GDPR Members Privacy Policy Notice

Wessex 4×4 Response is a Charity and is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us as a volunteer supporting the charity, in accordance with the General Data Protection Regulation (GDPR).

This applies to all Members, Support Members and anyone directly participating in or on behalf of Wessex 4×4 Response.

Wessex 4×4 Response is responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy notice.

This notice applies to current and former members and participants. This notice does not form part of any contract and does not seek to create one and we may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles:

We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date (to which all Members have access to the ARM (ACTIVE RESPONDER MANAGER) system to see their personal data, it is the sole responsibility of every individual to ensure that their information is correct and up to date).
Kept only as long as necessary for the purposes we have told you about.
Kept securely

Information held:

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Date of birth.
Gender.
Driving licence details inclusive of, but not limited to, any restrictions or penalties.
Vehicle details inclusive of, but not limited to, registrations, insurance, tax and MOT records.
Equipment details.
Details of professional qualifications (where necessary).
Details of radio licences, call signs or other relevant licences and insurance in relation to your activities with the charity.
Next of kin and emergency contact information.
National Insurance number where it is applicable or required to do so.
Bank account details.
Start date.
Location of employment or workplace.
Performance information.
Disciplinary and grievance information.
Media footage with regards to videos and photographs from incidents, events and deployments.
Social Media account information.

We may also collect, store and use the following “special categories” of more sensitive personal information:

Information about your health, including any relevant medical conditions.
Information about criminal convictions and offences.
DBS and NPPV vetting records and responses.
Personal complaints or records of incidents which may result in an adverse insurance liability, claim or PR risk.
Passwords / Login Details for the ARM (ACTIVE RESONDER MANAGER) online system, our website (where applicable) and SharePoint systems.

How is your personal information collected?

We collect personal information through the application and recruitment process directly from you. The remaining information is stored.

We may collect additional personal information in the course of related activities throughout the period of your membership.

How will we use information about you?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where there is an active deployment, incident or event which you are involved in or linked to.
To facilitate the operation and running of the Charity inclusive of making members’ basic details available to other members for the purpose of internal communication and organisation.
Where we need to perform the contract we have entered into with you or with another party which requires or facilitates your involvement
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes.
Where there is deemed to be an emergency situation with a risk to life of you or another, a national emergency or a situation which is classed as a major incident by the emergency services. In any such case Wessex 4×4 Response is entitled to pass on relevant information without consent where it is deemed necessary to do so in the circumstances.

Situations in which we will use your personal information:

We need all the categories of information in the list above primarily to allow us to manage your membership of Wessex 4×4 Response and to facilitate you participating in deployments, events and incidents. Further to enable Wessex 4×4 Response to comply with any legal obligations placed on us. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

Making a decision about your recruitment or membership or removal from Wessex 4×4 Response.
Determining any restrictions on or terms for your involvement with Wessex 4×4 Response.
Paying to you any expenses claims for your involvement with us as per the terms of the charity and each event or incident as advised on a case to case basis.
Providing the following benefits to you:
- Facilitating your involvement with Wessex 4×4 Response.
- Keeping in contact with you to keep you informed.
Your personal safety and wellbeing.
Administering any contracts we have entered into with you or with a third party you are directly applicable to as a member.
General internal communication.
Event organisation, planning and invitations.
Management and planning, including accounting and auditing of the charity accounts.
Making decisions about your continued participation.
Education, training and development requirements.
Dealing with legal disputes involving you, or other members including accidents whilst involved with or implicating Wessex 4×4 Response.
Complying with health and safety obligations.
To monitor your use of our information and communication systems to ensure compliance with our IT policies.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information:

If you fail to provide certain information when requested, we may not be able to properly manage your membership and involvement with Wessex 4×4 Response or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our Members). This may prevent your membership from continuing or it may temporarily remove your ability to be involved with Wessex 4×4 Response until it is received.

