The Worshipful Company of Upholders
General Data Protection Regulation 2018
On 25 May 2018 new regulations regarding the storage and handling of personal information held by organisations will come into force.
You need to be informed what information about you is held and to what purposes it can be applied. You need to be aware that such information is securely held and will not be used for any other purpose than those indicated.
You need to give your positive approval for such information to be held and used in the manner outlined and you need to be aware that you can request such data be removed from our records.
For the purposes of this policy, the Master, Wardens and Court are the Governing Body of the Worshipful Company of Upholders, together known as the Data Controller. For the purposes of this Policy the Charity Trustees are the Governing Body of the Upholders Charities named above, together known as the Data Controller. Together with the Clerk and Hon Treasurer, they are required to keep the information confidential.
What personal Information we might collect from you:
a) Full name, postal address, telephone number(s), email address, name of spouse [if applicable]
b) Dietary requirements, record of attendance including number of guests brought to events, payments relating to events organized by the WCU and occasionally other events open to Liverymen eg Beating Retreat, Lunches after United Guilds’ Service and City Elections
c) Details of subscription (quarterage) payments. If you pay by Direct Debit it is the third party provider, not the Upholders Company, who hold a record of your bank details and they will hold their own GDPR policy which you may consult for yourself
d) Donations to Upholders’ charities
e) Membership of related and other City organisations, photographs, members’ interests including businesses, and other information needed for the efficient running of our Livery
f) Website usage information to track visitor use can be collected using cookies.
Held by: The Clerk and the Hon. Treasurer, stored either on a local hard drive or in paper form.
The same records or more likely excerpts thereof may be requested from the Clerk by Members of the Court, Committee Chairmen, the Charity Trustees and our professional advisors. Details of individual donations are seen by the Treasurer and Trustees, and Clerk for administration purposes only.
How do we use this information?
For the distribution to Members only of Members’ Address Lists, Newsletters, Booking
forms for organised events, Subscription renewal forms, Obituary Notices, Notices of Meetings, all relating to the membership or activities of the Worshipful Company of Upholders.
Occasionally for the distribution to Members only of information on events organised by fraternal bodies connected with the cultural or corporate life of the City of London.
All such information is distributed [almost exclusively by email] by the Clerk.
With the exception of any external organisations listed below we will not sell or share any personally identifiable information collected by us to any third party so they can market their products or services to you:
- The Corporation of the City of London – We are legally obliged to submit data to the Common Hall Register which holds the names and addresses and position in the Company of all Liverymen entitled to vote in Elections of the Lord Mayor, Sheriffs and other City officials.
- A copy of our annual Livery List is requested by the Guildhall Library for its Archives.
Protecting your personal information:
The security of your information is very important to us. We ensure that there are appropriate controls and procedures in place to protect your personal details. However, despite all the security and protection put in place, the internet cannot be guaranteed to be 100% secure. Therefore, you submit data at your own risk.
Keeping your information up to date:
a) We may use publicly available sources to keep your records up to date and accurate. We also take appropriate measures to ensure that information is only kept as long as is necessary and only for the purpose for which it was given. You may at any time review or update any personally identifiable information we hold. In the first instance please email firstname.lastname@example.org. We will take any reasonable steps to confirm your identity before any such changes are made.
How long we will keep your information for:
a) Contact details and dietary restrictions of your guests other than partners, are deleted following each event. Contact details of any Master’s guests will be kept only for that Master’s year.
b) When you make an enquiry and complete a membership form, we will retain your data for as long as your membership is current (and quarterage is paid). Your original paper application form is kept indefinitely relying on legitimate interest in order to maintain the records and archives of the Worshipful Company of Upholders. Minimal information such as name, date of joining, last known address and any positions held during an individual’s career in the Livery will be retained on the local hard drive, however any other unpublished information is deleted on the resignation or death of a member.
c) Details of enquirers who never progressed to full membership can be retained for up to 7 years.
d) You may request the deletion or removal of personal data where there is no compelling reason for it to be held by the Worshipful Company of Upholders. However the Right to Erasure does not provide an absolute right to be forgotten. There are a number of circumstances where you have a right to have personal data erased including but not limited to when you withdraw consent, in order to comply with a legal obligation or when there is no overriding legitimate interest for continuing to hold the data.
If you do not wish the Worshipful Company of Upholders to store your email address, you will not be able to access the password protected website Members’ area and you will not receive email notices of events.
If you do not wish us to store your name and address, we will not be able to send mailings to you including the newsletter Upbraid.
Without your consent to the WCU holding your data as described, you will be unable to participate in the activities of the Company.