Fitzwilliam Private Members Club and Golden Horseshoe Limited
Data Protection Policy Statement
The Fitzwilliam Private Members Club and the Golden Horseshoe Limited is committed to the protection and privacy of personal data. All the personal data held by the Club and the Company, including that provided by third parties, is subject to the principles of Data Protection.
Data Protection Act – An Introduction
The Data Protection Act 1988 and the Data Protection (Amendment) Act 2003 regulates the use of information relating to individuals including information stored on non-computerised systems as well. The Data Protection Act is enforced by the Data Protection Commissioner and like all organisations that process personal data the Fitzwilliam Private Members Club and the Golden Horseshoe Limited must comply with the Act.
A full copy of the Data Protection Act 1988 is available on the Data Protection Commissioner’s website (www.dataprotection.ie), however good compliance with the Data Protection Act can be broadly equated to compliance with the eight Data Protection principles:
- Fair and lawful processing
- Processed for limited purposes
- Adequate, relevant and not excessive
- Kept accurate and up to date
- Not kept longer than necessary
- Processed in accordance with the individual’s rights
- Not transferred to countries outside European Economic area unless the country has adequate protection for the individual.
The Fitzwilliam Private Members Club and the Golden horseshoe Limited aims to meet the requirements of the Data Protection Act 1988 when processing personal data. In order to fulfil its obligations under the Data Protection Act the Club and the Company have implemented robust practices and policies. We train all staff to support the fair and lawful processing of personal data, implements security processes to prevent the unlawful disclosure of personal data and implements retention and disposal processes to ensure information is retained only as long as necessary.
What personal information do we hold?
In order to operate efficiently and to adhere to our legal obligations the Club and the Company has to collect and use information relating to individuals. This personal data includes information about individuals who become members of the Fitzwilliam Private Members Club, and people with whom it works and employees past and present of the Golden horseshoe Limited.
As outlined above, all personal data held by the Club and the Company including that provided by third parties is subject to the Data Protection Act 1988. The Club and the Company will only share personal data held by it with other organisations where there is a statutory provision. These provisions are set out in the Non-Disclosure Provisions of the Data Protection Act 1988 and more information is available upon request.
Any person about whom the Fitzwilliam Private Members Club and the Golden horseshoe Limited holds information has rights under the Data Protection Act. You may:
- be informed if the Club or the Company is holding personal data relating to you
- receive a description of the personal data, why the Club or the Company holds it and to whom your personal data may be disclosed
- have that information communicated to you
- have any inaccurate data corrected, or removed in certain circumstances
- stop processing likely to cause substantial damage or substantial distress
- receive compensation if you suffer damage as a consequence of wrongdoing by us
- appeal to the Data Protection Commissioner where you believe the Fitzwilliam Private Members Club or the Golden Horseshoe Limited as not complied with the Data Protection Act.
Making a Subject Access Requests
If a person wishes to view their personal data held by the Fitzwilliam Private Members Club or the Golden horseshoe Limited they must make a subject access request.
- The request must be made in writing, which includes email or fax, to the Data Protection Officer(DataProtectionManager@Fitzwilliamcardclub.com). The person is not required to state why they wish to access the information
- The request must include documents to identify themselves to the satisfaction of the Fitzwilliam Private Members Club / The Golden horseshoe Limited (e.g. driving licence, passport, birth certificate)
- The request must include a fee for €8 (cheques payable to ‘Fitzwilliam Card Club’ or the ‘Golden horseshoe Limited’)
- The request should include details of any specific information the person wishes to have access to
- The Club or the Company, as appropriate, will confirm receipt of the Subject Access Request and will respond in full within 40 calendar days. The person will receive all the information that has been located and can be released within 40 days and an explanation as to why any information cannot be provided at that time.
To make a complaint about the Fitzwilliam Private Members Club or the Golden Horseshoe Limited under the Data Protection Act please email DataProtectionManager@fitzwilliamcardclub.com or contact us at our offices on 01 611 4677.
Policy date: May 2018
Author: David Hickson