The Hurlingham Club is committed to protecting and respecting your privacy. We take our responsibilities seriously and will only use the personal data we hold in accordance with the law.
This Privacy Notice sets out the basis on which your personal data will be collected, handled, stored and shared by us. Please read the following to understand what we do with your information.
This Policy is effective from 23 May 2018.
1 Personal data we may collect from you
We may collect and hold a range of different information that you have provided us about you as a Member of the Club. This allows us to provide the services of the Club and keep in contact with you.
This information may include:
- Date of birth;
- Home address (and second address);
- Telephone (home, office and mobile);
- Email (personal and work);
- Details of spouse/partner/dependents
- Bank account details;
- Employment; and
- Date elected to membership.
- CCTV footage if you visit the Club
As a Club, we may need to process special category personal data, for example, concerning health of our Members or staff. We do so in accordance with applicable law (including with respect to safeguarding or employment) or by explicit consent.
2 How we use your information
We use your information to provide the services offered by the Club. These include (but are not limited to):
- Administrating your Club membership, including membership category changes and issuance of membership cards
- Sending you an annual invoice and collecting your subscriptions by Direct Debit
- Facilitating bookings of meals, rooms and sporting facilities;
- Contacting other members of the Club on your behalf when you request it;
- Circulating information about the Club;
- Organising sports and social events; and
- Organising external events.
- Administering and maintaining membership records
- Processing payments and maintaining accounts.
- Ensuring the security of staff, members and their guests while on Club grounds.
- Tracking member and guest visits to the Club during the COVID-19 pandemic in line with government guidance
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of the Information. Our security procedures mean that we may occasionally request proof of identity before we disclose the Information to you.
4 How we share your information
4.1 Third parties
We provide information to selected third parties, in order for them to supply services to us in relation to your membership of the Club.
Such third parties may include (but are not limited to) the following:
- a) Reciprocal clubs, in order to facilitate introductions that you request;
- b) Selected suppliers of products and services to the Club
- c) Government or national bodies requesting information acting in line with the government response to the COVID-19 pandemic
The Club can provide details on request of any third parties that process your data.
We will never share your personal information with third parties who intend to use it to send marketing content to you.
4.2 Disclosures and security
We will only share your personal information with third parties that have provided sufficient guarantees in respect of their data security measures. We require all third party contractors to demonstrate the same security measures that the Club would have to take if we were doing the processing.
During the COVID-19 pandemic the Club will provide information to government or national bodies acting in line with the government response to the COVID-19 pandemic without requiring them to demonstrate security measures, under the assumption that they will act in accordance with UK law.
4.3 Transfers abroad
We will only transfer your personal information to third parties based in countries outside the European Union (‘third countries’) in very limited circumstances. These include transfers to other clubs for the purposes described in Section 4.1 above where those clubs are based abroad.
We will also only transfer your personal information to third parties when the organisation receiving your information has provided adequate safeguards to ensure your data is protected. These are likely to comprise standard data protection clauses in the form of template transfer clauses adopted or approved by the European Commission.
5 The legal bases for processing your personal data
The GDPR sets out a number of different legal basis under which an organisation may collect and process your data. We rely on the following legal bases:
- In specific situations, we will collect and process your information with your consent. We will always make it clear to you what you are consenting to and what information is necessary for which services.
- In certain circumstances, we need your information to carry out our contractual obligations.
- If we are required to by law, we may need to collect and process your information.
- In specific situations, we require your information to pursue our legitimate interests in a way which you might reasonably expect as part of running our membership organisation and providing the services of the Club, and which will not materially impact your rights, freedoms or interests.
In the case of special category data, we will seek your explicit consent in line with our obligations under the GDPR.
6 Your Rights
The GDPR, which applies as of 25 May 2018, gives you certain rights over your personal information:
- Right to access the Information;
- Right to have the Information kept up to date;
- Right to have the Information erased;
- Right to restrict our processing of the Information;
- Right to have the Information transferred from us to another organisation; and
- Right to object to our processing of the Information.
- Right to lodge a complaint concerning protection of the Information with the Information Commissioner’s Office.
You can submit a request to exercise any of these rights in accordance with the GDPR. It will be free of charge, except where we deem it unfounded or excessive.
A fuller explanation of each of these rights, and the formal request procedure, is available on request.
7 Changes to our Privacy Notice
The Club may update this Privacy Notice as appropriate. We will never materially change our policies or procedures to make them less protective of personal information collected in the past. It is your responsibility to check this page from time to time to ensure that you are happy with our current Privacy Notice.
8 Contact us
If you have any questions, comments or concerns regarding this Privacy Notice or the way we handle your personal data, or wish to make any requests, please address these to:
The Hurlingham Club
London SW6 3PR