1. Introduction
1.1. The Russian Black Terrier Club is
committed to protecting your personal information and respecting your privacy.
1.2. This Privacy Notice sets out the basis
on which any personal data that we collect from or about you, or that you
provide to us, will be processed by us.
1.3. For the purpose of the UK General Data
Protection Regulation [the UK GDPR] and the Data Protection Act 2018 [DPA], the
data controller is the Russian Black Terrier Club (also referred to as RBT Club, we, us or our within this Privacy Notice)
1.4. We may update this Privacy Notice from
time to time. Please check back regularly to see any updates or changes to this
Notice.
2. Data Protection Contact
2.1. The contact for any data protection
queries is our Honorary Secretary:
Email: secretary@rbtclub.uk Tel: +44 (0)7831 112433
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly
explained to you and not used in any way that is incompatible with those
purposes.
3. Relevant to the purposes we have told you about and limited
only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told
you about.
6. Kept securely.
4. Particulars of processing
4.1. We process personal data about prospective members, members, show sponsors, judges, ring stewards and exhibitors to our events. The categories of person about whom we process personal data are described in more detail in the Annex to this Privacy Notice.
5. Your rights as a data subject
5.1. The UK GDPR/DPA provides the following
rights (subject to some exemptions):
5.1.1. The right to request access to the
personal data that we hold about you;
5.1.2. The right to request rectification of
the personal data that we hold about you;
5.1.3. The right to request erasure of the
personal data that we hold about you;
5.1.4. The right to request restriction of
processing about you;
5.1.5. The right to object to processing; and
5.1.6. The right to data portability.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Honorary Secretary using the contact details set out in Section 2 above.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO) full contact details for which can be found at https://ico.org.uk/global/contact-us/
6. How we will use information about you
We will only use your personal information when the law allows
us to.
Most commonly, we will use your personal information in the following
circumstances:
1. Where we need to perform the contract we have entered into
with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those
of a third party) and your interests and fundamental rights do not override
those interests.
We may also use your personal information in the following
situations, which are likely to be rare:
1. Where we need to protect your interests or someone else's
interests.
2. Where it is needed in the public interest or for official
purposes.
6.1 We will generally process your personal data for contractual necessity in
providing membership services and events.
We may also use personal information for additional relevant and related
purposes where you might reasonably expect us to do so, where the benefits of
doing so are not outweighed by your own interests or fundamental rights or
freedoms. This may include:
6.1.1. To maintain our records and other
administrative purposes, including updating your details and preferences;
6.1.2. To assist with queries, complaints and
dispute resolution;
6.1.3. To communicate with members regarding membership
and invitations to participate in canine market research or canine health
studies;
6.1.4. To assist with upholding the Club
constitution and taking action in cases where there may be a breach of the Club
Rules or Code of Ethics.
6.2 We will ask for your direct consent if we intend to use your personal data for marketing purposes. Where our processing of personal data is based on your having given consent, you have the right as a data subject to withdraw that consent at any time. If you wish to invoke this right, please notify the Honorary Secretary using the contact details set out in Section 2 above.
6.3 You have the right to lodge a complaint with a supervisory authority. In the United Kingdom, the supervisory authority is the Office of the Information Commissioner, full contact details for which can be found at https://ico.org.uk/global/contact-us/
7. Recipients of Data
7.1 We may use service providers to help
us provide you with our services. Personal data may be transferred to such
service provider, who act for or on our behalf, for further processing in
accordance with the purpose(s) for which the data was originally collected or
may otherwise be lawfully processed.
7.2 Such third parties have contracted
with us as data processors under the requirements in the GDPR. They are
contractually bound to only use personal data for the agreed purpose(s).
Relevant persons working for these third parties will have access to your personal
data under the terms of the data processor contract, but only to the extent
necessary to perform their services for us.
7.3 These data processors agree to
implement reasonable contractual and technical protections, to keep your data
confidential, not sell your personal data to third parties and to not disclose
your personal data to third parties except as may be required by law, as
permitted by us or as stated in this Privacy Policy.
7.4 In appropriate circumstances we may
disclose data to authorised bodies as required by law.
8. Visitors to Russian Black Terrier Club websites
8.1 We do not use cookies to monitor how people use our websites.
9. Contact details
9.1 Please contact the Honorary Secretary (see Paragraph 2.1) if you have any questions or concerns about personal data and privacy matters.
ANNEX
This Annex sets out the Russian Black Terrier Club’s processing of personal data relating to members (including officers and committee members), judges and exhibitors/competitors at our events.
What personal data do we process, why do we process it and what is the lawful basis?
