Networking Cupper Privacy Policy

 

 

Networking Cupper Privacy Policy

 

  1. INTERPRETATION

1.1  DEFINITIONS:  

Association name:  The Networking Cupper Association

Association Personnel:  all executive committee members, committee members and others.

Consent:  agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to them.

Controller:  the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

Data Subject:  a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

General Data Protection Regulation (GDPR):  the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.

Personal Data:  any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access.

Personal Data Breach:  any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Processing or Process:  any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

  1. INTRODUCTION

This Privacy Standard sets out how The Networking Cupper Association (”we”, “our”, “us”, “the Association”) will handle the Personal Data of our customers, suppliers, members, and other third parties.

This Privacy Standard applies to all Personal Data we process regardless of the media on which that data is stored or whether it relates to any Data Subject.

  1. SCOPE

    We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations.

  1. PERSONAL DATA PROTECTION PRINCIPLES

    We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

(a)  Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).

(b)  Collected only for specified, explicit and legitimate purposes (Purpose Limitation).

(c)  Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).

(d)  Accurate and where necessary kept up to date (Accuracy).

(e)  Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).

(f)  Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).

(g)  Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).

(h)  Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).

  1. CONSENT

As Data Controller we will only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR, which include Consent.

 A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing.

Data Subjects can withdraw their Consent to Processing at any time by writing to the President of the Association.

Upon receipt of any such withdrawal will be promptly honoured and the Data Subject informed of the timescales at appropriate time.

  1. PURPOSE LIMITATION

    Personal Data is collected only for the specified, explicit reasons at the time of collection.  

Personal Data will not be further Processed in any manner incompatible with those purposes unless we have informed the Data Subject of the new purposes and they have Consented where necessary.

  1. DATA MINIMISATION

We will ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised.

  1. ACCURACY

    We will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. We will check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

  1. STORAGE LIMITATION

We will not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

We will regularly review Personal Data that we hold to determine the above.

We will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require This includes requiring third parties to delete such data where applicable

  1. SECURITY INTEGRITY AND CONFIDENTIALITY

 

10.1  PROTECTING PERSONAL DATA  

   Personal Data is secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We will only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

We will maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

(a)  Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.

(b)  Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.

(c)  Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

10.2  REPORTING A PERSONAL DATA BREACH  

We will notify any Personal Data Breach to the applicable regulatory and, in certain instances, the Data Subject. where we are legally required to do so.

  1. DATA SUBJECT’S RIGHTS AND REQUESTS

    Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

(a)  withdraw Consent to Processing at any time;

(b)  receive certain information about the Data Controller’s Processing activities;

(c)  request access to their Personal Data that we hold;

(d)  prevent our use of their Personal Data for direct marketing purposes;

(e)  ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;

(f)  restrict Processing in specific circumstances;

(g)  challenge Processing which has been justified on the basis of our legitimate interests or in the public interest.

(h)  request a copy of an agreement under which Personal Data is transferred outside of the EEA;

(i)  object to decisions based solely on Automated Processing, including profiling (ADM);

(j)  prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;

(k)  be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;

(l)  make a complaint to the supervisory authority; and

(m)  in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable format.

We will verify the identity of an individual requesting data under any of the rights listed above

Any Data Subject request must be sent to the President of the Association and we will respond in the time allowed. 

  1. DIRECT MARKETING

We will ensure that a Data Subject’s prior consent is required for electronic direct marketing (for example, by email or what’s app messaging).

 We will offer the right to object on direct marketing to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

    A Data Subject’s objection to direct marketing will be promptly honoured. If a customer opts out at any time, we will suppress their details as soon as possible.

14  SHARING PERSONAL DATA  

    We will only share the Personal Data we hold with third parties, such as (but not limited to) MailChimp, Dropbox where

(a)  they have a need to know the information for the purposes of providing the Association services;

(b)  sharing the Personal Data complies with this Privacy Notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;

(c)  the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;

  1. CHANGES TO THIS PRIVACY STANDARD

    We reserve the right to change this Privacy Standard at any time so please check back regularly to obtain the latest copy of this Privacy Standard. We last revised this Privacy Standard on 22 May 2018