General Data Protection Regulation (GDPR) and AARG
Prepared and approved by the AARG Committee
This
document
explains
our
responsibilities
with
respect
to
GDPR
and
describes
how
we
discharge
them
in
a
compliant manner and informs you of your rights under the new legislation.
What is GDPR?
GDPR
expands
existing
Data
Protection
Regulations
and
widens
their
scope.
It
requires
that
personal
data
on
members (“data subjects”) must be:
·
processed lawfully, fairly and in a transparent manner in relation to individuals;
·
collected
for
specified,
explicit
and
legitimate
purposes
and
not
further
processed
in
a
manner
that
is
incompatible with those purposes;
·
adequate,
relevant
and
limited
to
what
is
necessary
in
relation
to
the
purposes
for
which
they
are
processed;
·
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;
·
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;
·
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.
How does AARG comply?
Under
the
legislation,
AARG
becomes
the
‘Data
Controller’
for
the
personal
data
it
holds
on
current
members,
and
past
members.
That
data
is
held
within
a
a
membership
spreadsheet
(referred
to
as
the
'database')
compiled and controlled by the AARG Secretary. Our policy for compliance with GDPR is as follows:
·
AARG
has
a
legitimate
reason
to
hold
your
personal
data:
AARG
holds
personal
data
to
allow
it
to
service
members
in
regard
to
subscriptions,
event
organisation
and
general
communications.
We
retain
ex-members’
personal
data
to
allow
us
to
re-engage
with
them
to
entice
them
to
re-join.
Personal
data
relating
to
all
non-members
will
be
addressed
as
defined
in
item (vi) below on or before 25
th
May 2018 when the new regulations come into force.
·
AARG holds your personal data securely: All of AARG’s membership and ex-membership is the AARG
membership spreadsheet.
·
AARG
uses
your
personal
data
responsibly:
AARG
uses
the
personal
data
it
holds
solely
for
the
purposes
of
administering
the
Club.
AARG
does
not
disclose,
share,
sell
or
otherwise
distribute
personal
data
in
its
database
with
the
exception
that
Name
and
Callsign
is
included
in
the
membership
listing
on
the
AARG
public
website.
If
a
member
wishes
to
have
his
name
excluded
form
the
memberships
listing
on
the
AARG
website
he
should
inform
the
AARG
secretary
who
will
then
notify
the
AARG
website
webmaster.
It
should
be
noted
that
this
information is available on other public amateur radio data sources e.g. QRZ.COM, Callbooks etc.
·
AARG
allows
those
whose
data
we
keep
to
know
what
we
keep
and
why:
AARG
keeps
the
following
personal
data
for
entries
on
the
database
(note
that
not
all
entries
have
all
of
the
following
fields
completed):
Full
name
and
title,
salutation
(on
air
name),
primary
callsign,
other
callsign(s),
postal
address,
e-mail
address,
telephone
number(s),
information
related
to
subscription.
·
At
present,
some
personal
data
we
keep
on
members,
with
the
exception
of
any
notes
added
to
a
record
by
Administrators,
has
been
obtained
either
directly
from
the
member
or
from
publicly
available
sources
(e.g.
callbooks,
QRZ.com
etc.).
Under
GDPR,
we
will
be
retaining
this
data as it is necessary for AARG and in the interests of the individual member.
·
AARG
allows
those
whose
personal
data
we
keep
to
request
some
or
all
of
it
to
be
updated
or
deleted:
Only
the
AARG
secretary
can
delete
data
from
the
database.
If
any
person
would
like
personal
data
removed
from
their
database
record
they
should
contact
AARG
secretary
at
derek.secaarg@gmail.com
.
Members
may
access
and
update
their
own
primary
data
by
contacting
the
AARG
secretary.
This
is
also
how
any
inaccuracies
or
changes
in
your
personal
data
can
be
updated.
AARG
committee
members
who
have
access
to
any
data
are
legally
required
to
comply
with
all
of
the
conditions
of
GDPR.
Whilst
it
is
the
right
of
any
person
to
have
their
personal
data
deleted,
removal
of
personal
data
that
would
result
in
AARG
being
unable
to
service
a
membership
or
which
created
a
significant
ongoing load on any of our volunteers may result in that person’s membership being suspended.
Some
AARG
members
have
signed
up
to
the
AARG
groups.io
forum,
which
is
a
separate
web
based
'members
only'
forum.
AARG
members
can
register
if
they
so
wish
setting
their
own
passwords
which
are
not
visible
to
any
other
users
including
the
forum
Administrator.
A
copy
of
the
AARG
GPDR
will
be
posted
on
the
forum
and
the
same
rules
will
apply.
However,
it
should
be
noted
that
members
have
total
control
of
their
personal
data
and
can
remove
themselves
from
the forum at any time.
·
AARG
does
not
retain
personal
data
for
longer
than
is
necessary
for
the
reasons
it
was
held
in
the
first
place:
This
is
not
something
we
have
considered
before
but
now
need
to.
The
AARG
Committee
believe
the
following
periods
to
be
reasonable
to
allow
it
to
function
in
a
responsive manner:
·
Members: All data to be retained for the period of their membership
·
Ex-Members: All data to be retained for seven years after cessation of membership
·
AARG
has
a
nominated
Data
Protection
Officer:
The
Data
Protection
Officer
will
be
AARG Secretary the who may be contacted at
derek.secaarg@gmail.com
·
The
Data
Protection
Officer
will
be
responsible
for
informing
the
Information
Commissioners
Office
within
72
hours,
if
there
is
a
suspected
breach
of
security
affecting
personal data.
What needs to be done by 25
th
May 2018?
The
action
on
AARG
secretary
is
to
delete
personal
data
on
ex-members
where
that
data
is
aged
by
the
amounts shown in (vi) above. This will be completed before the deadline.
What do members & ex-members need to do?
If
you
are
content
for
AARG
to
hold
the
personal
data
we
do,
then
nothing.
If
you
would
like
to
see
any
data
we
hold
on
you,
or
require
any
of
that
data
to
be
updated
or
deleted,
then
please
contact
derek.secaarg@gmail.com