Associations, clubs and non-profits.
WHAT THEY HOLD
Member details Subscription and payment records Attendance Photographs Sometimes health or dietary information Volunteer records
WHY THEY FREQUENTLY OVERLOOK OBLIGATIONS
Absence of commercial activity is assumed to mean absence of duties.
WHAT THE POSITION ACTUALLY IS
The rules apply regardless of profit motive.
WHAT LAWFUL BASIS USUALLY APPLIES
Contract, for membership administration Legitimate interests, for related activity Consent, for photographs and marketing
WHAT PHOTOGRAPHS REQUIRE
A choice, particularly where children are involved.
WHAT TO DO ABOUT MEMBER DIRECTORIES
Ask before publishing anyone's details.
WHY
Publication to other members is disclosure.
WHAT TO BE CAREFUL WITH
Committee members holding data on personal devices Spreadsheets circulated by email Data retained after membership ends
WHY THE FIRST ONE MATTERS MOST
Volunteers change, and data leaves with them.
WHAT TO ESTABLISH
One authoritative record, centrally held.
WHAT TO DO WHEN OFFICERS CHANGE
Transfer the data properly, and remove old copies.
WHAT RETENTION TO SET
A defined period after membership ends.
WHAT TO PROVIDE
A privacy notice, however brief.
WHAT TO ASSIGN
Responsibility to a named role, not a person.
WHY
Roles persist; individuals rotate.