Members
· Name
· Address
· Email address
· Telephone number
We process your personal data for the following purposes:
· Provision of membership services including administration and
transactional
communications relating to membership Contractual
Necessity
· Upholding the RBT Club Rules and Code of Ethics Contractual
Necessity
· Compliance
with Kennel Club Rules and Regulations Contractual
Necessity
· Contact you
regarding an event or meeting for which you have requested
information or submitted an
entry form (e.g. by phone or email) Contractual
Necessity
· Contacting
you regarding newsletters, invitations and information about
club events,
dog shows and meetings Legitimate
Interests
· To
communicate with all members regarding membership matters,
Club matters and
Club activities and services. Legitimate
Interests
· Publication
of information other than names on our website or social media pages
such as
Facebook (for Committee Members) Consent
· Contacting
you by email to provide related information and/or
information / marketing
communications. Consent
Judges
· Name
· Address
· Email address
· Telephone number
We process your personal data for the following purposes:
· Administration
and transactional communications relating to judging appointments Contractual Necessity
· Upholding the
Club/Society Rules and Code of Ethics Contractual Necessity
· Compliance
with Kennel Club Rules and Regulations (including sharing relevant
required
information) Contractual Necessity
· Publication
in the RBT Club judges’ list and for appointments in the show/event
schedules. Legitimate Interests
· Providing
appropriate information (contact details/breed assessment/status) to the Breed Education Co-ordinator in order for them to carry out their role in
overseeing the breed’s programme for educating its judges under the JCF/JEP. Legitimate Interests
Exhibitors/Competitors
· Name
· Address
· Email address
· Telephone number
· Dog information
We process your personal data for the following purposes:
· Administration
and transactional communications for exhibitors/competitors
entering our events Contractual Necessity
· Provision of
services relating to our events Contractual Necessity
· Upholding the
Club/Society Rules and Code of Ethics Contractual Necessity
· Compliance
with Kennel Club Rules and Regulations
· Contacting
you regarding future events Legitimate Interests
· Publication
of your name address and dog information in show/event catalogue
(subject
to the right to object) Legitimate Interests
· Publication
of event results on our website, social media pages, or in Our Dogs Legitimate Interests
We also process personal data for the Russian Black Terrier Club’s legitimate
interests as outlined in the main Privacy Notice (paragraph 4.1). Please be
assured that we will always take account of your personal data rights in doing
so.
Where do we obtain your personal data from?
Most of the above personal data is received direct from you (the data subject). However, information may be received from third parties (e.g. Fosse Data).
How long do we hold your personal data for?
Personal data will be retained in accordance with statutory requirements, Kennel Club requirements and recommendations and the RBT Club’s data retention policy.
Are you obliged to provide us with your personal data?
You are not obliged to provide the personal data in question. However, if you do not provide the personal data, we will be unable to perform any contract we have with you for the provision of membership services, judging appointments or event services.
Recipients of your personal data
We disclose data to the following outsourced data processors, in line with Section 5 of our main Privacy Policy:
MailChimp:
We use MailChimp to manage our member mailing list and for storing
communication preferences. Please see the RBT Club’s MailChimp Privacy Notice for details.
Royal Kennel Club Records
The Royal Kennel Club will hold the personal data of officers and committee members of the Russian
Black Terrier Club as a part of the implementation of Royal Kennel Club Rules
and Regulations.
We provide the Royal Kennel Club with
details of Russian Black Terrier Club officers and committee members in order to meet the requirements
of the the Kennel Club Rules and Regulations.
Fosse Data Systems
We employ Fosse Data to manage entries and documentation to our Open
and Limited Club shows and to print and publish online show schedules,
catalogues and results. The RBT Club may provide judge and exhibitor personal
data to Fosse Data in order for them to fulfil their role.
Breed Education Co-ordinator
We provide appropriate information regarding judges (contact details/breed
assessment/status) to the Russian Black Terrier Club’s Breed Education
Co-ordinator in order for them to fulfil their role in overseeing the RBT Club’s
programme for educating judges under the JCF/JEP.
Breed Health Co-ordinator
We provide appropriate information (contact
details) to the Russian Black Terrier Club’s Breed Health Co-ordinator in order
for them to fulfil their role.
Do we use your data for any automated decision-making?
No personal data is processed for
automated decision-making
Any financial data arising from a transactional process will be held securely by the Russian Black Terrier Club in accordance and compliance with all statutory and HMRC requirements.
Links to Third-party Privacy Policies:
Facebook: www.facebook.com/about/privacy/update
Fosse Data Systems: www.fossedata.co.uk/help/privacy.html.
MailChimp: https://mailchimp.com/legal/privacy
Our Dogs: www.ourdogs.co.uk/privacy/
Royal Kennel Club / Judges Critiques: www.theroyalkennelclub.org.uk/privacy-policy/