Privacy Policy & GDPR Notices

The Worshipful Company of Tobacco Pipe Makers and Tobacco Blenders Registered Office: 14 Montpelier Road, Sutton, Surrey, SM1 4QE

PRIVACY NOTICE

(Liveryman or Freeman)

Introduction

Our Intent. We are committed to safeguarding the privacy of our members. The Company will only use the information that we collect about you lawfully and in accordance with the Data Protection Act 1998 (the “Act”).

Changes to Data Protection Legislation. Data Protection legislation and the Act is currently going through a period of change. The introduction of the European Union’s General Data Protection Regulation (GDPR) and the new British Data Protection Bill, that will replace the Act and is currently passing through Parliament is the basis of this change. This Privacy Notice is therefore intended to comply with the Act and GDPR but may change over time.

Member’s Terms and Conditions. This Privacy Notice, forms part of Terms and Conditions for being a member of the Company. In legal terms, members are “Data Subjects”, i.e. “you”. However, we may also under this collect personal information regarding your spouse and dependents if appropriate.

The Data Controller. The Worshipful Company of Tobacco Pipe Makers and Tobacco Blenders (to be known as the Company) is from a legal perspective classed as the “Data Controller”.

Data Protection Officer (DPO). The Company’s DPO is the Clerk. The Company’s Clerk fulfils a number of roles, one of which is to be the primary point of contact for data protection matters. The formal mechanism for members to raise concerns regarding the processing of personal data is primarily to email: clerk@tobaccolivery.org; or send a letter by registered mail to: 14 Montpelier Road, Sutton, Surrey, SM1 4QE, at which point the inquiry will be actioned. However, verbal enquiries from guests will be treated appropriately by Company staff members, although a written follow up may be requested if appropriate.

Purpose of Processing Personal Data. We collect personal data primarily to support The Worshipful Company of Tobacco Pipe Makers and Tobacco Blenders, support the City and the Lord Mayor and to raise money and support charitable and educational works.

Lawful Basis of Processing Personal Data. The lawful basis of processing your personal data are as follows:

Consent. Once you have agreed to this Privacy Notice of our Terms and Conditions, you will be registered for the processing of your personal data, based upon your Consent.

Categories of Personal Data Processed. The information we hold should be accurate and up-to-date. The personal information which we hold will be held securely in accordance with our internal data protection and security policies. The type or categories of personal data we will collect about you includes your:

DISCLAIMER: The information in this Privacy Notice is for general guidance on your rights and responsibilities and is not legal advice. If you need more details on your rights or legal advice about what action to take, please contact an advisor or qualified lawyer.

The Worshipful Company of Tobacco Pipe Makers and Tobacco Blenders Registered Office: 14 Montpelier Road, Sutton, Surrey, SM1 4QE

Name

Postal address

Email address

Mobile and/or landline number

Your Spouse or Partner’s name

Photograph

Bank/Building Society details

Direct Debit Information

Gift Aid details

Benevolent Fund Donations

Date of Birth

Freedom Date

Liveryman Date

Date of joining Standing Committees or the Court

Date of becoming Warden and Master

Proposer and Seconder’s names

Education Details

Business/Work Information

If you apply for further roles or appointments within the Company, we may request further information and retain additional records, such as interview notes.

Equally minutes of meetings and records of decisions may include your name and other information about you.

Category of Recipients of Personal Data. Your name and contact details will primarily only be used internally within the Company. However, if you participate in a dinner, Inter-Livery or charitable outreach activity, we will normally have to provide your name and possibly other details to other stakeholders.

Transfer of Personal Data Outside the EEA (European Economic Area). Personal data will only be transferred outside the EEA or other areas of adequacy determined by the EU, for specific events. If this is required, consent will be explicitly requested from you.

Sensitive Personal Data. We will never collect sensitive personal data about you without your explicit consent and a clear explanation why it is required.

Spouse and Children Personal Data. If we hold personal data about a member’s spouse, we will ask for consent from the spouse for this. For member’s children, under the age of 18 years old, we will assume parental consent, however your child(ren) may withdraw consent, including as an adult.

