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GDPR and clubs and classes. |
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2547 
Really should get out more 
Joined: 11 Aug 11 Online Status: Offline Posts: 1151 |
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 Topic: GDPR and clubs and classes.Posted: 14 May 18 at 9:00pm |
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Anyone know how this impacts clubs and classes who of course hold member data.
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Rupert
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Joined: 11 Aug 04 Location: Whitefriars sc Online Status: Offline Posts: 8956 |
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Posted: 14 May 18 at 9:12pm |
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Yes, my wife does. I didn't understand any of it. She has been briefing various committee members. As each meeting has lasted an hour or more, I'm not sure it can be summarised on here, even if I had a clue.
The RYA have a pretty good hold on it, too. |
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Firefly 2324, Puffin 229, Minisail 3446 Mirror 70686
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The Moo
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Joined: 01 Jun 06 Online Status: Offline Posts: 809 |
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Posted: 15 May 18 at 7:09am |
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Our Club came to the party a little late on this one. Our understanding is that the regulations which come into place on 25 May apply to us.
We have therefore followed the RYA guidance and have developed a policy based on their online template which will be made available to all members. We will ask them to agree to us holding and using their data for the legitimate purposes of running the Club (including photographic material for the purpose of promoting the Club). They will be asked to reaffirm their agreement each time they renew their membership. New members will be asked to agree on joining. I guess we will also have to adapt our open meeting application forms. I think this is an unintended consequence of the new regulations that they apply to small organisations such as ours but for now we seem to be stuck with it. Some on here are quick to sl*g off the RYA but to be honest their support in matters such as these is exemplary. It took us about an hour to get it all drafted so isn't quite the ball ache we thought, though getting the initial declarations back might be more so. |
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PeterG
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Joined: 12 Jan 08 Location: United Kingdom Online Status: Offline Posts: 822 |
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Posted: 15 May 18 at 8:19am |
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The RYA legal dept has done an presentation on this for clubs, which is worth looking at:
I'm involved in membership of a (non sailing) organisation. We've taken the view, which the RYA apparently supports, that provided your data is being used for legitimate membership purposes only (contact etc) then keeping basic details (excluding certain special categories) does not require explicit consent. We are producing a privacy statement (as required) which will be available to all members and which explains what we are doing and why. One point the RYA presentation makes make is that if you rely on consent then you create a lot of potential administrative difficulty. You have to keep getting it renewed, and if it isn't (people don't respond, sign the form etc) then you have an issue. Provided your uses are limited to those that can be seen as inevitable and legitimate uses of membership data it's better to avoid that route.
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Peter
Ex Cont 707 Ex Laser 189635 DY 59 |
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The Moo
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Joined: 01 Jun 06 Online Status: Offline Posts: 809 |
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Posted: 15 May 18 at 3:39pm |
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I should clarify that our Club will only be seeking consent to pass on members contact details to other club members on the Duty Rota for the purpose of arranging swaps and the use of their images in Club newsletter and other promotional material.
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Sam.Spoons
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Joined: 07 Mar 12 Location: Manchester UK Online Status: Offline Posts: 3401 |
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Posted: 15 May 18 at 4:56pm |
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The info most clubs will keep will be name and address, email and phone, and identification details of their boat. They won't be passing those onto anybody other than other members and then, most likely, only with explicit permission. My reading of the new regs is that none of that requires an opt in or a regular renewal of the permissions (I have looked into it WRT my wife's business). The only other issue is to keep the computer files containing the info secure by having it password protected or better still on a secure remote server.
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Spice 346 "Flat Broke"
Blaze 671 "supersonic soap dish" |
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turnturtle
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Joined: 05 Dec 14 Online Status: Offline Posts: 2538 |
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Posted: 15 May 18 at 6:12pm |
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AIUI GDPR is as much about the processing of information as it is the storage and collection of data for everyday business practices. As such, I wouldn’t be worried about conventional membership activity and interns member communications - keep it secure as said already. but surely the external submission of data to the RYA through personally identifiable race results for whatever unknown processing they do, is in contravention without express consent from all participants?
Even annoymised data can be traced - a sail number with class can serve as a UI field, I’ve certainly traced boat ownership lineage pretty easily through sail numbers and publicly available results in the past. It’s not that hard. |
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L123456
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Joined: 30 Apr 12 Online Status: Offline Posts: 500 |
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Posted: 16 May 18 at 11:22am |
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SO what about all the results with names and sail numbers that feature on this and club and class websites?
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jeffers
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Joined: 29 Mar 04 Location: United Kingdom Online Status: Offline Posts: 3048 |
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Posted: 16 May 18 at 11:28am |
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I would say that is down to you to request removal given the experience of GDPR that I have so far.
GDPR is more about use of your data going forward and contacting you in the future than what is already out there. |
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Paul
---------------------- D-Zero GBR 74 |
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turnturtle
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Joined: 05 Dec 14 Online Status: Offline Posts: 2538 |
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Posted: 16 May 18 at 11:46am |
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that would be my take on it too- flat html files with data tables aren't really under the scope here. But I would say there needs to be some proper professional advice for any club or event which plans to submit data to a third party who intend to 'process' that data in any way going forward. EDIT: I guess the work around is to define the race itself as the data subject, rather than the individual competitors.... but that sounds a bit shaky and I wouldn't want to test it in a legal setting with prospective penalties for compliance failure.
Edited by turnturtle - 16 May 18 at 11:54am |
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