The Carlton Club is committed to protecting and respecting privacy of Members. We take our responsibilities seriously and will only use the personal data we hold in accordance with the law.
This Privacy Notice sets out the basis on which your personal data is handled, stored and shared by us. Please read the following to understand what we do with your information.
1 Personal data we may collect from you
We will collect and hold a range of different information about you as a Member of the Club. This allows us to provide the services of the Club and keep in contact with you.
This information may include:
- a) Name;
- b) Date of birth;
- c) Home address (and second address);
- d) Telephone (home, office and mobile);
- e) Email (personal and work);
- f) Nationality;
- g) Bank account details;
- h) Education;
- i) Signature;
- j) Employment; and
- k) Date elected to membership.
We may also collect information about your family members, including, where applicable, family members under the age of 18 (minors). We do not knowingly collect personal information from minors without the permission of their parent or guardian.
2 How we use your personal data
We use your personal data to provide the services offered by the Club. This includes (but is not limited to):
- a) Administrating your Club membership;
- b) Facilitating bookings of meals and rooms;
- c) Contacting other members of the Club on your behalf;
- d) Circulating information about the Club;
- e) Organising social events;
- f) Organising external events;
- g) Administering and maintaining membership records; and
- h) Processing payments and maintaining accounts.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may occasionally request proof of identity before we disclose the information to you.
4 Third Party Sharing
4.1 Third parties
We will not share your information with third parties except in the following circumstances:
- a) To carry out functions on our behalf; and
- b) To organise external events (for which you have expressed an interest).
Such third parties may include the following:
- a) Reciprocal clubs, in order to facilitate introductions and bookings;
- b) External venues; and
- c) Selected suppliers of products and services to the Club.
Following your request, the Club can provide details about any third parties that process your data.
We will not share your information with third parties who intend to use it to send marketing content to you.
4.2 Disclosures and security
We will only share your information with third parties that have provided sufficient guarantees in respect of their data security measures. We require all third party contractors to undertake the same security measures that the Club would have to take if we were doing the processing.
4.3 Transfers abroad
We will only transfer your personal information to third parties based in countries outside the European Union in very limited circumstances.
5 The legal bases for processing your personal data
The GDPR sets out a number of different reasons for which an organisation may collect and process your personal data. We rely on the following legal bases:
› In specific situations, we will collect and process your information with your consent. We will always make it clear to you what you are consenting to and what information is necessary for which services.
› In certain circumstances, we need your information to carry out our contractual obligations.
› If we are required to by law, we may need to collect and process your information.
› In specific situations, we require your information to pursue our legitimate interests in a way which you might reasonably expect as part of running our business and providing the services of the Club, and which will not materially impact your rights, freedoms or interests.
In the case of special category data, we will seek your explicit consent in line with our obligations under the GDPR.
6 Your rights
The GDPR, which applies as of 25 May 2018, gives you certain rights over your personal information:
› Right to access your personal information;
› Right to have your personal information kept up to date;
› Right to have your personal information erased;
› Right to restrict our processing of your personal information;
› Right to have your personal information transferred from us to another organisation; and
› Right to object to our processing of your personal information.
› Right to lodge a complaint with the Information Commissioner’s Office.
You can submit a request to exercise any of these rights in accordance with the GDPR. It will be free of charge, except where we deem it unfounded or excessive.
A fuller explanation of each of these rights, and the formal request procedure, is available on request.
7 Changes to our Privacy Notice
The Club may update this Privacy Notice as appropriate. We will never materially change our policies or procedures to make them less protective of personal information collected in the past.
8 Contact us
If you have any questions, comments or concerns regarding this Privacy Notice or the way we handle your personal information, or wish to make any requests, please address these to:
69 St James’s Street