BSA FWDC: DATA PROTECTION ACT:
PRIVACY STATEMENT
The UK Data Protection Act 2018 enacts the EU General Data Protection Regulation (EU) 2016/679 into UK law. The Act requires the Club to publish a ‘privacy policy’ to state what ‘personal data’ we are collecting and the use to which it will be put.
The identity and contact details of the controller and the data protection officer
The BSA Front Wheel Drive Club Limited, a company limited by guarantee and registered in England and Wales, company number: 032437485.
Primary Data Controller: Treasurer: Treasurer@bsafwdc.org
The purpose of the processing and the lawful basis for the processing
The Club may collect personal data when you join the Club, renew your membership, or place an order for spares, regalia or other purchases comprising:
1. your name,
2. postal address
3. telephone number(s)
4. email address (if provided)
We will only use this information to:
• Administer the Club’s affairs
• Supply you with the Club’s magazines and publications.
• Inform you about Club activities and other activities related to the Club’s interests – e.g: activities organised by others that the Club may support.
• Sell you Club spares and regalia
• To communicate with you in regard of any technical or historical matters relating to the Club’s interests.
• To maintain the Club’s historical archives
The ‘lawful bases’ for holding and using your personal data are:
A. the ‘legitimate interests’ of the Club in respect of 1,2,3 and 4 above;
B. the ‘legal obligation’ of the Club as a Company Limited by Guarantee and regulated by the Companies Act in respect of 1 and 2 above;
C. ‘contract’ in respect of 1, 2, 3, 4, and 5 above.
The legitimate interests of the ‘data controller’.
The Club has the aims of ensuring the continued existence of BSA FWD cars by encouraging interest and enthusiasm in the marque, including the provision of spare parts, the sharing of technical advice, and researching the history of the manufacturer and the cars.
This requires effective administration of the Club’s affairs and communication with all Club members.
Any recipient or categories of recipients of the personal data
We will not disclose your personal data to another person or organisation unless either:
1. We are required to do so by law or our contractual arrangements require it;
(e.g: we need to send a list of addresses to the printers every month)
2. You have consented to such disclosure
You will be asked to give your consent specifically to disclosing your personal details to other Club members on the membership application form or renewal form. Only a clear and unequivocal indication of consent will be recognised. At every annual renewal, this consent will be sought again. Any other consent will be sought separately.
Details of transfers to third country and safeguards
Our membership database and website data is currently held in the USA by Internet Service Provider iFastnet and has been so for some years. Any transfer of data to another country will be restricted to movement to the UK as part of a change of Internet Service Provider. iFastnet have their own privacy policy which can be found here https://ifastnet.com/privacy.php
All data on our website is subject to security controls and access to personal data is restricted to registered Club members. The personal data of Club members who have not given consent to share their details with other members will only be available to Club Committee members.
Retention period or criteria used to determine the retention period
Information on former members is retained as required by the Companies Act and for the legitimate interest of maintaining historical and archive records. Personal data will be treated as confidential.
The existence of each of data subject’s rights
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to the Club Chairman whose address appears in the Club magazine
We will respond to your request within a month.
We will not charge you for complying with such a request unless the request is ‘manifestly unfounded or excessive’; we may charge a reasonable administrative-cost fee if further copies are requested.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
The right to withdraw consent at any time, where relevant
Where a member has provided consent for his/her details to be shared with other Club members, they have the right to withdraw such consent at any time by informing the Club Treasurer by letter or email.
The right to lodge a complaint with a supervisory authority
If we are unable to resolve any complaint you have about the Club’s use of your personal data, you have the right to complain to:
The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data
As a company limited by guarantee, the Club has a legal obligation to maintain a register of its members and may be required by Companies House to provide to them the personal data that you have supplied to us.
In joining the Club, you enter into a contract in which we use your personal data to send you the Club magazine, publish adverts in the magazine for you, sell you parts and regalia, provide you with advice and support, and carry out administrative tasks to maintain your membership. Your personal details are also required to be held by our website to provide you with secure password-protected access. Without such data, we would be unable to fulfil your membership.
The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences
No automated decision making will be carried out.
How to contact us
For further information on how your information is used, how we maintain the security of your information, and your rights to access information we hold on you, please contact the Club Treasurer. Treasurer@bsafwdc.org. Postal contact details can be found in the Club Magazine.
Changes to our privacy policy
We keep our privacy policy under regular review and we will place any updates on the Club’s web page. This privacy policy was last updated on 11th June 2018.