GDPR - YOUR RIGHTS



             
THE ROYAL COMMONWEALTH EX-SERVICES LEAGUE (RCEL)
PRIVACY POLICY STATEMENT TO COMPLY WITH
THE NEW GENERAL DATA PROTECTION REGULATION (GDPR)

How we will use your information when you give your data to HQ RCEL.
This statement explains why we ask for your personal information, how we store and use it and who we may share it with, and what your rights are.
Why we ask for your personal information.
We want you to play a full part as a Member of The RCEL.  We would like you to process data on our behalf in order to provide welfare support to beneficiaries and potential beneficiaries in accordance with our Objects.  We would also like to process your data in order to provide welfare support to beneficiaries and potential beneficiaries in accordance with our objectives.  In addition we may want to be able to contact you about our events.  By consenting to us holding your information we can administer any membership and welfare applications and issues.
Who is your data shared with.
The data collected will only be shared within HQ RCEL and appropriate relevant organisations for legitimate reasons.  Any data received concerning welfare cases will only be shared with organisations in a position to support RCEL such as other Military and appropriate Civilian Charities.  These UK based organisations are subject to GDPR. The RCEL may offer a number of events that you may wish to attend.  Some marketing may be used, inviting you to events and supplying you with information we believe you may be interested in.
How we store your information.
The information you consent to give us is stored on a database on a secure IM & T system owned by The Royal British Legion that is fully GDPR compliant.  This database can only be accessed by the RCEL Controller Welfare or other HQ RCEL staff given authority by Controller Welfare.  This will be a fully managed database and there are procedures and policies in place in order to keep your information protected from misuse in accordance with the General Data Protection Regulations.
Objects of The Royal Commonwealth Ex Services League (RCEL)
The League exists to serve all members and their beneficiaries of The RCEL. The Objects of The RCEL, set out in the Articles of Association are as follows:  
Objects.

With a view to perpetuating the memory of gallant men and women who have suffered or died for the Commonwealth of Nations, the Objects of the Charity shall be by charitable means:
 
1.1. to seek to ensure that no man or woman resident overseas who has at some time served the Crown:
⦁    in the Armed Forces of any Commonwealth country or former Commonwealth country before that country achieved independence of the United Kingdom; or
⦁    during hostilities in the Merchant Navies of any such country; or
⦁    in the Red Cross or St John’s organisation while such organisation was serving with the Armed Forces of any such country,
should suffer undue hardship;

1.2. to seek to ensure the widows and widowers of such persons who qualify for support under 1.1 should not suffer undue hardship;
   
1.3. to assist United Kingdom service charities to provide welfare to qualifying personnel (including their widows or widowers) resident overseas who are in need and who at some time served in the Armed Forces or during hostilities in the Merchant Navy or the Red Cross or St John’s organisations while such organisations were serving with the Armed Forces of the United Kingdom; and
 
1.4. to seek, where possible and within resources, to raise awareness of the subject of Remembrance of the service of the Armed and Auxiliary Forces of the Commonwealth and of their needs.

How long do we keep your information for.
Each year we will review your data.  We shall decide if there is a legitimate reason to retain it.  If not, we shall dispose of it in accordance with The Royal British Legion disposal policy.  In most cases this will involve confidential shredding of hard copy material or deletion from IM & T systems.
As a Member of RCEL we will hold your data for legitimate reasons.  If you cease to be a Member we may hold your data for up to 6 years.  If you have consented for us to contact you about future events, then we will maintain your record until you tell us you would like us to delete it.
Your rights.
You have the right to see the information that we hold on you at any time, by submitting a Subject Access Request (SAR) in writing by contacting Controller Welfare as shown below.  You may also request to opt out of any of our services or have your details deleted from the database at any time, again by contacting Controller Welfare in writing and letting us know what your preferences are.
Controller Welfare
The Royal Commonwealth Ex Services League
Haig House
199 Borough High Street
London SE1 1AA

