About this policy
This policy explains when and why Pinhoe Target Shooting Club collect personal information about our members and how we use it; keep it secure and club member’s rights in relation to it. This includes full, probationary and social members, visitors and guests. We will collect, use and store personal data, as described in this Data Protection Policy when people engage in activities at the club.
We reserve the right to amend this Data Protection Policy from time to time without prior notice. You are advised to check our Club website regularly for any amendments www.pinhoe-tsc.org.uk. We will only share your personal data with any third parties as outlined below.
We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.org.uk).
Responsible person
For the purposes of the GDPR, The Club Secretary will be the “controller” of all personal data we hold about club members and others. The Secretary is responsible for making sure the club complies with the General Data Protection Regulation (GDPR). We will review personal data every year to establish whether we are still entitled to process it or not.
Member’s Rights
You have rights under the GDPR:
- To access your personal data
- To be provided with information about how your personal data is processed
- To have your personal data corrected
- To have your personal data erased in certain circumstances
- To object to or restrict how your personal data is processed in certain circumstances
For more details, please address any questions, comments and requests regarding our data processing practices to the Secretary.
Specific use and sharing of personal information
Your personal data (name, address, date of birth) will be used to notify the Police when you join the club and for any appropriate notifications as required by law. In general, your personal data will only be used for the purposes of membership management (renewals etc.); recording attendance at the club to fulfil legal responsibilities; your email and telephone numbers may be used for communication about news/work at the club/range closure, competition entries/results and other important notices etc. Your name/address and email address may be shared with our current National Governing Body (NSRA), organisers of competitions and the Charity Commission. Your personal data will not be passed to anyone else outside the club and your email address will only be given to someone outside the club with your permission.
The lawful reasons for processing your data
We have three lawful reasons for processing your data, which are:
(a) Processing is necessary for compliance with our legal obligation (Firearm Amendment Act 1988 c.45 Exemptions Section 15 – Firearms clubs
(b) Processing of your data is necessary for the administration of your membership contract.
(c) You have given consent to the processing of your data by signing our privacy statement for the specific purposes set out in this policy on our membership application form.
The tables below give further explanation of which lawful reason applies to which data, why we collect it and who we may be required to share it with. The club will make every effort to ensure data is only shared with organisations that are GDPR compliant.
What information we collect, why we collect it, and who we share it with
In addition to the reasons stated below we may have to disclose your data where we have an inescapable legal obligation.
Data process under our legal obligation
Requirements of Home Office Approval
The club is a Home Office Approved Rifle Club. This means that the club will
- Appoint a Police Liaison Officer – currently the Armourer.
- Maintain a register of attendance of all members with details of the firearm used.
- Inform the Police of any person other than a social member who has ceased to be a member for whatever reason.
- Inform the Police of any person other than a guest who has not shot at the club for a period of 12 months.
- Inform the Police of every application for membership giving the applicant’s full name and address, date and place of birth and the date on which they became a member.
Also see https://www.gov.uk/government/publications/approval-of-rifle-and-muzzle-loading-pistol-clubs
Type of information | Purpose | Shared with |
Members, probationary members and shooting guest’s names and address. | To meet our legal obligations | Committee and associated working groupsPolice and/or Home office representative |
Date and place of birth | ||
FAC details | ||
Club Attendance and firearms used | ||
Dates full and probationary membership commenced and ended. | ||
Section 21 declaration | Ensuring individual compliance with legislation |
Please note data processed for compliance with the Firearm Amendment Act 1988 must be kept for 6 years from the end of your membership and is therefore exempt for your right to erasure under GDPR.
Data processed as a requirement of managing your membership
Type of information | Purpose | Shared with |
Full members, probationary members, social members and shooting guests, address, telephone numbers, e-mail address | Managing the Member’s membership of the Club and club insurance purposes. | Committee and associated working groupsCharity Commission |
Dates full and probationary membership commenced and ended | Managing the Member’s membership of the Club and club insurance purposes. | |
Date of birth / age related information | Managing membership categories which are age related. Offering competitions and activities suitable for specific age-groups | |
Gender | Provision of adequate facilities for members and equality of opportunities for all. | |
FAC details | Duty of care to ensure firearms are being used lawfully on club premises | |
References | To check the applicant’s suitability for membership. | |
Disabilities | Provision of adequate facilities for members and equality of opportunities for all. | |
Emergency contact details | Contacting next of kin in the event of emergency. | Emergency services |
Member’s photograph | Included on Membership card and membership records | Worn while on club premises for anyone to see. |
First Aiders names | To provide a contact point in case of emergency | Members and probationary members |
Qualifications | RCO, Instructor and Coaching qualifications for quality assurance purposes | |
Competency | To record those who reach the required level of safety knowledge and practical shooting competency to move forward to full membership |
Please note data processed for compliance with insurance purposes must be kept for 30 years from the end of your membership and is therefore exempt for your right to erasure under GDPR.
