Background
Data is defined as any piece of personal information that can be used to identify an individual, either directly or indirectly. An organisation must ensure that all personal data is:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Item (a) states that the Guild and the Bell Fund must have a lawful purpose for the holding or processing of data. The GDPR specifies six categories that constitute a lawful purpose, the most relevant ones for the Guild and the Bell Fund being:
- Consent has been provided to hold or process the data;
- Holding / processing the data is necessary for the execution of a contract, or steps taken in anticipation of the execution of a contract
- There is a legal obligation to hold or process data; and
- The processing is necessary for the “Legitimate purposes” of the Guild or the Bell Fund.
Policy
The table sets out the data held and processed by the Guild and the Bell Fund. The Officers of the Guild and those of the Bell Fund consider the current consents held are sufficient to meet the requirements of the GDPR. The accuracy of data held and any consent provided will be verified at least once in every 5- year period.
The GDPR provides individuals certain rights surrounding their data:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Detail behind these rights may be obtained from the Information Commissioner’s Office or from their website. To request access, rectification or erasure of data, please contact, for matters concerning the Guild, the Guild Membership Secretary with copy to the Guild General Secretary and Guild Chairman (details found here), or for matters concerning the Bell Fund, the Bell Fund Secretary with copy to the Bell Fund Trustees (details found here).
Communication
From time to time, members of the Guild, District or Bell Fund committees will communicate with members, either directly or via tower representatives. Such communications will include notification of Guild or District events and meetings, wider ringing related news, or bell-ringing events that may interest members.
When emails are sent to multiple members, they will be either “blind carbon copied” (bcc’d) or a dedicated mailing list used, so as not to reveal a member’s email address to another member.
The Guild may set up electronic mailing lists to facilitate the sending of communications to committees, subcommittees, tower contacts, members or other groups. These mailing lists may be hosted by a third- party supplier. It will be ensured that the supplier has a suitable DP policy ahead its use.
Storage of data
Data may be held or processed using manual or electronic storage methods. When electronic storage methods are used, care is taken (such as maintaining up-to-date virus and firewall protection) to prevent data loss. To the extent that sensitive personal data is held, files will additionally be password protected. Electronic data is backed up regularly (with the previous backup being then deleted) and held on a different machine or location to enable restoration if the primary place of storage becomes
permanently inaccessible.
This version is as adopted by:
- the Management Committee of the Guild: November 2018
- the Trustees of the Bell Fund: January 2019
All information provided will only be used for ringing purposes and no commercial use will be made of the information provided.
- All adult Guild members are required to complete a Data Protection form. This may be in the format of a tower submission or an individual form.
- For all Guild members aged 12 or under, a parent or guardian must complete an individual form.
- Guild members who are district or Guild officers should, in addition, complete an officer form.
- Tower contacts should complete a tower correspondent form.
- The appendix to the above forms can be found here.
Please complete the appropriate form to confirm your consent to your personal data being processed as necessary for the purposes of the legitimate interests of the Guild.
Please ensure your completed and signed form is sent to your District Secretary; this may be done by post or by email attaching an image of the completed form.
If you wish to obtain a copy of the data held, a description of the purposes for which it is being processed, description of any potential recipients, or any information as to the source of the data, please contact the Honorary General Secretary of the Southwell and Nottingham Diocesan Guild of Church Bell Ringers. Please note that the Guild may charge a fee of £10 for the provision of this information. This fee may be amended from time to time at the discretion of the Guild Committee and with regard to the prevailing legislation at that time.