The Western Club is an unincorporated association of members (“we”, ”our”, “us”, “The Western Club”).
Information supplied to us by you will be dealt with in confidence. It will only be disclosed where reasonable and necessary to the provision of our services or if we are legally required to do so.
We fully abide by the data protection principles under the General Data Protection Regulation, the Data Protection Act 2018 and any associated Act of Parliament. Your personal data held by us on any relevant filing system will not be disclosed to third parties without your consent and is available to you on request.
We collect information about you when you first contact us or engage our services or when you provide any information we request or which you provide voluntarily. This includes information collected through our website or other electronic format.
We will hold some or all of the following personal information about you in our files and on electronic databases: name and address; date of birth; contact telephone number(s); email address(es); NI number (for staff); financial information we require in connection with your membership or employment; emergency contact details (spouse or next of kin). We may also obtain additional personal information to enable us to properly provide our services.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
We record and retain CCTV data where necessary and for the purpose of detecting and preventing criminal activity and to safeguard people and property on our premises. Our CCTV captures visual but not audio recordings. Requests to view footage must be made to the Data Controller and will only be granted if the purpose is legal. Footage of the CCTV system is held for 28 days and then is automatically deleted. A separate CCTV policy is available to peruse upon request.
As a social organisation, the Club makes use of photography to record and report on events. Where images are used on the Club website or in Club publications, we will seek the permission of those in the photograph.
When you become a member or employee, we will collect, store and use the personal information that you provide to us in your instructions and during the course of your membership or employment. The data that we collect from you will be stored inside the UK or the European Economic Area (EEA).
We have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, and other third parties who have a legitimate reason (see “Who we share your personal information with”).
If you provide personal data during the course of an initial enquiry but decide, for whatever reason, not to become a member or employee, in most cases we will retain your data for up to 12 months. It is often helpful for us to retain this information for that period, or longer, in case you change your mind and decide to become a member or employee or otherwise use our services. If you do not become a member or employee and we have not contacted you during that period, we will delete your personal data from our system, usually within 12 months of your enquiry.
We need to collect your personal information so that we can provide Club services or to perform our obligations as an employer. We will use your personal information to:
We may ask you for additional personal information during the course of your membership or employment, which shall be collected, stored and used in accordance with this privacy notice.
If you do not provide us with all of the personal information that we need, this may affect our ability to provide you with our services.
We also process your personal information in pursuit of our legitimate interests to:
In providing our services, we may send your details to, and also use information from credit reference agencies and fraud prevention agencies.
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us on firstname.lastname@example.org. If we comply with your objection, this may affect our ability to undertake the tasks above for the benefit of you as a member or employee.
We are under a legal obligation to process certain personal information relating to our members and employees for the purposes of complying with legal obligations, for example to comply with regulations about taxation, Anti-Money Laundering regulations or employment law.
Internal Third Parties
The Club is administered by several committees. The members of these committees will have access to personal data as required to fulfil their function. Committee members will not retain data longer than is necessary and will return or destroy data when no longer required.
External Third Parties
We may be required to share personal information with statutory or regulatory authorities and organisations. Such organisations include HMRC and other authorities who may require reporting of processing activities in certain circumstances for the purposes of compliance with statutory obligations.
The Club employs third party suppliers to provide services including event organisers, IT suppliers and professional advisors including lawyers, bankers, accountants and insurers. We may also share personal data with reciprocal clubs where a booking is made.
These third parties may process personal data on our behalf as “processors” and are subject to written contractual conditions to only process that personal data under our instructions and to protect it.
In the event that we do share personal data with external third parties, we will only share such personal data strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal data in accordance with those purposes.
Your continued relationship with the Club will be evidence that you consent to our use of your personal information for these purposes.
If we transfer your personal data out of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which, where applicable, you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time in any circumstances where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
By becoming a member or employee or enquiring about membership or employment or otherwise using our services which involves collection of your personal data, you consent to retention of data without further reference to you. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or regulatory requirements. In most cases, we will retain your data for up to two years after you cease to be a member. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or a prospect of your re-applying for membership or employment. 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, or regulatory, requirements.
We would like to send you information about services of ours which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please confirm this in writing to the Club Secretary at any time.
We will not share your information for marketing purposes with any third party.
If you are unhappy about any use we make of your personal information, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please discuss your concerns in the first instance with the Club Secretary or, if you prefer, to any other member of the management team.
Should you have other questions or concerns about these privacy policies, please contact us at 0141 221 2016 or send us an email at email@example.com.