Privacy Policy

121 Technology Ltd and the Rotary Club of Conwy (“we”/”us”/”club”) promise to respect the confidentiality of any personal data you share with us, or that we have access to through the Template Website System, or Rotary International (RI) (including The Rotary Foundation [TRF]), to keep it safe, and we will always take every effort to protect your privacy. [For the purpose of this privacy notice, Rotary Club of Conwy also includes Rotary Club of Conwy Trust Fund]

We pride ourselves on our honesty and openness and will always be clear how, when and why we collect and process your information; we promise we will never do anything with your details that you wouldn’t reasonably expect.

Developing a better understanding of our members and donors is crucial, and your personal data allows us to manage your membership and provide the services to which you are entitled.

It is expected that club members may also process member personal data on behalf of the club and the Rotary organisation and they too will also be bound by this privacy notice.  RI (website: www.rotary.org) may also process member personal data in accordance with their privacy notices published on their respective websites. 

We collect information in the following ways:

When you give it to us DIRECTLY

There are many ways you may give us your information. For example, when you join as a member, begin volunteering, make a donation, purchase our products or communicate with us either by phone, email or in person. We are responsible for your data at all times.

When you give it to us INDIRECTLY

Your information may be shared with us by independent organisations, for example sites like Virgin Money Giving or BT MyDonate or other such services. These independent third parties will only share your information when you have consented. You should check their Privacy Notice when you provide your information to understand fully how they will process your data.

Via Social Media

Depending on your settings or the privacy notices for social media and messaging services like Facebook, WhatsApp, LinkedIn or Twitter, etc., you might give us permission to access information from those accounts or services.

Via information available publicly

This may include information found in places such as websites (club, district, action groups etc), Companies House and information that has been published in articles/newspapers.

What personal information we collect and how we use it 

We will only ever capture the minimum amount of information that we need to in relation to your membership, donation or services we provide to you and we promise to keep your information secure. The personal data we may collect includes:

· Your name

· Your contact details (address, email and telephone number as appropriate)

· Your date of birth

· Gender

· Details of the enquiry, service or product

Where it is appropriate, we may also ask for additional information, and this will be made clear to you at the time the personal information is requested.

How we will use your data

We will use your personal data for the legitimate interest of conducting core club or district activities, these will include:

· Provide you with the website services, products or information you would reasonably expect to receive as part of your membership or enquiry.

· Communicating organisational messages and information to members, district and club officers, and with their consent, non-members and friends of the club.

· Supporting The Rotary Foundation (TRF)

· Providing information and updates to club members on RI programmes and service projects

· Appointments to club and district offices, committees, task forces and other assignments within the Rotary organisation

· To present our website and its contents to you and to allow you to participate in interactive features on our website

· Keep a record of your relationship with the club and within the Rotary organisation

· Understand how we can improve our services, products or information

· In any other way we may describe when you provide the information

· For any other purposes with your consent

Sensitive information

We do not collect any personal information on members classified as ‘sensitive’ under GDPR. For example, information about an individual’s: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation.

Interact, Rotakids and under 18’s data

We do not collect information from under 18’s. 

Data Sharing

1) Our service/host providers

In the course of our legitimate club activities, there may be a need for us to share, or give access to, your personal data to third parties that provide us with services or host our applications/software that you may access, for instance:

· Rotary International, including TRF

· Template Designer (Chris Sweeney, Rotary Club of Conwy & 121 Technology Ltd)

· Heart Internet – our Template database secure hosting service provider

We will ensure that data processing agreements, compliant to GDPR, are in place before sharing with, or giving access to, your data with any of our service/host providers outside of the Rotary organisation.

2) Sharing within the Rotary organisation

The Rotary organisation is made up of Rotary International, The Rotary Foundation (TRF).

When you give information to us it may be shared within the wider organisation to facilitate your membership or donations and to provide the service afforded to you as part of that membership/donation.

On occasion, the club may collect personal data for our individual activities (such as an event requiring personal information for registration) and are therefore independent data controllers. The club may also act as a data processor for some of your personal information associated with your membership via the Template. This means that we are also responsible for protecting your data under GDPR legislation whilst it is in our safekeeping and we will process your data in accordance with the privacy notices of the club as appropriate.

3) Sharing with third parties

We will never commercially sell your personal data to anyone else.

We will only ever share your personal data in other circumstances, not listed above, if we have your explicit and informed consent at the time of collection.

However, we may need to disclose your details if required to by the police, other agencies, for example HMRC, regulatory bodies or our legal advisors.

