Before forming the society
we enquired of the Office of the Information Commissioner about our responsibilities
with respect to Data Protection legislation. They advised us and sent
us a booklet called “Notification Exemptions” (form
DP/EXEMPT/1202/70k, available from the Information Commissioner).
We have fully reviewed that document, and this section summarizes
the most important points that you, as a member or
prospective member, may
wish to know. If you need more,
email
us with your question(s).
Does TWFS hold personal data
about its members?
Yes. We hold the information that you supply to us when you send in
your application form, or additions or corrections that you later give
us. We also hold information about when you join, when you renew
membership,
how
much you have paid
in subscriptions and when, your email address (if you have one), etc.
We hold this solely to enable us to run the society and you to enjoy
its
benefits.
Must TWFS comply with
the Data Protection legislation?
Yes. “Only individuals processing personal data for personal,
family or household affairs are exempt from notification and other
provisions of the Data Protection Act 1998.” (From the booklet
mentioned above.) This clearly does not apply to TWFS.
Must TWFS “notify” the Information Commissioner about
the data that it holds?
No. Provided that they satisfy certain conditions, there
is a specific exemption for not-for-profit
organizations, and that’s what TWFS is.
We have checked all those conditions and are satisfied that TWFS
does
not
need to
register with the Information Commissioner. (We still need to
comply, of course - see above.)
Who in TWFS can see the data on me that TWFS holds?
You can. If you ask to see the data that we hold, we will issue
you with a print-out of the data for you, but for no-one else. It
won't be prettily formatted, but it will be readable.
Current committee members.
Will TWFS release my personal data to other organizations?
Absolutely not! But ...
There is just one exception. We issue regularly to the
cinema
a list of members so that, if you have forgotten your membership
card, they can verify that you are a member when you claim discount
or buy a cinema ticket. That list holds just two pieces
of information about you: your name and title,
and
your
membership
number. This reveals no sensitive, personal data, so we think
this is reasonable.
There has now been a second exception: we gave
exactly the same list to Goodfellows in May 2008, as they were
offering a special discount to TWFS members during June.
We might, however, release your name and telephone number to other
members of TWFS if this supports the internal
purposes and activities of the society. (E.g. forming discussion
groups.)
But what if a member asks you to give to him data on other members
which would be useful for his charity or business?
We will not give it. Here is what we said in our news update to
all members in March 2004:
“Your committee has discussed how we should treat requests
to use our mailing list [i.e. your personal data] for advertising
and has agreed, firstly, that only
the committee shall have access to the full list with addresses.
(Data Protection applies, of course.) We do not encourage but may
be prepared to consider including in or with our normal mailings
or programme notes others’ publicity material, but only where
these conditions are all met:
from bona fide members of TWFS, on their own, not others’,
behalf;
where the event being advertised is considered appropriate (e.g.
no car boot sales, no MacDonald’s, no double glazing);
after consideration on a case-by-case basis by the committee
(which will limit the number of occasions on which you
receive such material);
on the understanding that the committee is simply including
the material for your information, is not attempting
to persuade you to take up the offer, and takes no responsibility
for
your decision
or its consequences.
Can you assure me that you don’t retain my bank account or
credit card details?
Yes.
Firstly, we cannot process credit or debit cards, so we
do not accept them for payment of subscription.
Secondly, if you
pay your subscription by cheque, we simply pay it into the TWFS
bank. We have
no interest
in which
bank
you
use,
or
your
bank branch, or its sort code, or your account number, so we keep
no record of them.
Do you comply with the Data Protection
requirement that “personal
data are not kept after the relationship between you [TWFS] and
the data subject [the member] ends”?
Yes.
You should, however, note that that quotation, from the booklet, Notification
Exemptions, mentioned
at the beginning of this page, continues
so: "...
unless and for so long as it is necessary to do so for the exempt purpose."
We therefore retain personal information (your address, telephone
number, email address, etc.) until we are quite certain that you have
left the society. In practice this means that we will delete this data
if you have NOT renewed or rejoined by mid-August of the following
TWFS year. We then keep your name, membership
number and dates and amounts of subscription payments
but nothing more, just so that we have a minimal record of who has
belonged to TWFS over the many years that we hope it will survive.
On your application form you ask for my telephone number and email
address. Why? Am I going to be pestered by your spam?
No. Both are for what we consider to be necessary or at least useful
communication.
Telephone number:
In case of
queries or issues
more easily resolved by phone. For
instance,
if someone has sent the
wrong subscription,
or expressed a forceful opinion that needs to be discussed, or
simply asked a question, it is often most simply resolved in
a brief telephone conversation. We avoid handwritten or typed
correspondence to individuals, except for new memberships, renewals,
newsletters and the AGM. It costs money and takes an awful lot
of your voluntary committee’s
time.
To contact you urgently if there is
an unforeseen
change that you may need to know about. For instance, in
2004-5 a distributor failed to deliver a film in time for the Monday
night
showing. On that occasion, committee members, at their own expense,
warned by phone every single TWFS member who was not on email and whose
phone number was on record.
Email address:
For the film reminder that we send out a few days before a film
night.
For other news or information that may be of
interest or advantage to members (e.g. the Goodfellows offer for June 2008).
In future we shall consider using email for missives that are currently
posted.
We shall NOT pester, or flood your inbox. If you think that
we are doing,
email
us, and we shall resolve it. (Most probably
by phone or email!)