Privacy Policy

GDPR, Cookies & Privacy Policy

 

We reserve the right to make changes to this Privacy Policy. The last modification was made 11th April 2018.

We are committed to safeguarding your privacy. Contact us at if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.

By using this site you consent to the Processing of your Personal Data as described in this Privacy Policy.

 

  1. What personal data does the SPA collect?

The data we normally collect includes names, addresses, telephone numbers and email.  We collect this data directly from our clubs and individuals.  We also collect data on judges by way of feedback forms.

For some of our data subjects we may have additional information such as committee memberships, club membership and distinctions.

We collect the images, scores and awards from competitions/exhibitions which may include personal data.

Data is published in the SPA Handbook and some data is published on the SPA website.

  1. What is our data protection policy?

The SPA complies with the principles of data protection (the principles) enumerated in the EU General Data Protection Regulation (GDPR). We will make every effort possible in everything we do to comply with these principles. The principles are:

  1. Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent about how the data will be used.

  1. Limited for its purpose

Data can only be collected for a specific purpose.

  1. Data minimisation

Any data collected must be necessary and not excessive for its purpose.

  1. Accurate

The data we hold must be accurate and kept up to date.

  1. Retention

We will not store data longer than necessary.

  1. Integrity and confidentiality

The data we hold must be kept safe and secure.

  1. What is this personal data used for?

We use data for the administration of club membership of the SPA; the production of the SPA Handbook; the communication of information; and the organisation of events. We provide data to the Photographic Alliance of Great Britain (PAGB) for their use as explained in section 4 below.

  1. Who is your data shared with?

Data on SPA committee members and officers is passed on to the PAGB for inclusion in the PAGB handbook.  Information about lectures and judges is passed on to the PAGB if they wish to appear in the PAGB Handbook.

Where images are selected on behalf of the SPA to represent in the SPA in PAGB competitions this information is also passed on to the PAGB for use in its competitions.

Where individuals are in the process of applying for PAGB Awards of Photographic Merit (APM) their details are passed on to the PAGB by the SPA APM Officer.

Your personal data is not passed on by us to organisations other than the PAGB whether or not connected with photography.

No data is shared with anyone outside the UK.

  1. Where does this data come from?

Data comes from clubs: when club members take on duties and responsibilities requiring an SPA contact; when clubs update their information directly when the SPA Handbook is published; or when they enter competitions/exhibitions.

Data comes from individuals: when they apply for an APM; when they enter an individual entry competition run by the SPA; or when they apply to or join the judges and lectures list.

Competition/exhibition data comes directly from the results of the competition/exhibition which you have entered or which your club has entered.

  1. How is your data stored?

This information is mainly stored in digital form on private computers with some back-up paper records held by SPA officersAny information that is stored remotely is stored in compliance with the GDPR and requires the explicit approval of the SPA Data Protection Officer.

  1. Who is responsible for ensuring compliance with the relevant laws and regulations?

Although under the GDPR (General Data Protection Regulation) we do not have a statutory requirement to have a Data Protection Officer the SPA has appointed a Data Protection Officer whose details are in the SPA Handbook.

  1. Who has access to your data?

Members of the committee and officers of SPA Clubs have access to data in order for them to carry out their legitimate tasks for the SPA and their clubs.  Officers of SPA clubs have access to data for specific legitimate interests such as contacting other clubs and the booking of lectures and judges.  They cannot use it for any other purpose.

  1. What is the legal basis for collecting this data?

The SPA collects personal data that is necessary for the purposes of its legitimate interests as a membership organisation and participant in nationally recognised exhibitions/awards/competitions.  At least one of the following two conditions must apply whenever we process personal data:

  1. Consent

We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.  We must also ensure that individuals whose data is being processed by us are informed of the basis for processing their data, as well as the intended purpose.  We do this by making this policy known when we seek consent.

  1. Legitimate Interest

The processing is necessary for our legitimate interests.

  1. How you can check what data we have about you?

If you want to see the data we hold about you, you should contact the Data Protection OfficerIf you are interested in any particular aspects, specifying them will help us to provide you with what you need quickly and efficiently. We will provide this to you within one month.  There is not usually a fee for this, though we can charge a reasonable fee based on the administrative cost of providing the information if a request is manifestly unfounded or excessive, or for requests for further copies of the same information.

  1. Does the SPA collect any “special” data?

The GDPR refers to sensitive personal data as “special categories of personal data”.

We do not record any such special data with the sole exceptions of:

data received from clubs on SPA judges feedback forms by the Judges and Lecturers Committee (where feedback shows a consistent pattern these are used to mainly assist new judges and for the purpose of enabling promotion to a higher level of judging).

data which may relate to the disabilities and special needs of individuals who have explicitly requested it to be recorded for the purpose of assisting them attend events etc.

  1. How can you ask for data to be removed, limited or corrected?

Contact the Data Protection Officer.

  1. How long we keep your data for, and why?

We normally keep club data for 2 years if clubs cease to become SPA members in case they later wish to re-join. However, we will delete any details entirely on request.  Data on other individuals is removed once they cease to be SPA judges, lectures, committee members, officers etc.  All Judges feedback forms are deleted within 3 years of receipt.

Since underlying statistical data, such as information from competitions/exhibitions continues to be necessary in relation to the purpose for which it was originally collected and processed, results from these events are not deleted.   Historical lists and award lists are required for archiving purposes and names cannot be removed from them.

Other data, such as that relating to accounting or personnel matters, is kept for the legally required period.

  1. What happens if a data subject dies?

We do not normally keep information after someone dies except for historical data outlined in 13 above.