As an organisation that processes personal data only for recreational purposes, the West of England Bridge Club is exempt from the need to register with the Information Commissioners Office under the new General Data Protection Regulations that come into force in May 2018. Nevertheless it is good practice for all organisations to adhere to the principles of those regulations, and we intend to do this.
This Privacy Notice describes how we use and control the personal data that is held and used by the Club, relating it back to the six principles of the new regulations.
1 Personal data shall be processed lawfully, fairly and in a transparent manner
Our lawful basis for processing data is that, as a recreational membership club, we have a legitimate interest in holding sufficient contact and other details to enable us to administer and communicate with our membership.
2 Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
We collect data from all Members of the Club solely for the efficient administration of the Club, including the ability to contact individual Members. We do not publish this data, nor share it with other Club members.
The Members' names, addresses and (where provided) phone numbers and email addresses are shared with the following organisations:
The English Bridge Union (EBU)
This is the regulatory body to which the Club is affiliated and of which all Full Members are automatically made members when they play in a competitive session at the Club. Our data is shared with them for the purpose of allowing the EBU to communicate with its members and provide its services such as the EBU magazine. It is shared for the same purposes with its associated organisations (the English Bridge Education and Development charity and the Avon County Bridge Association) and Pianola (see below).
By default, the EBU does not publish any member’s data unless the member has specifically requested that it should do so.The EBU’s privacy policy can be found on their website.
Pianola
This is a bridge software organisation that maintains playing records and enables us to send results and other bulk emails to those members who have provided an email address and have requested such information. It also acts as a data processor between us and the EBU; as such it is not free or able to share that data with any other organisation. It may publish a member’s contact details to other members but only if explicitly requested to do so.
Pianola’s Privacy Policy is described in article 6 of their Terms and Conditions on their website.
3 Personal data shall be adequate, relevant and limited
The data we collect from all Members of the Club is limited to their names, addresses and (where provided) phone numbers and email addresses, the date of their joining, their membership type and their subscriptions paid, plus their date of birth if under 25.
4 Personal data shall be accurate and kept up to date
We update our records when a member informs us of a change of details, when we become aware of a change of details at subscription renewal or at any other time, when we are notified of a change of details by the EBU and when we become aware of an error in the existing details.
5 Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary
We delete all record of previous members if they have not renewed their membership for two years or more.
6 Personal data shall be processed in a manner that ensures appropriate security
The personal data is held by the Membership Secretary of the Club on a private password-protected computer. Backup copies of the data are held similarly by the Chairman and the Secretary. Other members of the Committee may be provided with data for a specific purpose at the discretion of the Membership Secretary. The data is not provided to any other members of the Club.