Sale or Passing of Personal Data to Third Parties. We will not sell or pass your personal data to any commercial or charitable organisation.

DISCLAIMER: The information in this Privacy Notice is for general guidance on your rights and responsibilities and is not legal advice. If you need more details on your rights or legal advice about what action to take, please contact an advisor or qualified lawyer.

The Worshipful Company of Tobacco Pipe Makers and Tobacco Blenders Registered Office: 14 Montpelier Road, Sutton, Surrey, SM1 4QE

Retention of Personal Data. We will retain your personal data as follows:

Information Held Under Consent. Whilst you are a member of the Company. Upon leaving, we will request your consent to continuing to hold your name and relevant details to support our historical records.

Data Subject’s Rights. Under the Act and even more under the GDPR you have a number of Rights which we have outlined below:

Right of Access. You are entitled to access your personal data so that you are aware and can verify the lawfulness of the processing. This is achieved through the mechanism of a Subject Access Request (SAR) and you have the right to obtain:

Confirmation that your data is being processed (held)

Access to your personal data (a copy) and

Other supplementary information that corresponds to the information in this privacy notice.

Fees and Timings. Under GDPR and from 25 May 2018, this information will be provided without charge; without delay and within one month. If an extension is required or requests are considered manifestly unfounded or excessive, in particular because they are repetitive, the Company may choose to: charge a reasonable fee taking into account the administrative costs of providing the information; or refuse to respond. The reasons for this will be formally notified to you and your rights to appeal to the appropriate Supervisory Authority, i.e. UK Information Commissioner’s Officer (ICO) will be highlighted.

Identity Verification. To protect your personal data, the Clerk will seek to verify your identity before releasing any information, which will normally be in electronic format. As a member this will normally be a simple process, however if the SAR is made from a member living overseas, or former member, or by the relative of a deceased member, then additional verification steps are likely.

Right of Rectification. You are entitled to have personal data rectified if it is inaccurate or incomplete. The Clerk will respond within one month of your request. In the unlikely event, the Clerk does not take action to the request for rectification, we will inform you of your rights to complain or seek judicial remedy.

Right of Erasure. You may request the deletion or removal of personal data where there is no compelling reason for its continued processing. The Right to Erasure does not provide an absolute ‘right to be forgotten’. However, you do have a right to have personal data erased and to prevent processing in specific circumstances:

Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed

When you withdraw consent

When you object to the processing and there is no overriding legitimate interest for

continuing the processing

DISCLAIMER: The information in this Privacy Notice is for general guidance on your rights and responsibilities and is not legal advice. If you need more details on your rights or legal advice about what action to take, please contact an advisor or qualified lawyer.

The Worshipful Company of Tobacco Pipe Makers and Tobacco Blenders Registered Office: 14 Montpelier Road, Sutton, Surrey, SM1 4QE

The personal data was unlawfully processed

The personal data has to be erased in order to comply with a legal obligation

The personal data is processed in relation to the offer of information society services

to a child which the Company does not provide.

Right to Restrict Processing. Under the Act, you have a right to ‘block’ or suppress processing of personal data. The restriction of processing under the GDPR is similar. When processing is restricted, the Company is permitted to store the personal data, but not further process it. In this event, exactly what is held and why will be explained to you.

Right to Data Portability. You may request to obtain and reuse your personal data for your own purposes across different services. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The Right to Data Portability only applies:

To personal data you have provided to the Company

Where the processing is based on your consent or for the performance of a contract

and

When processing is carried out by automated means.

In these circumstances, the Clerk will provide a copy of your data in CSV format and, or PDF free of charge, without undue delay and within one month. If there is a delay to this, you will be informed.

Right to Object. You have the right to object to:

Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)

Direct marketing (including profiling) and

Processing for purposes of scientific/historical research and statistics.

Automated Decision Making and Profiling. The Company does not employ any automated decision-making or conduct profiling of Data Subjects. However, if you have consented to be held on our Customer Relationship Management (CRM) database, we may periodically send you marketing information so that you are informed of upcoming events. These are automated but they do not involve automated decision-making or profiling

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