The Old Monovians Association
Data Protection policy
• Policy prepared by: John Cunningham
• Approved by Committee: March 2018
• Next review date: March 2019
In order to operate, The Old Monovians Association needs to gather, store and use certain forms of information about individuals.
These can include members, suppliers, volunteers, business contacts and other people the Association 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 The Old Monovians Association data protection standards and comply with the law.
Why is this policy important?
This policy ensures that the Old Monovians Association:
• Protects the rights of our members, volunteers and supporters
• Complies with data protection law and follows good practice
• Protects the Association from the risks of a data breach
Who and what does this policy apply to?
This applies to all those handling data on behalf of The Old Monovians Association, for example:-
• Committee members
It applies to all data that The Old Monovians Association holds relating to individuals, including:
• Email addresses
• Postal addresses
• Phone numbers
• Any other personal information held (e.g. financial)
Roles and responsibilities
Everyone who has access to data as part of The Old Monovians Association has a responsibility to ensure that they adhere to this policy.
The Data Controller for The Old Monovians Association is Michael Higgins, Secretary, OMA. They, together with the Committee, are responsible for why data is collected and how it will be used. Any questions relating to the collection or use of data should be directed to the Data Controller.
Data Protection Principles
1. We fairly and lawfully process personal data
The Old Monovians Association will only collect data where lawful and where it is necessary for the legitimate purposes of the Association.
• A member’s name and contact details will be collected when they first join the Association, and will be used to contact the member regarding Association membership administration and activities. Other data may also subsequently be collected in relation to their membership, including about their payment history for fees and subscriptions.
• The name and contact details of committee members, employees, volunteers and contractors will be collected when they take up a position, and will be used to contact them regarding Association administration related to their role.
• Further information, including personal financial information and criminal records information may also be collected in specific circumstances where lawful and necessary (in order to process payment to the person or in order to carry out a DBS check).
• 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 (including when booking for an event), with their consent, in order for the Old Monovians Association to communicate with them about Association activities, and/or for Direct Marketing. See ‘Direct Marketing’ below.
2. We only collect and use personal data for specified and lawful purposes.
When collecting data, The Old Monovians Association will always explain to the subject why the data is required and what it will be used for, for example:-
“Please enter your email address in the form below. We need this so that we can send you email updates for Association administration including about events, subscriptions and other business.”
We will never use data for any purpose other than that stated or that can be considered reasonably to be related to it. For example, we will never pass on personal data to third parties without the explicit consent of the subject.
3. We ensure any data collected is relevant and not excessive
The Old Monovians Association will not collect or store more data that the minimum information required for its intended purpose.
For example we need to collect email addresses and telephone numbers from members in order to be able to contact them about Association administration, but data on their marital status or sexuality will not be collected, since it is unnecessary and excessive for the purposes of Association administration.
4. We ensure data is accurate and up-to-date
The Old Monovians Association will ask members, employees and volunteers to check and update their data on an annual basis.
Any individual will be able to update their data at any point by contacting the Data Controller.
5. We ensure data is not kept longer than necessary
The Old Monovians Association will keep data on individuals for no longer than 12 months after our involvement with the individual has stopped, unless there is a legal requirement to keep records.
6. We process data in accordance with individuals’ rights
The following requests can be made in writing to the Data Controller:
• Members, volunteers and supporters can request to see any data held on them. Any such request will be actioned within 14 days of the request being made.
• Members and supporters can request that any inaccurate data held on them is updated. Any such request will be actioned within 14 days of the request being made.
• Members and supporters can request to stop receiving any marketing communications. Any such request will be actioned within 14 days of the request being made.
• Members and supporters can object to any storage or use of their data that might cause them substantial distress of damage or any automated decisions made based on their data. Any such objection will be considered by the Committee, and a decision communicated within 28 days of the request being made.
7. We keep personal data secure
The Old Monovians Association will ensure that data held by us is kept secure.
• Electronically-held data will be held within a password-protected and secure environment.
• Passwords for electronic data files will be re-set each time an individual with data access leaves their role/position.
• Physically-held data (for example, membership forms or email sign-up sheets) will be stored in a cabinet capable of being locked.
• Keys for locks securing physical data files should be collected by the Data Controller from any individual with access if they leave their role/position. The codes on combination locks should be changed each time an individual with data access leaves their role/position.
• Access to data will only be given to relevant Committee members where it is clearly necessary for the running of the Association. The Data Controller will decide in what situations this is applicable and will keep a master list of who has access to data.
8. Transfer to countries outside the EEA
The Old Monovians Association will not transfer data to countries outside the European Economic Area (EEA), unless the country has adequate protection for the individual (for example, USA)
9. Member to Member Contact
We only share members’ data with other members with the subject’s prior consent
As a membership organisation The Old Monovians Association encourages communication between members.
To facilitate this, Members can request the personal contact data of other members in writing via the Data controller or Secretary. These details will be given, as long as they are for the purposes of contacting the subject (for example, an email address, not financial or health data) and the subject consents to their data being shared with other members in this way.
10. Direct Marketing
The Old Monovians Association will regularly collect data from consenting supporters for marketing purposes. This includes contacting them to promote events, updating them about Association news, fundraising and other Association activities.
Any time data is collected for this purpose, we will provide:
• A clear and specific explanation of what the data will be used for (e.g. ‘Tick this box if you would like The Old Monovians Association to send you email updates with details about our forthcoming events, fundraising activities and opportunities to get involved’)
• A method for users to show their active consent to receive these communications (e.g. a ‘tick box’)
Data collected will only ever be used in the way described and consented to (for example, we will not use email data in order to market 3rd-party products unless this has been explicitly consented to).
Every marketing communication will contain a method through which a recipient can withdraw their consent (for example, an ‘unsubscribe’ link in an email). Opt-out requests such as this will be processed within 14 days.
11. Cookies on The Old Monovians Association Website
A cookie is a small text file that is downloaded onto ‘terminal equipment’ (for example, a computer or smartphone) when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions.
We will implement a pop-up box on www.oldmonovians.com that will activate each time a new user visits the website. This will allow them to click to consent (or not) to continuing with cookies enabled, or to ignore the message and continue browsing (i.e. give their implied consent).