How BSCOS (‘we’) use your information
BSCOS is committed to safeguarding your personal information. In order to handle ‘personal data’ about you we are required by law to provide this notice to you.
Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by [the Data Protection Bill/Act 2017 the General Data Protection Regulation 2016/679 (the “GDPR” and other legislation relating to personal data and rights such as the Human Rights Act 1998].
Why are we collecting your data?
We collect personal data to provide appropriate membership services, to monitor and assess the quality of our services, to fulfil our purposes as a society and to comply with the law regarding data sharing. In legal terms this is called ‘legitimate interests’. When it is required, we may also ask you for your consent to process your data. We do not share your information with others except as described in this notice.
What data do we process?
When we hold or use your information it is known as ‘processing’. We will process some or all of the following where necessary to fulfil our roles and responsibilities as a Society:
- Names, titles, and aliases, photographs;
- Contact details such as telephone numbers, addresses, and email addresses;
- Where they are relevant to our purposes, or where you provide them to us, we may process
demographic information such as gender, age, date of birth, nationality, place of work, academic/professional qualifications;
- Where you make donations or pay for activities, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
- Where you provide this information, we may also process data from the other categories of sensitive personal data (these are defined as: racial or ethnic origin, sex life, mental and physical health, details of injuries, medication/treatment received, political beliefs, labour union affiliation, genetic data, biometric data, data concerning sexual orientation and criminal records, fines and other similar judicial records). At present, however, BSCOS has no plans to utilise any data from these categories.
How do we process your personal data?
We will comply with legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
- To enable us to meet any legal and statutory obligations;
- To provide you with appropriate support and services;
- To act in line with our constitution;
- To administer the membership records;
- To provide a membership directory online and to allow communication between members of the Society;
- To fundraise and promote the interests of the Society;
- To maintain our own accounts and records;
- To process membership payments or payments for events;
- To seek your views or comments;
- To notify you of changes to our services and events;
- To send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other fundraising activities;
- To process a grant or application for funding;
What is the legal basis for us processing your personal data?
- To enable us to provide a voluntary service for the benefit of the public
Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as a delegated data processing provider). We will always take into account your interests, rights and freedoms.
Some of our processing may be necessary for compliance with a legal obligation. We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use. Sharing your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is legally required or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary):
• Our agents and contractors. For example, we may ask a commercial provider to send out
newsletters on our behalf, or to maintain our database software. At present our mailing list uses MailChimp (www.mailchimp.com), our membership database is provided by Sitelok (www.vibralogix.com/sitelok), membership payments are processed by Stripe (www.stripe.com/gb) and annual meeting payments are managed by Eventbrite (www.eventbrite.co.uk). All have appropriate security and privacy policies available on their websites;
• Other persons or organisations operating with permission within the Society;
• On occasion, other Societies with whom we are carrying out joint events or activities.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed. Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
1. The right to access information we hold on you
- At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
- There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
2. The right to correct and update the information we hold on you
If the data we hold on you is out of date, incomplete or incorrect, you can inform us, and your data will be updated. Alternatively you may correct your own data using the Update Profile button when logged in to the website.
3. The right to have your information erased
If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
4. The right to object to processing of your data
You have the right to request that we stop processing your data. Upon receiving the request, we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
5. The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
6. The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought
You can withdraw your consent easily by email at email@example.com, or by post (to the Secretary via the British Orthopaedic Association, 35-43 Lincoln’s Inn Fields, London WC2A 3PE).
7. The right to object to the processing of personal data where applicable
8. The right to lodge a complaint with the Information Commissioner’s Office
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints:
By email at firstname.lastname@example.org
c/o The Secretary to the BSCOS Board, British Orthopaedic Association, 35-43 Lincoln’s Inn Fields, London WC2A 3PE
You can contact the Information Commissioners Office on 0303 123 1113 or via email
or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Reviewed 1st June 2019