Rugeley Phoenix Activities Club – Data Protection & Retention Policy
• Approved by Committee on: 11th September 2018
• Next review date: 1st May 2020
The Rugeley Phoenix Activities Club (Phoenix) is a membership club for people over 50 years of age and is an unincorporated association. In order to operate, Phoenix needs to gather, store and use certain information about individuals.
These can include members, employees, contractors, suppliers, volunteers other people the group has a relationship with or regularly needs to contact.
This policy explains how this data should be collected, stored and used in order to meet Phoenix data protection standards and comply with the Data Protection Regulations and General Data Protection Regulations (GDPR).
Entities must have to have a strict legal basis for holding any Personal Information. For Phoenix this legal basis is known as LEGITIMATE INTEREST. As a members’ club Phoenix has a legitimate reason to hold members’ personal information, so that Phoenix knows who its members are and can manage their membership.
Why is this policy important?
This policy ensures that Phoenix protects the rights of our members and others such that we:
• Comply with data protection law and follow good practice
• Protect the group from the risks of a data breach
Roles & Responsibilities
Phoenix is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer (DPO) for Phoenix is Rob Walker (firstname.lastname@example.org). He, together with the committee is responsible for the secure and fair retention and use of data by Phoenix. Any questions relating to data retention or use of data should be directed to the DPO.
The policy applies to all those handling data on behalf of Phoenix e.g.:
• Committee members
• Activity Group Leaders
• Contractors/3rd-party suppliers
It applies to all data that Phoenix holds relating to individuals, in order for Phoenix to communicate with them about and promote group activities, including:
• Membership numbers
• Email addresses
• Postal addresses
• Phone numbers
• Payment status for subscription and session attendance
Data Collection Principles
Phoenix will only collect data where lawful and where it is necessary for the legitimate purposes of the group.
• A member’s name and contact details (address, telephone number and email address) will be collected when they first join the group, and will be used to contact the member regarding group membership administration and activities. Other data may also subsequently be collected in relation to their membership, including their payment history for annual subscriptions, meeting attendance fees etc.
• The name and contact details of any non-member volunteers and contractors will be collected when they take up a position, and will be used to contact them regarding group administration related to their role.
• An individual’s name and contact details will be collected when they make a booking for an event. This will be used to contact them about their booking and to allow them entry to the event.
• An individual’s name, contact details and other details may be collected at any time, with their consent, in order for Phoenix to communicate with them about group activities.
When collecting data, Phoenix will always provide a clear explanation of why the data is required and what it will be used for.
Phoenix will not collect or store more data than the minimum information required for its intended purpose.
Phoenix will ask members, volunteers and contractors etc to check and update their data on an annual basis. Any individual will be able to update their data at any point by contacting Rob Walker.
Phoenix will keep records for no longer than is necessary in order to meet the intended use for which it was gathered (unless there is a legal requirement to keep records).
The storage and intended use of data will be reviewed in line with Phoenix’s data retention policy. When the intended use is no longer applicable (e.g. contact details for a member who has left the group), the data will be deleted within a reasonable period.
Phoenix will ensure that data it holds is kept secure:
• Electronically-held data will be held within a password-protected and secure environment
• Physically-held data (e.g. membership forms or email sign-up sheets or hard-copy lists) will be stored in a locked cupboard
• Access to data will only be given to relevant committee members, e.g. group leaders, where it is clearly necessary for the running of the group.
• Right to be informed: whenever Phoenix collects data it will explain why it is being collected and how it will be used.
• Right of access: individuals can request to see the data Phoenix holds on them and confirmation of how it is being used. Requests should be made in writing to the Data Protection Officer and will be complied with free of charge and within one month. Where requests are complex or numerous this may be extended to two months
• Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. Any requests for data to be updated will be processed within one month.
• Right to object: individuals can object to their data being used for a particular purpose. Where Phoenix receives a request to stop using data we will comply unless we have a lawful reason to use the data for legitimate interests or contractual obligation.
• Right to erasure: individuals can request for all data held on them to be deleted. Phoenix’s data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected unless there is a legal requirement to keep the data.
• Right to make a complaint: Should a member believe data is being misused in any way they should first lodge a complaint with the Data Protection Officer, Rob Walker.
• We only share members’ data with other members with the subject’s consent
A regular review of all data will take place to establish if Phoenix still has good reason to keep and use the data held at the time of the review.
As a general rule a data review will be held every two years and no more than twenty-seven calendar months after the last review.
Data to be reviewed
• Data on digital documents (e.g. spreadsheets) stored on personal devices held by committee members
• Physical data stored at the homes of committee members
Who the review will be conducted by: The review will be conducted by the Data Protection Officer with other committee members to be decided on at the time of the review.
How unnecessary data will be deleted: eg if a member has left Phoenix or no longer wishes to be contacted for marketing purposes etc
• Physical data will be destroyed safely and securely, including shredding.
• All reasonable and practical efforts will be made to remove data stored digitally.
• Where deleting the data would mean deleting other data that we have a valid lawful reason to keep (e.g. on old emails) then the data may be retained safely and securely but not used.
Date stored by Phoenix may be retained based in statutory requirements for storing data other than data protection regulations. This might include but is not limited to:
• Details of payments made and received (e.g. in bank statements and accounting records)
• Committee meeting minutes
• Contracts and agreements with suppliers/customers
• Insurance details
• Tax and employment records
Other Retention Principles
• When a member leaves Phoenix and all administrative tasks relating to their membership have been completed any potentially sensitive data held on them will be deleted.
Volunteer and freelancer data
• When a volunteer or freelancer stops working with Phoenix and all administrative tasks relating to their work have been completed any potentially sensitive data held on them will be deleted
• Unless consent has been given data will be removed from all email mailing lists
• All other data will be stored safely and securely and reviewed as part of the next periodic review
Activity Group Communications
Each activity group leader will necessarily need to know the name and membership number of any Phoenix member attending sessions of that group. The leader may request other contact details and members can volunteer these at their own discretion. If they chose not to do so they may well not be informed of session changes, venue alterations, group newsletters etc.