Aldershot, Farnham and Fleet Camera Club
Data Protection Policy (version 2-2 August 2023)
A “not for profit” organisation, the Aldershot, Farnham and Fleet Camera Club (the “Club”) is established with the objects set out in its constitution, and is a data controller within the UK.
Purposes, Data Subjects and Recipients
The Club processes personal data for the purposes of pursuing its legitimate interests as a membership club for photography enthusiasts.
Data may be processed about past, current and prospective members of the Club; members of other camera clubs; officials, representatives and members of local, national and international Federations of camera clubs; persons offering services and acting as judges in competitions; speakers from outside the Club; other persons providing or offering services to the Club; and other third parties.
In the course of pursuing its legitimate interests, the Club may necessarily have to disclose personal data it processes to members of the Club; officials and representatives of other camera clubs; officials and representatives of local, national and international Federations and other associations of camera clubs; persons offering services and acting as judges in competitions; speakers from outside the Club; other persons providing or offering services to the Club; and other third parties. Such disclosures will be limited to contact details and information about images entered in competitions.
By supplying an image to the External Competitions Secretary for use in an external competition, Members consent to the disclosure to the organiser of that competition such of their personal data as may be required by that organiser (normally limited to name, but might include contact details).
The personal data of Club Members, past Members and prospective members will not be disclosed to any commercial or non-commercial entity or natural person for any purposes save those of satisfying the Club’s legitimate interests.
Overseas processing
The Club uses the MailChimp email service. MailChimp is a data controller contracted to the Club. MailChimp’s servers are located in the United States of America. The Club has a private Facebook page. Facebook is headquartered in the United States of America and the personal data of members of the Club registered in that group (whether they post there or not) may be processed on servers outside the UK.
The Club also uses the 1&1 Webmail service from 1&1 IONOS SE, which company also hosts the Club’s website. This company is headquartered in Germany, within the European Union, and subject to the General Data Protection Regulation which is currently incorporated within the UK’s Data Protection Ac t 2018. It is understood that the servers that provide services to the Club are located within the European Union.
For completeness, the Club uses the Photoentry subscription system to enable members to enter images in competitions and challenges, and for other display purposes. Photoentry acts as a Data Processor to the Club. This system is hosted in the UK. The DiCentra system is used in-house for the projection of digital images. This is licensed software with the data processed on the Club’s IT equipment. Both systems process personal data.
Policy
The Club is committed to comply with the Data Protection Act 2018.
- Personal data processed by the Club may be in paper or electronic format.
- Data are processed to:
a) establish and maintain membership;
b) inform Club members of activities and requirements;
c) facilitate the management of photographic images belonging to Club members;
d) record entries to competitions and the results of those competitions;
e) enable the notification and management of Club meetings in person or online. - The data processed about members of the Club shall comprise exclusively:
a) name including any affiliations, qualifications and awards
b) address(es)
c) telephone number(s)
d) email address(es)
e) titles of images entered in competitions by that member
f) results of competitions. - Exceptionally, the Club may hold special categories of data about members and others in order to facilitate their fullest involvement with the Club and its activities.
Retention
The Club shall retain such personal data as it processes for the following periods:
| Category of data | Retention period |
| Data about members, whether paid-up or honorary | For the duration of their membership |
| Data about past members, whether paid-up or honorary | For three (3) years after their membership lapses |
| Data about members of other camera clubs | For three (3) years after last contact |
| Data about representatives of local, national and international Federations of camera clubs | For so long as they remain in their relevant role(s) and then for three (3) years after the last contact |
| Data about persons offering services and acting as judges in competitions | For so long as they offer such services and then for three (3) years after the last contact |
| Data about speakers from outside the Club | For so long as they offer such services and then for three (3) years after the last contact |
| Data about other persons providing or offering services to the Club and other third parties. | For three (3) years after the last contact |
| References to members and other individuals in, but not limited to: minutes and other records of meetings; emails; reports; handbooks; competition results; awards; event results; images provided by members; and other such documents. | Without limitation, as a historical record. |
Rights
Data subjects have the right to request access to and rectification or erasure of their personal data, or the restriction of their processing, and to object to the processing. They also have the right to ‘data portability’. Data subjects have the right to complain to the Information Commissioner’s Office regarding the processing of their data.
Right of access
Data subjects wishing to obtain a copy of the data processed about them by the Club; or to seek rectification or erasure of their personal data, or the restriction of processing of their data, or to object to the processing, should contact the Membership Secretary. Data will be supplied within 30 days of receiving a validated ‘subject access’ request, other requests will be satisfied with in the respective time limits set out in the Data Protection Act 2018.
Security
Taking into account the nature, scope, context and purposes of processing, the Club will take appropriate technical and organisational measures to ensure and demonstrate that processing is in accordance with the law.
Access to the Club’s private (Members-only) Facebook page
All Members, paid-up and Honorary, shall have the standard (i.e., any Facebook user) access to the Club’s private (Members only) Facebook page.
Any Member whose Membership lapses through non-renewal of their Annual Membership fee shall continue for a further year to have the same access to the Club’s private (Members only) Facebook page as they enjoyed as a paid-up Member. Lapsed Members may, of course, decline to continue to have such access, and will be informed of this right.
Any Member who is asked to leave the Club, shall have all previous right of access to the Club’s private (Members only) Facebook page rescinded as soon as is practical.
Inclusion on the Club’s Mailing List
All Members, paid-up and Honorary, shall be included on the Club’s Mailing List, to receive information about the Club’s activities. Members may, of course, opt out of receiving such information.
Any Member whose Membership lapses through non-renewal of their Annual Membership fee shall continue for a further year to be included on the Club’s Mailing List, to receive information about the Club’s activities. Lapsed Members may, of course, opt out of receiving such information, and will be informed of this right.
Any Member who is asked to leave the Club, shall be removed from the Club’s Mailing List as soon as is practical.