The King’s Army Being part of the English Civil War Society
DRAFT ISSUE 1 – For approval by the Council of Warre
DATA PROTECTION PRIVACY NOTICE KING’S ARMY MEMBERSHIP AND TRAINING DATA
Overview 1. The King’s Army (KA), part of the English Civil War Society (ECWS), processes personal data on its members to further its aim through distribution to eligible members of information on events and the seventeenth century. This data is subject to legal requirements, including the Data Protection Act [Ref A] and the EU General Data Protection Regulations [Ref B]. These regulations impose strict rules about the management and protection of your personal information. This notice describes how the KA will comply with these rules.
Data Controller 2. The KA Council of Warre (acting through the Secretary of Warre and the KA Membership Secretary) is the Data Controller of data relating to all Members of all Regiments of the KA collected and held by the KA. Regimental Commanding Officers (acting through their Membership Secretaries) have this responsibility for the Members of their own Regiment. The ECWS GDPR Officer is Gary McCann who can provide guidance.
Personal Data Collected and Held 3. If you are a member of a Royalist Regiment and of the KA the personal data held by the Regiment and the KA will include some or all of the data set out below which was collected from you with your Membership Application Form including, if applicable, your Pay Pal Receipt details and cheque details. Your full Name, Regiment, Rank, Role(s) and length of service; Your contact details (Address, email address and telephone number(s)); Age, but not date of birth, if under 18; Details of subscription payment made. Copies of cheque deposit receipts, Pay Pal receipt details and equivalent receipts are destroyed after 18 months; Details of Shotgun, Firearms, Black Powder and First Aid Certificates held. 4. Some of the personal data held about you has been created by the KA and/or Regiments as part of your Membership Record or record of Training. Your membership number; Your type of membership; The date and amount of the last payment received and the method of payment. Regimental and KA Awards made to you and due dates for potential awards for length of service; Signing sheets for issue of black powder to Musketeers and Gunners with data on Certificates held. Overall KA record of Acquire and Keep Certificates and First Aid Certificates held. Records of Health & Safety and Drill training received to provide evidence of competence. Processing Personal Data 5. Processing is necessary to fulfil the commitments made to you when you joined. Personal data is processed by the Regimental and KA Membership Secretaries and by the Commanding Officers and/or Adjutants/Distribution Officers of Regiments to: Obtain subscriptions to the Regiment and the KA; Mail/e-mail Orders, newsletters and information to members; Sending other communications about the Regiment, ECWS and the KA to members; Provide access to the Member’s area of the ECWS, KA or Regimental websites and social media; Provide Check-in lists for Major Musters and Regimental events to ensure persons attending are eligible members. Manage the organisation of effective training and monitoring of the performance of KA members at events. 6. Our lawful basis under GDPR for processing your membership data is usually under Article 6(1)(b) [Ref B] “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;” 7. Occasionally we will process your data in line with our legal duties around firearms and explosives legislations under Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject”.
Storage of Personal Data 8. Personal data relating to your membership is stored on computer databases. This data is only accessible in full to the KA Membership Secretary and their deputy. A limited range relevant to each Regiment is held by the appropriate Regimental Membership Secretary, Commanding Officer, other delegated officers and distribution officers. Password protected back-up copies are stored securely off site. Hard copy personal membership data is stored in locked filing cabinets or locked room/building and computers are password protected.
Sharing of Personal Data 9. No personal membership data on any members or groups of members is shared with third parties. Data on one individual to make contact for the purposes of exchanging information may be released on receipt of a valid request to the Regimental or KA Membership Secretary by another Officer or member of the KA or Roundhead Association. Where such data is shared as detailed above, it will only share personal membership data that is relevant and proportionate to the data request being made. The King’s Army will not share personal membership data for other reasons without seeking your specific consent, unless it is to comply with a request from a lawful authority (e.g. Police, Court Order etc.) or in an emergency situation (such as where your health or safety may be at risk).
Removal of Personal Data 10. If you cease to be a member, your personal membership data will become dormant. This is because members sometimes cease their membership for a period and then re-join, so it is possible to ensure that their overall length of service record can be maintained. At your request, that data can be deleted.
Your Rights 11. You have the right to object to the King’s Army or your Regiment processing your personal membership data for any or all of the purposes set out in this Privacy Notice and may do so at any time. To exercise this right, please contact the Regiment or KA Membership Secretary giving clear details of the processing activities and/or types of personal membership data to which your objection applies. You have a right to request copies of the personal membership data held about you. To do so, please submit your request to the Regimental or KA Membership Secretaries. Should you object to the holding of your data by the Regiment or the KA, the use of your data for any or all of the above purposes, or should you wish to amend the type of communications you receive from your Regiment or the KA, or the way in which your Regiment or the KA contacts you, please inform the Regimental or KA Membership Secretary. Note however that some of the data is necessary for you to be a member, so asking for it to be deleted would require you leaving the KA.
Changes to the Privacy Notice 12. This Privacy Notice will be kept under regular review. This Privacy Notice was first produced on 13 January 2020. It will be re-issued annually.
Further Information If you have any questions which you feel have not been covered by this Privacy Notice, please do not hesitate to email or write to the ECWS Data Protection Officer, Gary McCann: 12 King St Wimborne Dorset BH21 1DY firstname.lastname@example.org
Draft Issue 1 – For approval by the KA Council of Warre 13 January 2020
A. The Data Protection Act 2018 dated 23 May 2018 B. Regulation (EU) 2016/679 dated 27 April 2016 C. Guide to the General Data Protection Regulation (GDPR) – ICO dated 22 Mar 2018 D. ECWS Guidance Notes on General Data Protection Regulation (GDPR) v3 dated 8 May 2018