1. This Policy sets out the obligations of National Association of Tangent Clubs (“We” or “Our”) regarding data protection and the rights of individuals (“You” or “Your”) in respect of their personal data (“information”) under the General Data Protection Regulation (“the Regulation”).

   This Policy aims to ensure compliance with the Regulation

   The Regulation seeks to ensure that personal information is processed lawfully, fairly, and transparently, without adversely affecting your rights.

2. We have identified that processing carried out by us is necessary for the purposes of the legitimate interests pursued by us or by a third party acting on our behalf, except where such interests are overridden by your fundamental rights and freedoms which require protection of personal information. Our legitimate interests are the management of the Association and includes without prejudice to the foregoing generality: contacting member clubs and passing/receiving information to/from them; the collection of subscriptions; the collation and delivery of magazines; the maintaining and updating of our website and website galleries; the maintaining of a social media presence; the collation of information about regional lunches; the maintaining of insurances; the collation and distribution of the Association directory; the collation and maintaining of the historical archive of the Association and assume deemed authorisation to use those photographs for Tangent News, the website and social media.

   You have the right to object to our processing of your personal information based on our legitimate interests. Where you object to our processing of your personal information based on our legitimate interests, we shall cease such processing forthwith, unless it can be demonstrated that our legitimate grounds for such processing override your interests, rights and freedoms; or that the processing is necessary for the conduct of legal claims.

3. The personal information we collect may include your name, address, email address and telephone number(s); information you provide to us by sending us a message through our website; information provided to us when you communicate with us electronically or via post (If you contact us, we may keep a record of your email, letter and other correspondence) and information that you provide us as a result of filling in forms on our website. We may collect photographs showing your attendance at event(s) as well as maintaining historic records also showing your attendance at event(s).

   We shall ensure that all personal information collected and processed is kept accurate and up-to-date. The accuracy of information shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date information is found, all reasonable steps will be taken without delay to amend or erase that information, as appropriate.

4. We will pass your information to third-party providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you (for example to publish and deliver the magazine, maintain our website galleries and to send you email). However, when we use third party service providers, we will disclose only the personal information that is necessary to deliver the service and we will have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

   We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes.

5. The information which you provide to us will not be transferred to countries outside the European Union (“EU”). However if we do transfer your information outside of the EU (By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU) we will take steps to ensure that appropriate security measures are taken. By submitting your personal information, you’re agreeing to this transfer, storing or processing.

6. We’ll keep your information for as long as you are a member of NATC. When you are no longer a member, we’ll keep it where we may need it for our legitimate purposes for example to help us respond to queries or complaints, or for other reasons for example insurance purposes or to maintain our historical records.

7. You have the following rights in terms of the regulation:-

   1. You may request that we cease processing the personal information that we hold about you. If you make such a request, we shall retain only the amount of your personal information that is necessary to ensure that no further processing of your personal information takes place. We will inform all appropriate third parties of your request

   2. You may ask us to erase the personal information we hold about you in the event that it is no longer necessary for us to hold that personal information or where you object to us holding and processing your personal data and there is no overriding legitimate interest to allow us to continue doing so or where your personal information has been processed unlawfully or where your personal information needs to be erased to comply with a particular legal obligation

      Unless we have reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and you will be informed of the erasure, within one month of receipt of your request. We will inform all appropriate third parties of your request.

   3. You can ask us for details about the personal information we hold about you. This is known as a Subject Access Request. We will respond to you with one month of receipt of your request.

8. We do not use personal information for the purposes of automated decision-making.

Details of our full policy in terms of the regulation is available to members from our National Secretary. If you have a concern about our information rights practices you should address that concern to our National Secretary in the first instance. If your concern is not addressed to your satisfaction you can report your concern to the Information Commissioner’s Office https://ico.org.uk/

(Nov 2020)