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Privacy & Cookie Policy

PRIVACY POLICY
2018 REVISION (v20180510)
GENERAL INFORMATION 

The Honourable Artillery Company (HAC) is committed to doing the right thing in how we collect, use and protect your personal data.  This Privacy Policy:

  • Sets out what personal data we may collect from you
  • Explains why and how we use your personal data
  • Explains who your personal data might be shared with
  • Explains how long we might keep your data for
  • Explains how we keep your data safe
  • Explains your rights and choices in relation to your personal data

 

1. WHAT DATA DO WE PROCESS?

 The HAC processes information relevant to the purposes described below. This may include:
 
  • personal details
  • family details
  • lifestyle and social circumstances
  • affiliations and memberships
  • employment and education details
  • financial details
  • military service details
 
Some or all of this may be Special Category Data, subject to additional regulation, which we process for the purpose of administering your membership.
 
Photographs of members. As a secure site, we will ask you to provide identification and to allow us to photograph you when you first arrive at Armoury House. This photograph is used to identify you when you wish to access the site by us and by our appointed Security Contractors. We will ask you for your consent before we take a photograph. You may refuse or change your consent to this processing of your image but it may affect our ability to identify you when you visit Armoury House. Photographs are stored on our secure membership database in association with your membership details.
 
Who the information is processed about.  We process personal information about our members, members of the Regiment who are not members of the Company, members of the Special Constabulary who are not members of the Company, members of HAC Sports Clubs who are not members of the Company, members of our affiliated cadet units, commercial clients, supporters and sponsors, tenants, our staff, contractors and volunteers.
 
 

2. WHY DO WE PROCESS IT?

The Company is a regimental organisation, both active and veteran, founded in 1537 by royal letters patent and registered as a charity since 1964 (charity no. 208443) with its charitable purpose being for ‘the better defence of the realm’.   The Company is, at its core, a closed membership organisation, operating simultaneously as a charity, commercially exploiting some of its assets to generate funds for its charitable purpose, as a barracks and as a mess for its members.  We hold current personal data on our 2,580 members, permanently archived data for many more, data on employees and also commercial client data and data on public enquirers. Data processing required by each element of the Company’s work may be different.
 
We process personal information to enable our members to stay in touch with the Company and with each other; to fulfil members’ role as advocates for Defence; to fundraise for the Charity and for other charitable causes through commercial activities and events; for the leasing of Company property, the management of investments, the collection of subscriptions and the encouragement of donations; for the administration of elections; to communicate Charity updates regarding the governance and administration of the HAC; to enable us to administer our membership records and process subscriptions; to administer gym memberships; for the administration of HAC Sports Clubs, member activities and events; to distribute publications and administer our website; to sell merchandise; to administer activities and the use of the property by members of the Regiment who are not members of the HAC; to assist the Regiment with the administration of their records for their purposes where appropriate for individual members; to maintain our own accounts and records; to archive permanently for purposes of the Company’s historical record and corporate memory and to answer historical enquiries from members of the public; and to support and manage our staff and volunteers. 

 

3. YOUR RIGHTS

Access to your personal data. You have the right to request a copy of the information that we hold about you. You are entitled to be given a description of what information we hold about you; what we use it for and who we might pass it on to. We are required to answer your request within one month of its receipt at the latest, and occasionally may then need to ask for an extension. We may need to carry out additional identity checks before we release your personal data to you. In most circumstances we will not charge a fee when you wish to access your information. If you would like a copy of the personal data we hold about you, please write to the Data Protection Officer, Honourable Artillery Company, Armoury House, City Road, London EC1Y 2BQ or email:  privacy@hac.org.uk
Accuracy. We want to make sure that the personal information we process about you is accurate and up to date. You may ask us to correct or remove information that you think is inaccurate and in most circumstances we will correct inaccuracies within one month of you informing us. To help us in this, we would ask you please to keep us informed when your details change by writing to us at the address or email address given above.
 
Deleting personal data or restricting processing activity. You may ask us to delete the personal data that we hold about you in part or in full. This is sometimes called an ‘erasure request’ or your ‘right to be forgotten’. There are some circumstances in which we cannot delete all personal data (for example where we have a legal obligation to retain it or because we may need it to defend legal claims), but we will always consider such requests on a case by case basis and where we can comply, in most cases complete the deletion within one month of your request.
 
In addition, you may ask us to stop some types of processing activities with some or all of your personal data. For example, you may wish use to stop sending you membership newsletters. You can do this by changing your communication preferences associated with your membership or by writing to us to outline what types of processing you wish us to restrict. Again, please use the address or email address above.
 

4. SHARING YOUR DATA

Who has access to it?
 
We sometimes need to share the personal information we process with the individual themselves and also with other organisations. Where this is necessary we are required to comply with all aspects of the General Data Protection Regulations (GDPR). What follows is a description of the types of people and organisations we may need to share some of the personal information we process.
 
Where necessary for the purposes of administering the membership, or when required by law, we share information with family, associates and representatives of the person whose personal data we are processing; government institutions and organisations; legal and professional bodies; contractors and service providers; affiliated organisations; partnered and other charitable organisations; current, past or prospective employers.  
 
Transferring information overseas.  We may need to transfer personal information outside the United Kingdom for the above reasons/purposes.  This may be relevant in relation to the Boston Association, the visit to Vittorio Veneto and so on.
 
Our and other websites. 
 
  • Our website contains links to other websites. Our privacy notice only applies to our own website, so when you link to other websites you should read their own privacy policies. We cannot guarantee the security of your personal data when you navigate away from our website to those of third parties.
 
  • Cookies.  Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org  You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.

 
WE DO NOT USE YOUR DATA FOR AUTOMATED PROFILING OR DECISION MAKING
 

5. HOW LONG WE KEEP YOUR DATA

We will retain all of your data for the duration of our administration of your membership and we will retain some of your data permanently for our archives, which are maintained in the public interest, stored securely and accessible under certain closure rules.
 

6. HOW WE KEEP YOUR DATA SECURE

We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe. We only authorise access to employees who need it to carry out their job responsibilities.
 
We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We may occasionally ask for proof of identity before we share your personal data with you.
 
Please note that whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.
 
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
 

7. CHANGES TO OUR PRIVACY POLICY

We keep our Privacy Policy under regular review and we will place any updates on the Company website and notify members through the Newsletter and Regimental Fire. This Privacy Policy was last updated on 10th May 2018.
 

8. CONTACT US

If you have any questions relating to Data Protection, then you may write for the attention of the Data Protection Officer, Armoury House, City Road, London, EC1Y 2BQ or email us at: privacy@hac.org.uk 

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