or changes to this Policy.
2. Data Protection Contact
The contact details for our Secretary for any data protection queries is as follows:
Mrs Jenny Bird
A:11 Harcourt Road, Kibworth, Leicestershire, LE8 0HP.
T: 0116 2793203
3. Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
4. Particulars of processing
We process personal data about members, judges, ring stewards, helpers and competitors/exhibitors to our events, and data regarding health conditions in the breed.
The categories of person about whom we process personal data are described in more detail in the Particulars of Processing that are set out in the Annex to this Privacy Notice.
5. Your rights as a data subject
It is important that we tell you your rights that you have as a data subject under the General Data Protection Regulation – these are set out below.
The General Data Protection Regulation provides the following rights (subject to some exemptions):
- The right to request access to the personal data that we hold about you;
- The right to request rectification of the personal data that we hold about you;
- The right to request erasure of the personal data that we hold about you;
- The right to request restriction of processing about you;
- The right to object to processing; and
- The right to data portability.
If at any point you believe the information we process on you is incorrect, incomplete or out of date then please let us know and we will make sure that your data is corrected.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Secretary using the details above.
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
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:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- 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.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest (or for official purposes).
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. The law calls this the “Legitimate Interests” condition for processing. This may include:
- To maintain our records and other administrative purposes, including updating your details and preferences.
- To assist with queries, complaints and dispute resolution.
- To provide communications related to membership and invitations to participate in events organised on your behalf by the Society, including but not limited to shows, training, tests, trials, lectures, seminars, canine health testing and studies.
- Upholding our club constitution and taking action in cases where there is a breach of the Club rules or Code of Ethics.
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 above or, in the case of email communications by using the “unsubscribe” function at the end of each communication.
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
We may use service providers to help us provide you with our services. Personal data may be transferred to such a service provider, who acts for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed.
Such third parties have contracted with us as data processors under the requirements in the General Data Protection Regulation. 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.
In appropriate circumstances, we may disclose data to authorised bodies as required by law.
8. Visitors to The workingflatcoats website
Yes we do. Cookies are small pieces of information, stored in simple text files, placed on your computer by a website. Some cookies can be read by the website on your subsequent visits. The information stored in a cookie may relate to your browsing habits on the webpage, or a unique identification number so that the website can ‘remember’ you on your return visit. Other cookies are deleted when you close your browser and only relate to the working of the website. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have furnished such information to the website. Cookies help us to provide you with a good experience when you browse our website and also allows us to improve our site.
Cookie information is held on your browser and you can amend your browser settings at any time. If you want to learn more about what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance.
Currently, we operate an ‘implied consent’ policy which means that by using our website you agree we can place these types of cookies on your device. If you are not happy, then you should either not use the site, or you should delete the cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.)
Third party cookies may be set on your machine by external websites accessed via this website. Cookies may also be set which are the sharing buttons which allow users to share content onto social networks.
What cookies do we use?
We use google analytics on our website. This collects cookies and is widely used across the web. It collects information about your activity on our site, the device used to access the site, how you came on to the site (directly, through social, or through google) and your general location.
We use this information to gather feedback on our website, to see how users behave on our website, and to learn how they came to our website. It helps us to improve our site based on this information.
The data that we see through google analytics does not include any personal information.
Some emails we send we track, at an individual level, whether the user has opened and clicked on the email. We do not use this information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. If you want to be sure that none of your email activity is tracked then you should opt out of our emails which you can do via the unsubscribe link at the bottom of every email we send.
9. Contact details
Please contact the Secretary above (section 2) if you have any questions or concerns about personal data and privacy matters.
ANNEX TO THE PRIVACY NOTICE
What is the purpose of processing your personal data?
We process your personal data for:
- Provision of membership services including administration and transactional communications relating to membership
- Upholding the Society Rules and Code of Ethics
- Compliance with Kennel Club Rules and Regulations
- For the organisation of events
- Contacting you by email to provide related information and information concerning events and activities
- We also process personal data for the Society’s legitimate interests as we have outlined in the main Privacy Notice. Please be assured that we will always take account of your personal data rights in doing so.
What is the lawful basis for the processing of your personal data?
The Society has entered into a contract with you to provide membership services including administration and communications relating to membership which constitute a contractual necessity.
As a Member of the Society, you have given your consent through the provision of personal data.
What personal data do we process?
The personal data for Society members that we process are:
- Email address(es)
- Telephone number(s)
- Date joined
- Method of payment of subscription
- Membership application proposer and seconder
- Date of birth of junior members.
Where do we obtain your personal data from?
Most of the above personal data is or has been received directly from you (the data subject). However, information may be received from third parties e.g. The Kennel Club, Fossedata, Higham Press, FTMS etc.
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 Society’s data retention policy (below).
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 your personal data, we will be unable to perform any contract we have with you for the provision of membership or event services.
Who are the recipients of your personal data?
- A copy of the Yearbook is provided to the British Library and the Kennel Club in accordance with legal requirements or KC Rules.
- Members names and addresses are provided to Morleys Print and Publishing Ltd for postal services.
- Names and addresses of entrants to the Society’s Championship and Open Shows are provided to Fosse Data Systems for printing purposes.
- Data relating to the reported health conditions of members’ dogs may be shared to contribute to validated research projects as approved by the Society’s Health committee.
- Information relating to the dog’s pedigree will be shared with owner consent but members names and addresses will not be shared.
The following Society Officers and Committee members also hold personal data:
- The Membership Secretary maintains the central record of all current members of the Society for the Society’s organisational, administrative and communication purposes.
- Officers of the Society have access to the membership list for administrative and communication purposes.
- We provide the Kennel Club with details of Society officers, Challenge Certificate winners at our show events, and entries to our Field Trials and the award winners, in order to meet the requirements in the Kennel Club Rules and Regulations.
- Membership details are held by the 250 Club Administrator, Area Representatives Coordinator and Field Trial Secretary, for organisational, administrative and communication purposes.
- Bank details are held for 250 Club Members using Direct Debit services for administrative purposes.
Health data relating to dogs provided by Members is held by the Health Coordinator for current and future research projects.
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 Society in accordance and compliance with all statutory, HMRC and Financial Authority requirements.
What records are maintained by the Society?
The Society maintains a list of all current members, including names, addresses, telephone numbers and email addresses supplied by the Member.
The Society holds the personal data of Officers of the Club as a part of the implementation of Kennel Club Rules and Regulations.
The Society holds the personal data of members of Sub-Committees and other organisational groups within the Society in order to operate effectively in Members’ interests.
The Society maintains records regarding the health of dogs owned by Members for use in research projects.
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.
The Society will only retain personal data for as long as necessary to fulfil the purposes for which it was collected, 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 for historical and 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.
There is a statutory requirement to keep financial records for seven years. However, records may be kept for the last eight years, in order to ensure that year ends are available. Beyond the eight-year point, there is little justification in keeping bank statements, cheque stubs etc. unless there was an incident which was of particular significance.
Membership Records and Lists
Membership records will be deleted within 24 months of an individual ceasing to be a Member of the Society. Printed membership lists, i.e. those contained within Yearbooks etc., will be retained as a historical record.
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, Field Trial and Working Test schedules and running orders
Show catalogues, schedules and running orders 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.