Data Protection Policy

The data that members provide OSA are kept in documents that are held and processed both as hard copy and electronically. This means that is subject to the General Data Protection Regulation 2016 (GDPR) in force in the UK from 25th May 2018.

 

We are only allowed to keep data which is necessary for OSA activities. We keep some or all the following:

1. Name

2. Plot location

3. Email address

4. Postal address

5. Landline phone number and/or mobile phone number

 

OSA uses electronic spreadsheets to manage personal data (including membership and finances). These spreadsheets are held securely on individual Committee members’ computers and are emailed between Committee members on a need-to-know basis.

• When you pay money to us (for example, your annual plot rental), we may keep a record of your payment and what it was for.

• Committee meetings are held several times a year. Committee minutes, which may include member names and plot locations, are emailed to Committee members but these minutes are not posted on our website.

• The minutes of the Association AGM, including names of attendees, are emailed to members.

 Confidential or sensitive information is only shared between Committee members, and only on a ‘need to know’ basis.

 

• You are the source of your own personal information, initially from when you joined OSA, and then changes that you notify us about.

• We will endeavour to maintain accurate records, but we rely on members keeping us updated.

• All information is checked and updated when plots change hands.

 

• OSA uses email to handle most administration and communication tasks.

• Committee members, who are responsible for bulk emails use one Association email accounts for this purpose (thecommittee@oakhamallotments.com).

• This email account contains members’ email data.

 

The data are only used for legitimate uses; these include:

• Communication between committee members and other members as part of the daily running of the Association

• Notification of Association meetings and the minutes of those meetings

 

• We will not disclose your data to other members or to third parties or use it on behalf of third parties. For example, members may sometimes be lobbied to advertise a service or product that might be useful to other members of the association. We will not use your addresses to do this (no “spam” allowed).

 

• GDPR data protection law has six possible bases on which to hold personal data, including Obtaining Consent, and as Legitimate Interests.

• Like other membership organisations we hold your personal data on the basis of ‘Legitimate Interests’.

• This is defined as meaning in ways one would “reasonably expect … and which have a minimal privacy impact, or where there is a compelling justification for the processing” such as being able to communicate with our members – we cannot rent plots to members with whom we have no way to communicate.

 

• Only those who need access to the data have access and they do not share it with anyone else.

• The following Committee members have access to the full membership data: President, Secretary, Treasurer, relevant Committee Members with justifiable cause (for example plot

management).

 

• Data are held as documents on password-encrypted computers.

 

• We do not keep data which is not needed for operation of the allotments. The data for members who leave is usually held for at most 6 months, after which time it will be deleted from our records.

• We keep the data for a short period in case we need to communicate with a member who has recently left, but only for the purpose of resolving any outstanding matters.

• Accounts data is retained for a longer period of time (5-7 years).

 

The key purpose for holding your personal data is for the administration of OSA and the management of the allotment site. In practice, this means:

• Dealing with prospective members (initial/follow-up contact, waiting list, site tours, site access…)

• The offer of a plot, and acceptance of a plot. Any moves from one plot to another, additional plots. Relinquishing of plots, and termination of membership.

• Payment for membership, the plot, and associated sundries.

• Management of permissions associated with the plot (e.g., shed and other permissions).

• Communication about the site and plots (e.g., social events, working parties, policy reminders, gardening advice…). Communication on individual circumstances affecting the plot holder or plot. Communication about OSA (e.g., AGM).

• Issues with plots, and enforcement of site and plot rules, including any follow-up required with individual members.

• Urgent contact for plot or site problems.

• Management of the Site and Association as a whole, for example, meeting minutes, analysis of plot vacancies, deliveries.

 

• A nominated member of the committee is responsible for ensuring that this policy is adhered to.

• The GDPR Data Controller is the OSA President who will undertake this role.

• Other Committee members act as GDPR Data Processors – collecting data e.g., from new

tenants or at rent renewal time.

 

• Data protection law gives you certain rights. Full details are available on the Information Commissioner’s website.

• For a small organisation like ours with relatively simple records, the relevant rights are for you to see your record and to correct any errors in it. Members can at any time ask the President or Secretary for a copy of their recorded data. To request this, send an email to- thecommittee@oakhamallotments.com

• When you come to pay the plot rent each year you can check the information we hold on you is correct.

• You also have a right to complain to the supervising authority, i.e. to The Information Commissioner’s Office (ico.org.uk).

 

We care deeply about the management and usage of your data and will work hard to safeguard it.

 

The OSA website stores very limited information about our site visitors..