Virtus Rifle Club
General Data Protection Regulations
About this policy
This policy explains when and why we, Virtus Rifle Club, collect personal information about our members and how we use it; keep it secure and club member’s rights in relation to it. This includes probationary members, visitors and guests. We will collect, use and store personal data, as described in this Data Protection Policy when people engage in activities at the club. Normally this will be through some level of membership.
We reserve the right to amend this Data Protection Policy from time to time without prior notice. You are advised to check our Club Website https://virtusrifleclub.co.uk/ regularly for any amendments. We will only share your personal data with any third parties as outlined below.
We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (ico.org.uk).
For the purposes of the GDPR, The Club Secretary will be the “controller” of all personal data we hold about club members and others. The Secretary is responsible for making sure the club complies with the General Data Protection Regulation (GDPR) which applies from 25 May 2018. We will review personal data every year to establish whether we are still entitled to process it or not.
You have rights under the GDPR:
- To access your personal data
- To be provided with information about how your personal data is processed
- To have your personal data corrected
- To have your personal data erased in certain circumstances
- To object to or restrict how your personal data is processed in certain circumstances
For more details, please address any questions, comments and requests regarding our data processing practices to the Secretary.
Specific use and sharing of personal information
Your personal data (name, address, date of birth) will be used to notify the Police when you join the club and for any appropriate notifications as required by law. In general your personal data will only be used for the purposes of membership management (renewals etc.) and your email and telephone numbers may be used for communication about news/work at the club/range closure, competition entries/results and other important notices etc. Your name/address and email address may be shared with our current National Governing Body (NRA). Your personal data will not be passed to anyone else outside the club and your email will only be given to someone outside the club with your permission.
The Lawful reasons for processing your data.
We have three lawful reasons for processing your data, which are:
(a) Processing is necessary for compliance with our legal obligation (Firearm Amendment Act 1988 c.45 Exemptions Section 15 – Firearms clubs
(b) Processing of your data is necessary for the administration of your membership contract.
(c) You have given consent to the processing of your data by signing our declaration statement for the specific purposes set out in this policy.
The tables below give further explanation of which lawful reason applies to which data, why we collect it and who we may be required to share it with. The club will make every effort to ensure data is only shared with organisations that are GDPR compliant.
What Information we collect, why we collect it, and who we share it with
In addition to the reasons stated below we may have to disclose your data where we have an inescapable legal obligation.
Data processed under our legal obligation
Requirements of Home Office Approval
The club is a Home Office Approved Rifle Club. This means that the club will
- Appoint a Police Liaison Officer – currently the Chairman
- Maintain a register of attendance of all members with details of the firearm used
- Inform the Police of any person other than a guest member who has ceased to be a member for whatever reason
- Inform the Police of any person other than a guest who has not shot at the club for a period of 12 months
- Inform the Police of any application for membership giving the applicant’s full name and address, date and place of birth and the date on which they became a member
Please note data processed for compliance with the Firearm Amendment Act 1988 must be kept for 6 years from the end of your membership and is therefore exempt for your right to erasure under GDPR.
Data processed as a requirement of managing your membership
Please note data processed for compliance with insurance purposes must be kept for 30 years from the end of your membership and is therefore exempt for your right to erasure under GDPR.
Data processed with your consent
The club will seek consent in the application form before processing any information as outlined below.
The club may be asked to share personal information we process about an individual and the name, address and email address with an appropriate National Governing Body (NGB). These include NRA, Home Office, MOD.
Enquiries and other communications with the club
When enquiring about the club we may hold your details for a period of time to deal with the enquiry. Any emails and other communications with the club will only be retained for a period of time appropriate to the content or request. Club emails will be purged on a regular basis. People added to a club waiting list for membership will be informed and asked for permission to store that data at that point.
Parents or guardians signing the probationary or full membership form are giving their permission for the data to be used as described elsewhere in this policy.
How we protect your personal data
The Data Controller will process membership information electronically and hold all information on a database in the cloud which is secured by 2 Factor Authentication. Paper copies of data will be held at the secretary’s house and secured by a locked Firearms cabinet. If it is necessary to transport data it will be kept secure by way of encryption.
Coaches and instructors will also process and hold information pertaining to people under their instruction and necessary information will be made available to coaches and instructors only as required, this is limited to Name, Email address, Phone Number, Photo and qualifications and will be stored in the cloud via 2 Factor Authentication.
For any on-line payments which we take from members, probationers, visitors and guests we will use a recognised online secure payment system.
In the unlikely event of a breach of the security of data we will notify members promptly and we will never sell or pass on your personal data.
Request to see your personal information
Accuracy and retention of data
Each individual member is responsible for keeping the Secretary informed of changes to their data (e.g. address/telephone number etc. and this is updated at least once a year at renewal and you are at that time authorising the club to hold such data on file.
The data is kept on file at the Secretary’s home address and in a secure area in the cloud. The data will be normally be kept for up to 6 years from the end of your membership. It may be kept for a longer period for reasons of legal and civil action or other ongoing case management. Name, address and length of membership will be kept for up to 30 years for management of historical insurance claims. Names and scores may be kept indefinitely for reason of historical significance – e.g. on trophies, plaques and other awards.