SURREY CLUBS FOR YOUNG PEOPLE – PRIVACY NOTICE

As a response to the implementation of European Union General Data Protection Regulation (GDPR) scheduled for May 2015 Surrey Clubs for Young People has reviewed its approach to the holding of personal data. This notice outlines our formal practice as of February 2018.

Potential Bases for holding data

Our position is that we may have any of three potential bases for holding or using your data:

  • You have given us explicit permission to hold and use your data for specific purposes
  • We hold your data in order to fulfil a contractual obligation that we believe we have taken on.
  • We hold you data in order to comply with our current understanding of the legal requirements around record keeping

Your rights under EU GDPR

You have a number of rights under GDPR. If you have any concerns about data we may hold on you please get in touch with Joyce Quinell at [email protected] or Tony Willis at [email protected] If you want an independent view on those rights we recommend looking at the website of the Information Commissioner’s Office.

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Our purposes for holding your data and what we will do with it

  1. If you have asked to receive literature about what we do and opportunities to help support our work then we will keep your data for six years from January 1 2018, and will periodically send you such information.
  2. If you have attended one of our fund raising events we believe we have both a contractual and legal basis for holding your data for a period of three years relating to the event. We also believe that in return for your support we incur an obligation to keep you in touch with the work that you have helped support and with opportunities to keep on supporting that work. We will keep your data for six years from January 1 2018, and will periodically send you such information.
  3. If you have given us a separate donation then we believe we have a contractual and legal basis for holding your data related to that donation. We currently believe that our legal obligations related to the donation itself may require us to hold your data for an indeterminate period of time. We also believe that in return for your support we incur an obligation to keep you in touch with the work that you have helped support and with opportunities to keep on supporting that work. We will keep your data for six years from January 1 2018, and will periodically send you such information.
Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:
1) Your data will be made available to our website provider 
2) The data that may be available to them include any of the data we collect as described in this policy.
3) Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
4) They will store your data for a maximum of 7 years.
5) This processing does not affect your rights as detailed in this privacy policy.

If at any stage you want us to stop sending us information then please let us know at either of the email addresses above and we shall do so.

Tony Willis

Chair

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