Or email:
lgill@commonwealthveterans.org.uk
Our Data Controller is The RCEL and you may contact them if you feel your rights have been breached.  
Secretary General
The Royal Commonwealth Ex-Services League
Haig House
199 Borough High Street
London SE1 1AA

When we receive your information, we only use it for the purposes that you have agreed and we will adhere to all aspects of the new General Data Protection Regulation (GDPR).  For independent advice about data protection, privacy and data-sharing issues, you can contact the Information Commissioner at:  Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.  Phone:  08456 30 60 60 or Fax:  01625 524510
Website:  http://www.ico.gov.uk    


RCEL COMPLIANCE STATEMENT WITH THE NEW GENERAL DATA PROTECTION REGULATION (GDPR)
RCEL MEMBERSHIP PERSONAL INFORMATION

You are probably unaware that from 25th May 2018 the UK will be subject to new data regulation.


The General Data Protection Regulation (GDPR) replaces the Data Protection Act (DPA, 1998). It aims to standardise the way personally identifiable information is dealt with in terms of data processors and data controllers that exist within the EU, or countries operating outside of the EU that process the data of EU nationals.  RCEL will be required to treat non-UK Nationals in the same way to ensure their data, once in the EU, is correctly handled.  Put simply, this regulation gives an individual control over how their data is used by both data controllers and data processors, and what communications they receive.


For The Royal Commonwealth Ex-Services League (RCEL), it means:

•       Ensuring that the right processes, procedures and policies in place to carry out data processing
•       And more generally; accurately recording and storing data and permissions, so that RCEL only contact those people who explicitly want to hear from you on behalf of RCEL.

1.      The new GDPR will replace the current ‘Data Protection Act (DPA, 1998)’ on the 25 May 2018.  It aims to standardise the way personally identifiable information is dealt with in terms of data processors (Controller Welfare RCEL) and data controller (The ‘Secretary General’ on behalf of The RCEL) that exist within the EU, or countries operating outside of the EU that process the data of EU nationals.

2.      A data processor is a person or organisation that processes data, and a data controller is a person or organisation that controls the data.

3.      All organisations including Charities that record the personal information of its members must be compliant with the new GDPR that will be introduced by the UK Government on 25 May 2018.  Under Article 5 of the GDPR it clearly states that organisations must handle all personal data as follows:

          a)  Processed lawfully, fairly and in a transparent manner in relation to individuals;
          b)  Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
           c)  Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
           d) Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
            e) Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
             f) Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Cyprus and Malta are within the EU and subject to full GDPR compliance.  RCEL has a responsibility to make all Members aware of the importance of good data control. Many Members will have in place data control measures similar to GDPR, but all should make every effort to comply with data handling principles as shown in paras 3 a-f (above).

4.         Failure to comply with GDPR compliance can lead to an organisation being fined up to €20m or 4% of its annual turnover (whichever is higher).

5.         Therefore to ensure that the RCEL comply with these new regulations I enclose a copy of our ‘Membership Privacy Policy Statement’ that gives clear guidance on why, how, where we use personal information and rights to see the information we hold and how you can ask for it to be deleted.

6.         You are kindly requested to ensure that when a potential welfare beneficiary is interviewed that they are made aware of their rights.  They should also be advised to read carefully the new Declaration at Part 13 on the RCEL Form A that will come into effect from 25 May 2018.  By signing the new Form A they agreeing to allow their personal data to be shared with appropriate organisations that RCEL feels are best placed to help their case.

7.         Your cooperation in this matter would be greatly appreciated.

8.         Attached to this email are:

             1.   RCEL Privacy Policy Statement
RCEL Form A (May 2018)

Should you have any questions, please email us at:
mgordon-roe@commonwealthveterans.org.uk

 

RCEL - Royal Commonwealth Ex-Services League - Registered Charity No. 1174874 - Haig House, 199 Borough High Street, London SE1 1AA, United Kingdom - Telephone +44 (0)20 3207 2413

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