How we keep your information safe and who has access to it

We ensure that there are appropriate physical and technical controls in place to protect your personal details and we work within good practice, for example, confidential paper records are securely stored, or securely disposed of as appropriate. The club and its members ensure that PCs/devices holding personal information on behalf of the club are protected with appropriate anti-virus and malware protection and this is routinely monitored by the club.

We undertake regular reviews of who has access to information that we hold to ensure that your personal information is only accessible by appropriate members, Rotary officers, Rotary staff and members and our service/host providers. We do comprehensive checks on the companies we use before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they may have access to as part of providing those services.

We have a duty to report certain types of personal data breaches to the relevant supervisory authority, and where feasible, we will do this within 72 hours of becoming aware of the breach. If a breach is detected and likely to result in a high risk of adversely affecting you, we will inform you without undue delay.

Where we store your information:

The club may hold your information in various ways depending on your relationship with us, for instance:

· Members’ personal information is stored via the Template and in some instances may held by individual club officers or members for the purpose of specific club activities.

· As a ‘friend of this Rotary club’, with your consent, your personal information may be stored on theTemplate System and in some instances may be held by individual club officers or members for the purpose of specific club activities.

· As a non-member of Rotary, with your consent, your personal information will be held by individual club officers or members for the purpose of specific club activities.

Your personal information held on the Template System will be held securely within the UK or the EU by 121 Technology Ltd and their secure hosting service provider.

How long we retain your information and how we keep it up to date

We will only keep your information for as long as we need it to assist you with your enquiry, process your membership, with either membership of this club, volunteering, any enquiry you make to us, donations, event registrations or other services as part of your membership, club activity or as requested by you. There are statutory timescales on how long we should keep your information, for example, gift aid transactions must be retained indefinitely, financial records must be kept for 7 years, information associated with Health & Safety can be retained for up to three years after an event etc. We shall delete your information according to these statutory limits, or according to guidance issued by the Information Commissioner, or guidance issued at the time the personal information is collected.

Individual members are responsible for keeping their own personal information up to date and have access to the self-service systems within the Template System. Relevant officers of this club (such as club administrator) can also assist you in keeping your information up to date. In addition, where necessary, we will keep your information accurate and up-to-date.

Non-members of Rotary (including ‘friends of this club’) should also keep their personal information held by the club up to date and you can do this via the club administrator.

Your rights

The General Data Protection Regulations gives you certain rights and these are listed below for your convenience, further clarification of your rights is available on the Information Commissioners website:

· You have a right to be informed when your personal data is being collected, what is collected and how it will be used or shared.

· You have a right of access to your personal data: the right of access allows you to be aware of and verify the lawfulness of the processing of your personal data. Members and donors have access to their personal data via self-service systems such as the RIBI Data Management System (DMS) or My Rotary via the RI website. You can also request a copy of the information which we hold on you. This information will be provided free of charge, unless the request is found to be manifestly unfounded or excessive then a reasonable fee will be charged. The application should be made in writing, by letter or email, and addressed to the club, contact details shown below, enclosing two proofs of identification. Applicants should be aware that where requests are manifestly unfounded or excessive, in particular because they are repetitive, the club can:
- charge a reasonable fee taking into account the administrative costs of providing the information; or
- refuse to respond.

· You have a right in certain circumstances to have inaccurate personal data rectified, blocked (restrict processing), erased (right to be forgotten), or destroyed.

· You have a right in certain circumstances to object to the processing of your personal data for such reasons as direct marketing, automated decision making, profiling; although we can confirm we make no decisions on you using an automated process.

· You have a right in certain circumstances to data portability.

In certain situations, these rights may not apply, for example if you are a valid member we will need to communicate with you about your membership and those services afforded to you as part of that membership; you hold a club or district office and we need to communicate with you in relation to that office, in which case you will not be able to unsubscribe from certain communications.

We collect and process your personal data through legitimate interests or because you have provided it to us to enable us to deliver a service to you. We will only process your personal data as you would reasonably expect us to. You can opt out of general member mailings at any time.

Finally, if you are unhappy with how we have processed your information, you have the right to lodge a complaint with the Office of the Information Commissioner, contact details below.

Changes to this privacy notice

We may change this privacy Notice from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on our website or by notifying you directly.

Our contact details

121 Technology Ltd

Email: info@121technology.com

Complaints

If you are unhappy with how we have processed your personal information, please firstly contact the club,  details above. If you are still unhappy you may contact the following:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF


Helpline: 0303 123 1113 (local rate) or ++44 1625 545 745

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