Privacy Policy

1. Background.

a. On 25 May 2018, the new General Data Protection Regulation (GDPR) comes into force. This will operate across the EU and in UK it supplements the existing Data Protection Act (DPA). More about the GDPR and its relationship to the DPA can be found on the website of the Information Commissioner’s Office (ICO) at ico.org.uk. The ICO is the body responsible for implementing the legislation.

b. The general thrust of the GDPR is to give extra duties to organisations, such as the FIA, which hold Personal Dataand extra safeguards to those members of the public, such as FIA members, whose personal data is held. Organisations holding personal data are called Data Controllers.

c. The purpose of this Privacy Policy is to explain how the FIA obtains and manages Personal Data for which it is Data Controller as well as to set out its general approach to privacy and compliance with the GDPR.

d. The FIA takes its privacy and data protection obligations seriously and is registered with the ICO (Registration Ref: ZA335714).

2. About the FIA.

a. The FIA is an unincorporated members’ association. (It is neither a charity nor a company.)

b. The registered address is: c/o Falkland House, 14 Broadway, London, SW1H 0BH

c. There are no paid staff and it is administered by unpaid volunteers who work from home.

3. The FIA’s Main Object.

a. The FIA has a foundation document which sets out its constitution and states that its main object is to: "assist the people of the Falkland Islands to decide their own future for themselves in accordance with their own wishes."

b. To this end the FIA has members who pay an annual subscription; it publishes and distributes a Newsletter twice per year; it engages with academics, journalists and others who have an interest in the future of the Falkland Islands; it holds an annual wreath laying ceremony in London; it organises other events and activities from time to time to enhance public awareness of the rights of the Falkland Islanders to decide their own future; it stands ready to mobilise public opinion in support of the Falkland Islanders if ever it seems that their future is to be decided without their consent.

4. Why do we hold and process personal data?

We hold and process the personal data of members and supporters for such reasons as:

a. To enable us to maintain contact with them to facilitate the distribution of the Newsletter, information on special events and news which may be of interest to those that support the objects of the Association.

b. To keep a record of subscriptions made by members and communications with them.

c. To keep a record of donations made by supporters, who are not also members, and communications with them.

d. To ensure we do not send unwanted information to supporters or members of the public who have informed us that they do not wish to be contacted.

5. Legal Basis.

Under the GDPR we are obliged to explain the legal basis for holding and processing personal data. We do this in accordance with Article 6 of the GDPR using the justification of "legitimate interest”. By joining the Association and paying a subscription, members indicate their interest in and concern for the future of the Falkland Islands. Therefore, we assume that they are content to be contacted from time to time in connection with the Objects of the Association providing the contacts are relevant and not unreasonably frequent.

6. How and when do we collect information about you?

a. The FIA only collects, stores and processes information which you give us.

b. We do not acquire information from other sources such as the internet or social media.

7. What information does the FIA collect about you?

Most information is provided during the membership joining process and includes:

Name

Membership type (Honorary, ordinary, corporate etc).

Address

Telephone numbers

Email address

Date joined FIA

Subscription payments

Method of subscription payments (cheque, standing order etc)

Whether a printed copy of the Newsletter is requested

Reason for interest in the Falkland Islands

 

8. What does the FIA not collect?

We do not collect or process personal information on such things as:

Bank details (although we see your bank details when you send us a cheque)

Credit card numbers

Age

Marital status

Health status

Political affiliations

 

9. How will the FIA use your data?

The FIA will use your information for example to:

a. Send you a copy of the Newsletter and other information relevant to the Association’s work.

b. Administer your membership including reminding you about subscriptions overdue.

c. Draw your attention to any development relating to the Falkland Islands which we think might be of interest or concern.

d. Thank you for any contribution you have made to the Association by way of money, or time, or skills.

e. Respond to any correspondence or query from you.

10. Will the FIA share your personal information with anyone?

a. We will only use your information within the FIA for the purposes for which it was obtained.

b. The FIA will not, under any circumstances, pass your details to any other person or organisation without your explicit consent which must be obtained on every occasion.

c. However, we will comply with legal requests from authorised, official bodies (eg, the police, HMRC etc) where disclosure is required or permitted by law.

11. How long will the FIA retain your personal information?

a. We will retain your personal information so long as you remain a member.

b. We will delete your details 12 months after you have ceased to be a member or at any time at your request.

12. Can I see what you hold on me?

Under the Data Protection Act you have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

13. How does the FIA keep my data safe?

a. Your information is stored on an electronic database hosted by a reputable company under secure conditions. It is kept completely separate from the website. Access is over the internet by password and the only people who use it are selected and authorised members of the Executive Committee.

b. Distribution of the Newsletter is carried out by the company which prints it. We provide distribution lists from which the printer creates mailing labels. The printer understands that these lists are to be treated as confidential, deleted immediately after use and never passed to a third party.

14. When and why we will contact you?

The FIA will contact you from time to time for the purposes set out in Paragraph 9 above. We will avoid repeated communications on the same subject. Telephone calls will not be made at unsocial hours.

15. Website and Internet Aspects.

a. This privacy policy only applies to our website www.fiasssociation.com Third party sites that are linked from our site are not covered by the FIA Privacy Policy and you should check the privacy policy for the site in question to determine how your information will be used when visiting that site. Note that sites outside the UK and/or EU may not be covered by the GDPR or equivalent.

b. PayPal. PayPal requires us to explain that PayPal and the FIA each have their own, independently determined privacy policies, notices and procedures for the personal data they hold. They are each a data controller (and not joint data controllers). They should both:

(1) Implement and maintain at all times all appropriate security measures in relation to the processing of personal data;

(2) Maintain a record of all processing activities carried out during PayPal transactions; and

(3) Not knowingly do anything or permit anything to be done which might lead to a breach by the other party of the data protection laws.

c. Cookies. Cookies are used on the website. Information on their use is contained in a separate cookies policy document which may be viewed on the website.

16. Data Exchanges with the Falkland Islands.

As at May 2018, it is unclear whether the GDPR applies in the Falkland Islands.

17. How to complain about this policy and raise privacy concerns.

If you wish to have more information, wish to make a complaint, or have any questions about this policy, please contact the Hon Secretary by:

a. Emailing: honsecfia@msn.com

b. Writing to: The Falkland Islands Association, c/o Falkland House, 14 Broadway,

London, SW1H 0BH

c. Telephoning: 020 3764 0824 (calls to this number are automatically routed to the

Hon Secretary at his home).

18. Changes to this Privacy Policy.

This Privacy Policy may be updated from time to time to ensure we keep in line with the law and best practice.

19. Date Last Modified.

21 May 2018.



[1] Personal Data means any information relating to an identified or identifiable natural person.

[2] A Data Controller is a person who, either alone or together with other persons, determines the purposes for which and the manner in which any personal data are, or are to be, processed.