PRIVACY
PRIVACY NOTICE
This policy covers individuals who visit the Club, but are not staff or members. This will usually comprise:
- Guests of members.
- Visiting members of Reciprocal Clubs and their guests.
- Individuals attending events, classes, or participating in sporting fixtures.
- Individuals coming to see the Club staff for professional purposes, such as business meetings.
- Individuals, such as contractors or consultants, attending the site to provide services such as advice, consultancy services or maintenance and repair of Club facilities or equipment.
The Hurlingham Club is committed to protecting and respecting your privacy. We take our responsibilities seriously and will only use the personal data we hold in accordance with the law. This Privacy Notice sets out the basis on which your personal data will be collected, handled, stored and shared by us. Please read the following to understand what we do with your information.
1. PERSONAL DATA WE MAY COLLECT FROM YOU
We may collect and hold a range of different information that you or the member or member of staff associated with your visit have provided us. This allows us to provide the services of the Club and to contact you if needed.
This information may include:
- Name
- Telephone (home, office and mobile)
- Email (personal and work)
- Vehicle registration
- CCTV footage if you visit the Club
- A history of when you visited the Club
- -A record of any incidents that occurred during, or related to, your visit
On very rare occasions, we may need to process Special Category Data, for example, if you injure yourself at the Club. We do so in accordance with applicable law (including with respect to safeguarding or employment) or by explicit consent.
2. HOW WE USE YOUR INFORMATION
We use your information to provide the services offered by the Club. These include (but are not limited to):
- Keeping a record of guest visits to the Club for the purposes of managing guest visits in line with the Club’s rules and bye-laws.
- Keeping a record of visits to the Club and incidents while at the Club for the purpose of maintaining security.
The Club will never use your data to send you any marketing material, and will only contact you when necessary.
3. SECURITY
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of the information. Our security procedures mean that we may occasionally request proof of identity before we disclose the information to you.
4. HOW WE SHARE YOUR INFORMATION
4.1 THIRD PARTIES
We provide information to selected third parties, in order for them to supply services to us.
Such third parties include selected suppliers of products and services to the Club, such as software providers.
The Club can provide details upon request of any third parties that process your data. We will only share your data where it is strictly necessary for the management of the Club, and will never share your personal information with third parties who intend to use it to send marketing content to you.
4.2 DISCLOSURES AND SECURITY
We will only share your personal information with third parties that have provided sufficient guarantees in respect of their data security measures. We require all third-party contractors to demonstrate the same security measures that the Club would have to take if we were doing the processing.
4.3 TRANSFERS ABROAD
The Club will never transfer your data abroad, unless you are a Reciprocal Member or their guest, visiting from overseas and we need to discuss your visit with your club.
5. THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
The GDPR sets out several different legal bases under which an organisation may collect and process your data. We rely on the following legal bases:
CONSENT
In specific situations, we will collect and process your information with your consent. We will always make it clear to you what you are consenting to and what information is necessary for which services.
CONTRACTUAL OBLIGATIONS
In certain circumstances, we need your information to carry out our contractual obligations.
LEGAL OBLIGATIONS
If we are required to by law, we may need to collect and process your information.
LEGITIMATE INTERESTS
In specific situations, we require your information to pursue our legitimate interests in a way that you might reasonably expect as part of running our membership organisation and providing the services of the Club, and which will not materially impact your rights, freedoms or interests.
In the case of special category data, we will seek your explicit consent in line with our obligations under the GDPR.
6. YOUR RIGHTS
The GDPR gives you certain rights over your personal information:
- Right to access the information
- Right to have the information kept up to date
- Right to have the information erased
- Right to restrict our processing of the information
- Right to have the information transferred from us to another organisation
- Right to object to our processing of the information
- Right to lodge a complaint concerning the protection of the information with the Information Commissioner’s Office.
You can submit a request to exercise any of these rights by the GDPR. It will be free of charge, except where we deem it unfounded or excessive. A fuller explanation of each of these rights, and the formal request procedure, is available on request.
7. CHANGES TO OUR PRIVACY NOTICE
The Club may update this Privacy Notice as appropriate. We will never materially change our policies or procedures to make them less protective of personal information collected in the past. It is your responsibility to check this page from time to time to ensure that you are happy with our current Privacy Notice.
8. CONTACT US
If you have any questions, comments or concerns regarding this Privacy Notice or the way we handle your personal data, or wish to make any requests, please address these to:
Matthew Sommerich at dataprotection@hurlinghamclub.org.uk
The Hurlingham Club
Ranelagh Gardens
London
SW6 3PR