Karabiner Mountaineering Club (KMC) - Privacy Notice
In this Privacy Notice, the terms “we”, “us”, “our” and “ours” means the Karabiner Mountaineering Club; the terms “you”, “your” and “yours” means members of the KMC (including Prospective Members), and non-members making club hut bookings.
1. Keeping your information safe and secure is a high priority for the KMC. This update to the KMC’s privacy Notice implements changes required by the data protection regulations (GDPR) introduced during 2018. Although a number of KMC members live overseas, we are a UK based club, and the processing of all our members data will be done in compliance with UK law as it applies at the time.
2. These changes in the law do not alter what we use your personal information for, but they make it easier for you to find out how the KMC uses and protects your information.
4. The KMC is required to state the basis on which it collects and stores your personal information, and two legal bases, as defined by the ICO, are applicable.
5. Becoming a member of the KMC is a contract and we collect and process your personal data to:
- Identify and communicate with you,
- Collect your subscriptions and other money due, and
- Process the affiliation fee with the British Mountaineering Council (BMC).
Paying your membership subscription annually is deemed to be renewal and acceptance of this contract.
6. For the remainder of the collection and use of your personal data, the KMC is operating on the Legitimate Interest basis.
7. Members who wish to pay subscriptions by direct debit can pay the KMC using the GoCardless service https://gocardless.com/. You can find this under “Payments and Fees” on the members area of the website. The KMC does not hold members bank details when you pay by direct debit. GoCardless are the Data Controller for Banking and Payment data for KMC members who pay the KMC by Direct Debit. An FAQ on GoCardless and GDPR can be found here - https://support.gocardless.com/hc/en-gb/articles/360000281005-GoCardless-and-GDPR
8. The following information mostly relates to members of the KMC. Details of non-members and prospective members may be held when a non-member makes an enquiry, attend meets as a prospective member, during an application for membership, or when they make hut bookings.
Personal Data used by the KMC
9. For prospective membership applications we record your name, address, phone numbers and email address. During your period of prospective membership we will record the date at which you attend your first meet, the date on which your 3 month period of free 3rd party liability insurance from the BMC starts and ends, and whether or not you have chosen to continue with the KMC after that date, either via continuing as a prospective member, or by applying for associate membership. If you continue with the KMC, we will share your details with the BMC as described in 13.3 and 17.2 below.
10. For associate membership applications we record your name, address, phone numbers, occupation, email address and a record of your climbing experience. These details are held on the application form and are not shared with any third party except as below. Note that membership is only open to those over 18.
11. When an associate member upgrades to full membership, the names of the 3 members supporting their application are also recorded, together with further details of the member’s experience since becoming an associate.
12. New or upgraded members are listed in the KMC newsletter, as are changes to member’s addresses, email addresses or phone numbers.
13. Upon admittance, and during your ongoing membership of the KMC, your membership application data is used as follows-
- Your details are replicated in electronic files for on-going membership administration.
- Your details are used to provide you with a KMC website login, and to email or mail you the newsletter, and other club communications, as described below.
- Name and contact details of UK members are sent annually to the BMC to support the BMC club affiliation, the subscription process, delivery of Summit magazine, provision of free liability insurance, access to BMC travel insurance, etc.
14. The following further data may be captured during your membership -
- records of your interactions with us such as emails and other correspondence and your instructions to us;
- your use of the KMC website, including your password and member number Note - we recommend that you do not use the same password for the KMC website as you use for any other websites. This is normal good practice when using any website.
- records of your attendance at KMC meets, dinners, training events or presentations;
- images in video and/or photographic form and voice recordings of your attendance on KMC events.
15. 6 times per year we will send you the club newsletter. You can decide whether you wish to receive this electronically or by post. This will contain any recent changes to members contact details which have been notified to us, and details of the mountaineering activities of club members, including reports on recent meets. Notices of upcoming meets are also included.
16. From time to time, we may contact you by email, post or SMS with information about club activities. We will only contact you about club activities, or to provide information we judge to be of interest to club members.
