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Again, very helpful - but when does their membership lapse? When they breach the contract by forgetting to pay or when the club strikes them out after chasing them a 'reasonable' amount. Chris Webster Somerset Historic Environment Record Somerset Heritage Centre Brunel Way Taunton TA2 6SF 01823 347434 Online HER: www.somersetheritage.org.uk The Somerset HER is managed for Somerset County Council by the South West Heritage Trust. -----Original Message----- From: Issues related to Historic Environment Records [mailto:[log in to unmask]] On Behalf Of Mike Heyworth Sent: 19 January 2018 15:28 To: [log in to unmask] Subject: Re: General Data Protection Regulations (GDPR) Without wishing to add to the general confusion in this area, as we all find our feet with the new regulations, I would just add to the comments from Chris below when he says: "The member has a contract with the club to supply membership benefits in return for subscription fees, so my reading is that consent is not needed." The advice we have received is that this only works whilst the contract is in place, ie whilst the individual is a member. As soon as their membership lapses this is no longer the case and you cannot assume that you can chase them up to encourage them to renew unless you have their specific permission to do so - though it might be possible to include this in a specific new membership contract which societies might introduce ... Mike -- Dr Mike Heyworth MBE MCIfA FSA Director, Council for British Archaeology Beatrice de Cardi House, 66 Bootham, York YO30 7BZ E: [log in to unmask] W: http://archaeologyUK.org T: +44 (0) 1904 671417 M: +44 (0) 7793 817510 Twitter: @mikeheyworth -- The CBA is a registered charity in England & Wales (287815) & a charity registered in Scotland (SC041971). It is also a Company Limited by Guarantee 1760254 Join us at http://new.archaeologyuk.org/join-us-today/ -----Original Message----- From: Issues related to Historic Environment Records [mailto:[log in to unmask]] On Behalf Of Chris Webster Sent: 19 January 2018 14:36 To: [log in to unmask] Subject: Re: General Data Protection Regulations (GDPR) That's really useful stuff, Ed. The information commissioner's blog is very helpful and to return (briefly, I hope) to the question of membership clubs, I think that consent (which is only one of the ways to lawfully process personal data) will not be required as data processing will be covered by Article 6.1 (b) of the regulations: Article 6 1 Processing shall be lawful only if and to the extent that at least one of the following applies: [...] (b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [...] The member has a contract with the club to supply membership benefits in return for subscription fees, so my reading is that consent is not needed. Phew! (?) Chris Webster Somerset Historic Environment Record Somerset Heritage Centre Brunel Way Taunton TA2 6SF 01823 347434 Online HER: www.somersetheritage.org.uk The Somerset HER is managed for Somerset County Council by the South West Heritage Trust. -----Original Message----- From: Issues related to Historic Environment Records [mailto:[log in to unmask]] On Behalf Of Edmund Lee Sent: 19 January 2018 14:08 To: [log in to unmask] Subject: Re: General Data Protection Regulations (GDPR) Hello all, You will, needless to say have to go with your local organisations advice on this, but it may well be worth, before planning to do extensive trawling of records, getting some further advice, for example from the Local Government Association, which can be found at https://www.local.gov.uk/our-support/general-data-protection-regulation-gdpr All the best Ed Historic England [https://themuseumofsomerset.files.wordpress.com/2017/05/swht-green-e-sig.jpg]<http:www.swheritage.org.uk/> We are a charity supported by Somerset and Devon County Councils and other generous funders South West Heritage is a charity and a company limited by guarantee registered in England. Registered office: Somerset Heritage Centre, Brunel Way, Norton Fitzwarren, Taunton, Somerset TA2 6SF. Company number: 09053532 Charity Number: 1158791 VAT Registration Number: 197221592 Disclaimer This email communication along with any attachments is intended for the person(s) it is addressed to only. The communication is not legally binding, nor is it a contractual commitment on behalf of the South West Heritage Trust. We make every effort to keep our network free of malicious software and take no responsibility for any malware, virus or other damaging files transmitted via this communication. South West Heritage Trust <http://www.swheritage.org.uk>