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
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Dr Mike Heyworth MBE MCIfA FSA
Director, Council for British Archaeology Beatrice de Cardi House, 66 Bootham, York YO30 7BZ
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-----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
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