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R&PWCGS Privacy Notice Society Members August 2018

1. What is the purpose of this document?
   • The Roads & Public Works Contractors Golf Society is committed to protecting the privacy and security of your personal information (collectively referred to as “the Society”, “RPWCGS”, “we”, “us”, or “our”).
   • This Privacy Notice (“Notice”) describes how we collect and use personal information about you during and after your membership with the Society, in accordance with the General Data Protection Regulation (“GDPR”).
   • This Notice applies to all past, present and prospective members of the Society (“Members“). This Notice does not form part of the Rules & Bye-Laws or any other contract to provide services you may have with the Society from time to time.
   • It is important that you read this Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
   • We reserve the right to amend this Notice at any time without notice to you so, if required, please check to ensure that you are referring to the latest copy of this Notice. We may also notify you in other ways from time to time about the processing of your personal data.
2. Data Controller
   • The Roads & Public Works Contractors Golf Society committee is a “data controller” for the purposes of the GDPR. This means that we are responsible for deciding how we hold and use personal information about you.
   • You have the right to make a complaint at any time to the ICO (www.ico.ora.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. Data protection principles We will comply with data protection law. This says that the personal information we hold about you must be:
   • Used lawfully, fairly and in a transparent way.
   • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
   • Relevant to the purposes we have told you about and limited only to those purposes.
   • Accurate and kept up to date.
   • Kept only as long as necessary for the purposes we have told you about.
   • Kept securely.
4. The kind of information we hold about you
   • Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are also “special categories” of more sensitive personal data which require a higher level of protection.
   • We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
     • Identity Data includes first name, last name;
     • Contact Data includes address, email address and telephone numbers;
     • Membership Data includes the general particulars of your membership including (but not limited to) the category of your membership, handicap;
     • Technical Data includes information about your use of our information and communications systems (including our website) such as your internet protocol (IP) address, your login data, browser type etc.;
     • Usage Data includes information about how you use our website.
     • Profile Data includes your username and password, feedback and meeting entry forms.

5. How is your personal information collected?
   • We collect personal information about you through the membership application and election process, both directly from you and from existing Members.
   • We may also automatically collect personal information about you as you interact with our website including data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies, as almost all websites do, to help provide you with the best experience we can. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our “cookie policy”.
   • Additional personal information will also be collected during the course of your membership with the Society from time to time.
6. How will we use the information about you
   • We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
     • Where we need to perform the agreement we have entered into with you.
     • Where we need to comply with a legal obligation.
     • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   • We may also use your personal information in the following situations, which are likely to be rare:
     • Where we need to protect your interests (or someone else’s interests).
     • Where it is needed in the public interest or for official purposes.
   • Generally, we do not rely on consent as a legal basis for processing your personal data and we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Situations in which we will use your personal information
   • We need all the categories of information in the list above primarily to allow us to administer your membership and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
   • The situations in which we will most likely process your personal information are listed below:
     • Making decisions about your membership;
     • Administering your membership and any other reasonable purpose connected with your membership and notified to you in advance or as otherwise agreed with you from time to time;
     • responding to, or following up on, your comments and questions, and otherwise providing services in connection with your membership;
     • To provide meeting entry services;
     • To assist and inform the Society’s management and planning, including accounting and auditing;
     • Complying with health and safety obligations;
     • Gathering evidence for possible grievance or disciplinary hearings;
     • Dealing with legal disputes involving you or other Members, employees, workers and contractors and attending to accidents at the Society meetings;
     • To monitor your use of our information and communication systems to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems;
     • crime prevention; and/or
     • legal and regulatory compliance.

8. If you fail to provide personal information If you fail to provide certain information when requested, we may not be able to administer your membership with the Society, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our Members, visitors and staff). In this case, we may have to cancel your Membership but we will notify you if this is the case at the time.
9. Change of purpose We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
10. How we use particularly sensitive personal information
    • “Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.
    • We may process special categories of personal information in the following circumstances:
      • In limited circumstances, with your explicit written consent.
      • Where we need to carry out our legal obligations.
      • Where it is needed in the public interest.
    • Most commonly, we may use sensitive personal information about your physical or mental health, or disability status, to ensure your health and safety and to provide access to the clubhouse and golf courses at meetings.
    • Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about Members or former Members in the course of our legitimate business activities with the appropriate safeguards.
    • We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific legal rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your membership that you agree to any request for consent from us.
11. Data sharing
    • We may have to share your Data with third parties. We will only share your Personal Data with third parties where required by law, where it is necessary to administer your membership or where we have another legitimate interest in doing so.
    • “Third parties” includes third-party service providers (including contractors and designated agents) and other affiliates of the Society, for example suppliers of golf equipment. We may also need to share your personal information with a regulator or to otherwise comply with the law.
    • In particular, the following third-party service providers may process personal information about you for the purpose of confirming your handicap and club memberships from time to time: England Golf, Surrey County Golf; CONGU; and Central Database of Handicapping.
12. How secure is my information with third-party service providers?
    • Third parties in the United Kingdom and the EU are subject to the provisions of the GDPR or similar regulations in relation to your Personal Data.
    • All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
    • We do not envisage we will need to transfer your personal information outside the EU- If we do, you can expect a similar degree of protection in respect of your personal information.
13. Third-party links on our website
    • Our website may include links to third-party websites, plug-ins and applications from our partners, members, advertisers or affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
    • Similarly, if you take up any offers or promotions with our affiliates, those third parties may pass information on to their own suppliers once we have provided it to them. We are not responsible for personal data that is used by such third parties in their capacity as independent or joint ‘data controllers’.
    • When you leave our website or otherwise engage with third-parties, we would urge you to read the privacy-notice-of every website you visit to ensure you are fully informed of all data processing activities connected with the services you receive from us.
14. Data security
    • The GDPR requires us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We ensure that reasonable security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
    • We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
    • If you have any questions about our current organisational and technical security procedures, please contact the Society Secretary.

15. How long will we use your information for?
    • We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
    • To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
    • In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

16. Your duty to inform us of changes It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your membership with the Society. You can update your own personal information on the website.
17. Your rights in connection with personal information
    • Under certain circumstances, by law you have the right to:
      • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
      • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
      • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
      • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
      • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
      • Request the transfer of your personal information to another party.
    • If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Society Secretary in writing.
18. No fee usually required You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
19. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
20. Right to withdraw consent In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Society Secretary. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.