Another GDPR question, would appreciate help
buildersdaughter
Posts: 482 Forumite
Hello, I mostly post on Old Style. I have looked at the GDPR thread here, but feel it doesn't really apply.
I am secretary of our Village Hall. The only data I hold is the committee's names, addresses, phone numbers and emails. I thought that they had agreed to this by agreeing to be on the committee! But someone has told me I have to get specific permission. That part won't be difficult, but I am worried about this:
We put a list of committee members on the Village notice board, and I have been told that I can no longer do that.
We do have an 'anonymous' booking email, but I and other committee members use our own emails for most correspondence - do we have to change this?
We put 2 key holder telephone numbers outside the hall in case of fire or similar emergency - should we just put the numbers, with no names?
For events, we usually put 'contact committee members for tickets' - how can we do this? We are so tiny that getting a dedicated mobile seems excessive - especially given the poor mobile reception in our village!
I am struggling to understand this, I will be contacting the Voluntary Services support at our local council, but MSEers are usually helpful and clear, so I'd be grateful for any information and support.
Many thanks!
I am secretary of our Village Hall. The only data I hold is the committee's names, addresses, phone numbers and emails. I thought that they had agreed to this by agreeing to be on the committee! But someone has told me I have to get specific permission. That part won't be difficult, but I am worried about this:
We put a list of committee members on the Village notice board, and I have been told that I can no longer do that.
We do have an 'anonymous' booking email, but I and other committee members use our own emails for most correspondence - do we have to change this?
We put 2 key holder telephone numbers outside the hall in case of fire or similar emergency - should we just put the numbers, with no names?
For events, we usually put 'contact committee members for tickets' - how can we do this? We are so tiny that getting a dedicated mobile seems excessive - especially given the poor mobile reception in our village!
I am struggling to understand this, I will be contacting the Voluntary Services support at our local council, but MSEers are usually helpful and clear, so I'd be grateful for any information and support.
Many thanks!
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Comments
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buildersdaughter wrote: »We put a list of committee members on the Village notice board, and I have been told that I can no longer do that.
No problem at all as long as committee members expressly agree. Same with publishing phone numbers and emails on your website etc - get the committee members to agree in writing and you're sorted.0 -
Thank you very much. In the past we have had members who have requested not to have their details published, and I have respected that. For most of though, it is information that is public knowledge, and that is enough names for contacts.0
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Hopefully your local voluntary services will be helpful, but you may get conflicting information.
I agree with Pennywise, but it's worth pointing out that there are two bases on which you can proceed. One is explicit consent, the other is legitimate interest. I think you can claim legitimate interest - if someone is willing to serve on the committee, they've got to be contactable, at least by other committee members. However you still have to tell people what you're doing and allow them to object.Signature removed for peace of mind0 -
Thank you Sue. We do have explicit consent for most committee members (and we only need a few) for the notice board. I also have verbal (and will get written) consent to keep the committee list, as secretary. I also need, with advice, to ensure that new committee members are aware.
The person who initially explained it to me is being trained at work, and told us that we could not put names + contact details on the notice board, even with consent. I think that must be specific to her work (as it was with mine, years before this law) but she was adamant. I can't see how we can be accountable to the village if no-one knows who we are!0 -
I' secretary a similar sort of voluntary group - though not with any public facing data displayed.
I'm ignoring GDPR totally.
I did get one question about it - the usual reply is along the lines to all moans about anything being "don't care, not bothered - if you are then you can do this volunteer job instead"... strange to report that always results in the complainant going very quiet.0 -
I agree that consent (or legitimate interest) would be appropriate for publishing contact details on the notice board.
However, consent is NOT appropriate for your keeping the committee list (as secretary). Imagine that someone refuses; you wouldn't be able to function (similarly for the minute book if you have one). I suppose legitimate interest might be appropriate here, but one should always be cautious about resorting to legitimate interest; it is not just a get out of jail free card; I am not sure you can justify it.0 -
Now i am not saying i am right or wrong, but i think you can carry on as normal with how you do things as long as you have consent. You need a little folder, with signed consent forms, and an audit type document which shows what information you hold, how you use it, who you give it to etc etc
Would it be that difficult for you all to be able to use the anonymous booking email? I still don!!!8217;t think it will really matter0 -
Have you tried contacting the Village Halls Adviser at your local Rural Community Council? Legitimate interest should cover publishing names, tel number &/or email.0
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