The European Union (EU) General Data Protection Regulation (GDPR) will come into force on the 25 May 2018. The GDPR will provide a set of standardised data protection laws across the EU making it easier to understand how data is being kept, stored and for what purpose. The Heavy Transport Association (‘HTA’ / ‘we’) is legally obliged to protect any Personal Data or information held and will only hold and use those details as legitimately necessary in the administration of the HTA.
· What data is collected and what we use it for. We retain the e-mail address, telephone number and correspondence address of the membership point of contact. This is Personal Data. We use such Personal Data for the administration of your membership, the communication of HTA information to you and the organisation of HTA events. There are industry publications such as “Heavy Torque” and the “HTA Yearbook” and industry events such as “The Heavies” industry awards gala dinner managed by media specialists. The HTA sees these publications and the annual event as beneficial to members of the HTA and has secured certain benefits such as complimentary circulation of the HTA Yearbook and Heavy Torque to members. To facilitate this membership information is supplied to Nimble Publishing Limited on the strict basis that the information is only used for the sole purpose of facilitating delivery of such publications to HTA members and the promotion of “The Heavies” and “The Heavies” awards. The HTA regard this as a lawful and legitimate use of member’s information as it is in the HTA’s legitimate interest in terms of promoting the benefits of membership of the HTA (as published and communicated to members) and we believe it would be in the members’ reasonable expectation the HTA would use their information in this manner.
· What we do to ensure your data’s security. Your data, held by us, including our main database, is stored in digital form on computers and servers which are encrypted, and password protected in compliance with the GDPR.
· Where we get it from and to whom we give it. The information is received in accordance with the membership application procedure. We will not share your contact details with anyone outside of the HTA although historically membership data has been shared with Nimble Media Limited an entirely separate organisation to the HTA for limited purposes of circulating Heavy Torque and the HTA Yearbook and promoting “The Heavies” industry awards gala dinner. In order to continue to receive the HTA Yearbook and Heavy Torque publications (currently published by Nimble Publishing Limited (Nimble Publishing) an entirely separate organisation to the HTA) we will continue to provide your information to Nimble Publishing for the above mentioned purposes.
· Who is responsible for ensuring compliance with the relevant laws and regulations? Under the GDPR we do not have a statutory requirement to have a Data Protection Officer. The HTA is responsible for ensuring the HTA discharges its obligations under the GDPR and Nimble Publishing is equally responsible for discharging its obligations under GDPR in relation to your Personal Data howsoever obtained processed by them. This includes maintaining a log of data breaches and notifying the ICO and any members of such breaches as necessary in accordance with legal obligations.
· Who has access to your Personal Data? The Secretariat (administered by Dyne Solicitors Limited) has control of and access to the data for them to carry out their legitimate administrative tasks on behalf of the HTA, such as responding to members’ enquiries and notifying meetings and other relevant information concerning the business of the HTA. Members of the committee may be given access to this data for any legitimate purpose in accordance with their roles as officers of the HTA but will not be free to pass it on to any other organisation or entity. The membership data is protected data meaning that it can only be utilised for restricted purposes linked to the administration of the HTA or for the purposes of mailing the HTA Yearbook and Heavy Torque or informing members of “The Heavies” industry awards gala dinner.
· Your Personal Data will not be shared with any third parties for any purpose other than for the purpose of enabling the mailing of Heavy Torque and the HTA Yearbook both being publications produced by Nimble Publishing as described above. The HTA has agreed with Nimble Publishing as to how Nimble Publishing may utilise your Personal Data or information but this is limited to sending you such publications and information concerning events as mentioned above.
· What is the legal basis for collecting the data. The HTA undertakes to collect and use your Personal Data in compliance with the GDPR. Our legal basis for processing this data is our legitimate interest as a membership organisation and in meeting the expectation of the members that they will be sent relevant and topical information from time to time concerning the abnormal loads industry, HTA meetings, and general industry liaison meetings including the Heavy Torque and HTA Yearbook publications produced by Nimble Publishing and industry events managed by Nimble Publishing.
· How long we keep your data. We will keep your data for the duration of your membership of the HTA. When your membership terminates for any reason your Personal Data will be deleted from our database subject to our legitimate interest in retaining your data for any reason (e.g. to collect an unpaid subscription). We will notify Nimble Publishing that you are no longer a Member of the HTA who will remain responsible for any of your Personal Data held by them.
· Your Rights
You have the following rights, which you can exercise free of charge:
(i) Access: The right to be provided with a copy of your Personal Data (the right of access)
(vi) To object:
If you would like to check your personal information held by us you can contact the HTA with a ‘Subject Access Request’ at the following address: info@HTA.uk.net. Similarly, you can contact Nimble Publishing with a ‘Subject Access Request’ by contacting Andy Adams at the following address: email@example.com.
This Privacy Notice explains your relationship with the HTA and how the HTA will manage your Personal Data. If you engage directly with Nimble Publishing and provide them with consent to use your Personal Data or if Nimble Publishing processes your Personal Data obtained by any other means or on any other lawful basis then Nimble Publishing will be responsible for how your Personal Data is managed and processed by them.
The Heavy Transport Association,