Change of purpose:

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Use of particularly sensitive information:

”Special Categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

In limited circumstances, with your written consent.
Where we need to carry out our legal obligations or exercise rights in connection with your involvement (specifically in relation, but not limited to, criminal records and suitability)
Where it is needed in the public interest, such as for equal opportunities monitoring.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate activities with the appropriate safeguards.

Do we need your consent:

We do not need your consent if we use special categories of your personal information to carry out our legal obligations. In some circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Criminal convictions:

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions.

We note that in most cases any criminal convictions will prohibit involvement with Wessex 4×4 Response and all cases are independently reviewed on a case-by-case basis by the Trustees of the Charity at that time. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you participating in and/or being a member of Wessex 4×4 Response. Where this is applicable we will inform you of the implications privately.

Automated decision-making:

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

Where it is necessary for the operation of the ARM (Active Responder Manager) system which is our partly automated membership and incident management and control system.
Where it is necessary to manage your membership.
Where these is a Health and Safety risk to any member or a risk to you personally.
Where it is necessary to safeguard your rights.
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard you.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

Data sharing:

We may have to share your personal data with third parties, including third-party service providers.

This will be to enable the functioning of the ARM (Active Responder Manager) system and the other systems used by the Charity from time to time for emails and calendar management and for the conveying of information such as, but not limited to, Office 365 / SharePoint or in the course of an exercise or deployment. In such circumstances it
will be necessary to provide our service users, such as (but not limited to) the emergency services, local council, NHS, emergency responders etc. for the protection of you and the service users and for adequate checks and information sharing.

In each case only the necessary information in the circumstances to facilitate your involvement will be given. This will often include, but not be limited to, you name, telephone number, vehicle type and registration for communication, safety and security needs.

We require third parties to respect the security of your data and to treat it in accordance with the law.

If we do share data you can expect a similar degree of protection in respect of your personal information as a result.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

How secure is my information with third-parties?

All third-parties are required to take appropriate security measures to protect your personal information in line with our and their policies. We do not allow our third-party service providers to use your personal data for their own purposes save for during an active deployment or incident. Save for information which must be retained in relation to legal obligations or in relation to any incidents all personal information must then be deleted. This is a legal obligation placed upon them directly. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data retention:

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

As the law provides a limitation period for Personal Injury Claims of three years and Contractual Claims of six years we may need to hold certain information for these periods to protect the charity against any future claim for losses resulting from a time during which you were a member. In such circumstances your personal data will be held securely with limited access to the Trustees of the Charity.

Rights of access, correction, erasure, and restriction:

Your duty to inform us of changes:

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. You have access to your information that we hold on your personal ARM (Active Responder Manager) account at any time. It is your obligation to update this regularly and to inform us of any inaccuracies.

Your rights in connection with personal information:

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information however this right is limited by our legal and contractual obligations as noted above.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes however we do not currently envisage that we will be undertaking any such activity save for the use of photographs and videos from Wessex 4×4 Response events and deployments. If this position changes we will of course let you know.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the current Trustees of Wessex 4×4 Response in writing.

Fees:

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you:

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent:

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Wessex 4×4 Response Trustees in writing.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection lead:

We are not currently required to have a Data Protection Officer. There is however an appointed Trustee of Wessex 4×4 Response who is responsible for Data Protection. This can be confirmed in the ‘Trustee’ list under the Members tab of the ARM (Active Responder Manager) online system or by emailing trustees@wessex4x4response.org.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice:

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Consent:

In applying to Wessex 4×4 Response for membership, undergoing foundation training and continuing membership inclusive of (but not limited to) the payment of subscription fees all members are as a contingent requirement positively opting into and consenting to this Policy and the Charity’s policies and constitution as a whole. Part of the recruitment and training process involves a positive decision and declaration to follow the rules and procedures of the Charity of which this is one and the voluntary provision of personal information, by you, which is fully within your control at all times through ARM. By continuing membership, taking active involvement and maintaining subscription fees you confirm that you have read and understood the policies of the charity, inclusive of this one, and that you consent absolutely. It is therefore agreed between the Charity and all members that this is a positive action and indication of consent.