Sharing Your Data
17. We ONLY share your personal information with the following parties:
- Other members, via the annual KMC handbook, and the “KMC Membership List” area on our website (only accessible by members). The name, address and contact details of members are listed in the club handbook, which is circulated to all members. It is each member’s responsibility to use this handbook only for club purposes, take care of it, not share it with any third party without the express permission of the Committee, and dispose of it securely by shredding when no longer needed. Members wishing to have a redacted entry in the handbook should contact the Secretary with their request
- The British Mountaineering Council, to allow them to properly represent mountaineering and related activities on a local, regional and national level, and for the purposes of providing you with 3rd party liability insurance.
- The Fell and Rock Climbing Club, to allow them to offer “reciprocal rights” in their club huts to KMC members.
- Other service providers: for example, our website hosting company, our handbook printers.
Your image in photos or videos
18. The ICO has advised that GDPR does not apply to images of people taken in public places by amateur photographers. Although not a GDPR issue, we offer general advice below -
- You do not usually have a legal right to object to being photographed in a public place. However it is common courtesy for photographers to seek permission from subjects. You are not obliged to consent to being photographed. If you have given your consent, and later wish to withdraw this, this is primarily an issue between you and the photographer.
- It is normal practice for the KMC to use images or video of members on our website, in club social media, and in printed club publications. If you do not wish your image to be used in this way, you should notify the committee and any members of the club operating on club meets. If you wish for any image or video of you to be removed from our website, or club social media, you must notify both us and the photographer, in writing. On such notification, we will use reasonable endeavours to remove such images from our website or club social media, but it is impractical for us to remove images of individuals from club printed publications, and we are not able to offer this option. Note that we can only help where your image appears in club media. Any issues you have with any other use of your image by the photographer, are between you and the photographer.
Transferring Your Data Internationally
19. The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. This is most likely to happen with data stored on our website, and on any “cloud servers” which we use. Some countries have different levels of protection for personal information, and the laws in those countries may be less protective than in the UK. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is kept secure. Where a third party processes your data on our behalf, we will put in place appropriate safeguards.
How Long Do We Keep Personal Information For?
20. This will differ, depending on the type of information and the reason why we collected it. Some personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Note that we may need to retain limited information (e.g. Name, Membership Start and End date, Date of Birth) for extended periods for the purposes of BMC liability insurance.
21. The KMC maintains a club archive. Material includes newsletters, club handbooks, photos, videos and other relevant materials that show the club’s history. This data is retained indefinitely.
22. For information not relevant to the club archive, and where there is no legal requirement, we retain all physical and electronic records for a period of no more than 6 years after your last contact with us or the end of your membership. Exceptions to this rule are:
- Details regarding prospective membership applicants who do not proceed to join the club, where we hold records for a period of not more than 24 months;
- Information that may be relevant to personal injury or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after the event.
Your right to access and update your data
23. It is important that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything is incorrect or changes, e.g. if you change your phone number or email address. You can update your personal information yourself using the member’s area of the club website www.karabiner.org . Alternatively, you can contact us, requesting us to update your information by using the details set out in the "Contacting us" section below.
24. We will rectify the personal data in question, and inform you of that rectification, within one month of you informing KMC of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, you will be informed. If any affected personal data has been passed on to third parties, we will inform those parties of any rectification that must be made to that personal data.
25. You have the following rights in relation to your personal information:
- the right to be informed about how your personal information is being used; hopefully this privacy notice has done that, but do contact us if you have any questions.
- the right to access the personal information we hold about you;
- the right to request the correction of inaccurate personal information we hold about you;
- the right to request the erasure of your personal information in certain limited circumstances - but see “how long do we keep your information for” above.
- the right to restrict processing of your personal information where certain requirements are met; specifically you do not have to complete all the members information fields we supply for your use, and you can control whether or not others can see your contact details. There is a certain minimum of information you must supply and allow us to process to fulfil our membership contract with you - see points 5 and 6 above.
- the right to object to the processing of your personal information;
26. To exercise any of the above rights, or if you have any questions, please contact us by using the details set out in the "Contacting us" section below.
27. If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office. We are here to help - please contact us to resolve your complaint first.
Changes to this Notice
28. We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version numbers date at the top and bottom of this document. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
29. In the event of any query or complaint in connection with the information we hold about you, please email firstname.lastname@example.org, or you can identify the current secretary in the KMC handbook and write directly to the secretary.
Links from KMC website to other websites
Version 1.1 dated 23/02/2019