PEYC Legitimate Interests Assessment

Port Edgar Yacht Club

Legitimate Interests Assessment

  1. Purpose Test – are we pursuing a legitimate interest?
  • Why do we want to process the data – what are we trying to achieve?

The data that we hold is used to enable us to run club activities efficiently, keep members informed of events and developments and request payment of subscriptions.

  • Who benefits from the processing? In what way?

The club membership in general. The data enables us to inform them of events, important developments, impending duties and payments coming due.

  • Are there any wider public benefits to the processing?

No. The club does not use this data to communicate with the wider public. Some of the information on club events that we distribute to members using their email addresses is also published on our web site, which is available to the general public, but this would not include personal details.

  • What would the impact be if you couldn’t go ahead?

We would have to rely on members monitoring our web site to find out details of events and duties etc.

  • Would your use of the data be unethical or unlawful in any way?

No.

  1. Necessity Test
  • Does this processing actually help us further our legitimate interest?

Yes. The data that we hold and the way that we use it helps us run the club activities efficiently and keep the whole membership advised of events and other important issues.

  • Is it a reasonable way to go about it?

Yes. The membership of the club are aware that we use their data to help manage club activities. This includes duties which members cannot opt out of if they participate in racing. We do not share data with outside agencies and do not use it for marketing purposes.

  • Is there another less intrusive way to achieve the same result?

We do not believe there is.

  1. Balancing Test
  • What is the nature of your relationship with the individual?

Individuals are members of the club.

 

  • Is any of the data particularly sensitive or private?

The data we hold on club members is personal but not particularly sensitive. We do our best to keep it private and would share it only between members with the express permission of both parties.

  • Would people expect you to use their data in this way?

Yes we believe so.

  • Are you happy to explain it to them?

Yes. Our note to members detailing our privacy policy goes some way towards doing this. We are happy to provide more details if asked.

  • Are some people likely to object or find it intrusive?

We do not believe so. No one has ever objected to the way we use the data we hold about them.

  • What is the possible impact on the individual?

Members are kept informed of events and important developments within the club. They are also reminded of impending duties and payments coming due.

  • Are you processing children’s data?

No. We have a family category of membership which allows children to join the club but we do not keep any details of them. All communication is with their parents who also have to be club members.

  • Are any of the individuals vulnerable in any other ways?

Not that we are aware of.

  • Can you offer an opt-out?

We are willing to consider this but boat owners who participate in club racing have an obligation to help run these races. As we need a certain amount of data to enable us to manage this obligation they cannot opt-out completely.

 

Conclusion

We believe that legitimate interests is an appropriate basis for us to hold and process our club members’ data.

We hold the minimum amount of information necessary to enable us to efficiently run the club activities.

We do not share this data with outside bodies except in ways that members would reasonably expect us to: for instance bank details with their banks to facilitate agreed payments.

We do not use this data for marketing purposes or make it available to anyone else to do so.

Sharing of this data between club members will only take place with the express permission of all people involved.

Management of some of the club activities such as boat racing would be very difficult, if not impossible without access to the data that we hold.