The purpose of the General Data Protection Regulation (GDPR) is to provide a set of standard data protection laws across the European Union, making it easier for people to understand how their data is being used and to give individual people greater control over its use. Berkhamsted Bowls Bridge Club (the Club) undertakes to collect and use provided personal data in compliance with the GDPR.
1. What personal data does the Club collect?
2. What is this personal data used for?
3. With whom is Member data shared with?
4. How is Member data stored?
5. Who is responsible for ensuring compliance with the relevant laws and regulations?
6. Who has access to Member data?
7. What is the legal basis for collecting this data?
8. How Members can check what data we have?
9. Does the Club pass any data to the EBU or EBED?
10. How can Members ask for data to be removed, limited or corrected?
11. How long does the Club keep Member data for and why?
12. What happens if a Member dies?
13. Can Members download other Member data to use it elsewhere?
14. Can the Club down-load Member data to use it elsewhere?
What personal data does the Club collect?
The data the Club collects is limited to Members’ names, email addresses and telephone numbers. The Club collects this data directly from Members and stores it on BridgeWebs.
Some Club Members may have additional information such as Directors, Scorers and teaching qualifications recorded.
The Club collects the scores from games Members play, which are used in maintaining results displayed on the club website, hosted by BridgeWebs.
Members’ names are also held within each instance of the ScoreBridge application.
What is this personal data used for?
The Club uses Members’ data for Membership administration and for the communication of information relating to the playing of bridge and the organisation of any special events. The Club provides a limited amount of data for use by the scoring program to ensure that Members’ results are correctly attributed to them.
With whom is Member data shared with?
Membership data is not shared with the EBU or other Bridge Clubs.
A limited amount of information e.g. name listed in the Membership database on BridgeWebs is made available for use in the scoring program ScoreBridge, to allow the correct identification of players for scoring purposes only.
Some data will be accessible by the BridgeWebs capability operator which is resident in "the cloud", as they act as Data Processors on behalf of the Club but they are not free to pass this on to other organisations.
Only the names of Members are resident on the ScoreBridge application. ScoreBridge data is retained only on the Club’s specifically nominated “Scorers” on their personal computers. Name data stored on the ScoreBridge instances of previous Scorers is considered out of date and not relevant, as the ScoreBridge license for those instances has expired.
Uploads of ScoreBridge files to BridgeWebs require a password as agreed by the Webmaster with BridgeWebs and the upload takes place over a secure connection.
Members' personal data is not provided by the Club for use by any organisation.
How is Member data stored?
The Club's main Membership database is stored in digital form using the BridgeWebs capability which is operated in “the cloud” in compliance with the GDPR.
Consent Forms are kept in the form of hardcopy stored in a file retained by the Club Bridge Manager(s).
Who is responsible for ensuring compliance with the relevant laws and regulations?
Under the GDPR the Club does not have a statutory requirement to have a Data Protection Officer. The person who ultimately is responsible for ensuring that the Club discharges its obligations under the GDPR is the Berkhamsted Bowls Bridge Club Manager(s). The day-to-day operation and enforcement of the policy is delegated to the Webmaster.
Who has access to Member data?
Members can access the Membership List via their personal login to BridgeWebs – each Member can see the name, home and mobile phone numbers but not individual email addresses.
Access to the full personal information held on BridgeWebs is restricted to the following organisational roles at the Club:
- Bridge Manager(s)
Whilst Scorers can technically undertake such action they are not permitted to do so.
Only the personnel in the roles below can send out bulk emails on behalf of the Club:
- Bridge Manager(s)
- Partner Finder
The Club’s Organisation Structure showing the up-to-date list of Club personnel by role is available on the website.
What is the legal basis for collecting this data?
The lawful bases for processing are set out in Article 6 of the GDPR. The Legal Basis that applies to the Club is that of Consent – where the individual has given clear consent to the Club to process their personal data for a specific purpose.
The Club only collects personal data that is necessary for the purposes of its legitimate interests as a Members Club.
How can Members check what data we have?
Members can see the basic Membership data the Club retains by loging into the Club website using their personal password and select the Members tab option. There Members can see and update all their details and change the permissions as required via the Personal Details page under the Account tab.
Members can contact the Club Webmaster if they wish a hard copy version of the information retained. Legally the Club is required to provide this within one month, though in reality it will be done more quickly.
Does the Club pass any data to the EBU or EBED?
The Club is not affiliated to the English Bridge Union (EBU) so no personal data is passed to them or the English Bridge Education Department (EBED).
How can Members ask for data to be removed, limited or corrected?
If Members want to remove the basic Membership data the Club retain they can log in to the Club website using their personal password and select the Members tab option. Using the Personal Details page under the Account tab the Member can view and amend any or all their details and correct the permissions granted for the use of personal data e.g.
- Members can select to not be included in the Membership list.
- Members can select not to be included in any bulk email that may be sent out on behalf of the Club (the Club does not send any email on behalf of other organisations).
Also, Members can on receipt of any email from the Club, click on “Unsubscribe” which will ensure their email address is removed from future emails until at such a time they select to receive emails again. Note only the Member can select to re-subscribe.
How long does the Club keep Member data for and why?
The Club normally keeps Members’ data after they resign or their Membership lapses. The data continues to be necessary in relation to the purpose for which it was originally collected and processed e.g. scoring.
What happens if a Member dies?
The Club normally deletes a Member’s information after they die as it can be upsetting to their partner and other Members to be reminded of the deceased.
Can Members download Member data to use it elsewhere?
Technically it is possible for a Member to copy/paste the Membership List for inclusion in some other format e.g. Word or Excel. Such practice is not permitted.
Can the Club download Member data to use it elsewhere?
Those roles listed in the Organisation structure may download Members’ information for use at meetings, but it will not be distributed.
Any queries with this Policy please liaise with either the Berkhamsted Bowls Bridge Club Bridge Manager(s) or Webmaster.