Data processed with your consent
The club will seek consent in the application form before processing any information as outlined below.
Type of information | Purpose | Shared with |
Full, probationary and social members and shooting guests’ address, telephone numbers, and email address recorded on online attendance register or membership application form. | Managing the member’s membership of the Club. Recording attendance at the club to fulfil legal responsibilities. | National Governing Body (NSRA) and other shooting organisations e.g., British Shooting, County Associations etc. |
Date of birth / age related information. | Managing membership categories which are age related. Age related competition and training opportunities | |
Gender. | Provision of adequate facilities for members. Gender related competition opportunities.For the purposes of Reporting gender data. | |
Disabilities | Provision of adequate facilities for members. Providing competitive and other opportunities. | |
Competency | To record those who reach the required level of safety knowledge and practical shooting competency to move forward to full membership | |
Qualification | RCO, Instructor and Coaching qualifications for quality assurance purposes | |
Scores | For performance measures related to competition and selection.For media publicity of events | Names and scores will be published and therefore available for others to see from other clubs and shooting organisations. |
Photos and videos of members and their firearms | Recording on the Club’s website and social media pages and using in press releases. | With permission of the members |
Instructor’s name, address, email address, phone numbers and relevant qualifications and/or experience. | Managing coaching, instruction and supervision of shooting activity | Members, probationary members, other clubs and shooting associations and NGBs |
Member’s name, address, telephone numbers, e-mail address | Website access and newsletter distribution | Web and newsletter publishers |
Members are required to record their attendance at the club using the online system, currently SignInApp. Only if this is not available, the Record of Shooting paper form should be completed instead. Using the online system gives the club permission for the members’ details to be stored electronically. The club may be asked to share personal information we process about an individual and the name, address and email address with an appropriate National Governing Body (NGB). These include NSRA & NRA.
Enquiries and other communications with the club
When enquiring about the club we may hold your details for a period of time to deal with the enquiry. Any emails and other communications with the club will only be retained for a period of time appropriate to the content or request. Club emails will be purged on a regular basis. People added to a club waiting list for membership will be informed and asked for permission to store that data at that point.
Children
Parents or guardians signing the probationary or full membership form or completing the online attendance register, are giving their permission for the data to be used as described elsewhere in this policy.
How we protect your personal data
The Data Controller, Membership Secretary and Treasurer will process membership information electronically and hold all information on a database with backup of this information being held on password protected computer. If it is necessary to transport paper copies of data, it will be kept secure.
Coaches and instructors will also process and hold information pertaining to people under their instruction and necessary information will be made available to coaches and instructors only as required.
Names with competition scores will be published and available for other club members, members of other clubs, and shooting organisations to see. No other personal details will be shared without permission from the member.
For any online payments which we take from members, probationers, visitors and guests we will use a recognised online secure payment system.
In the unlikely event of a breach of the security of data we will notify members promptly and we will never sell or pass on your personal data.
Request to see your personal information
If you wish to know what personal data the club holds please email the Secretary ([email protected] ) and he/she will respond within 14 days of the request.
Accuracy and retention of data
Each individual member is responsible for keeping the Membership Secretary ([email protected]) informed of changes to their data (e.g. address/telephone number etc. and this is updated at least once a year at renewal and you are at that time authorising the club to hold such data on file.
The data will normally be kept for up to 7 years. It may be kept for a longer period for reasons of legal and civil action or other ongoing case management. Name, address and length of membership will be kept for up to 30 years for management of historical insurance claims. Names and scores may be kept indefinitely for reason of historical significance – e.g. on trophies, plaques and other awards.
CCTV Images
CCTV is used to record activities on the ranges at the club in the interests of safety, management of the ranges and crime prevention. Images/data are stored for 3 months for security and safety purposes and then these are over written. If required, the images can be transferred to a password protected memory stick within the 3-month period to be referred to at a later date.
For these reasons the information processed may include visual images, personal appearance and behaviours. This information may be about club members, potential members and suspected offenders, members of the public and those inside, entering or in the immediate vicinity of the area under surveillance.
Where necessary or required this information is shared with the data subjects themselves, Club trustees, committee members, police forces and persons making a legitimate enquiry, such as damage to a vehicle or theft captured on CCTV.
Any complaints which rely on this relating to theft/bullying/abuse etc. must therefore be made within 3 months of the incident otherwise the images will have been overwritten.
Policy updated by PTSC Secretary January 2023 and agreed during committee meeting dated 25/01/2023.