EUROPEAN FEDERATION OF CAMPINGSITE ORGANISATIONS AND HOLIDAY PARK ASSOCIATIONS – PRIVACY NOTICE
INTRODUCTION
This privacy notice applies to the European Federation of Campingsite Organisations and Holiday Park Associations (EFCO&HPA) and is meant to help you understand what data we collect, and what we do with it.
We respect your privacy and are committed to protecting your personal information, which we call “personal data”. This privacy notice will tell you how we look after your personal data and about your privacy rights. It supplements any other notices and is not intended to override them.
WHO WE ARE
EFCO&HPA is the representative body of the campsite, holiday and caravan parks industry at the European level.
Data Controller (referred to as “we/us/our”)
EFCO&HPA is registered in France and our registered office is at EFCO&HPA, 105, rue Lafayette, 75101 Paris, France.
However the EFCO&HPA secretariat and websites are managed from the UK and can be contacted at:
EFCO&HPA
6 Pullman Court
Great Western Road
Gloucester
GL1 3ND
United Kingdom
Telephone:
(44) 1452 526911
Email:
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would appreciate the chance to deal with your concerns first.
CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed of any changes.
HOW WE COLLECT YOUR PERSONAL DATA
Personal data are defined as any information relating to a living individual from which he or she can be identified, such as a person’s name, address or date of birth.
The personal data that we collect consists mainly of the names and contact details of the representatives of each national trade association in EFCO&HPA membership and any other information necessary for the function of the secretariat.
You may give us data verbally or by filling in forms or by corresponding with us by post, phone, email or otherwise, for example when you:
-
become a member of EFCO&HPA
-
communicate with us
HOW WE USE YOUR DATA
We will only use your personal data when the law allows us to.
We have set out below how and why we plan to use your personal data.
Purpose/Activity
Lawful basis for processing including basis of legitimate interest
To register you with EFCO&HPA
Necessary for our legitimate interests (to maintain a membership list)
To manage our relationship with you which will include:
Notifying you about changes which are relevant to you
Necessary for our legitimate interests (to reply to communications sent to us and to keep our records updated)
We need to obtain, store and use information about you for legitimate business purposes - namely so that you can receive information. We may use information we hold about you in the following ways:
-
to let you know about meetings and circulate information
-
to notify you about changes to EFCO&HPA
We may combine information we receive from other sources with information you give to us for the purposes set out above (depending on the types of information we receive).
An important part of our work is communicating with you, telling you about our activities. To do so, we use personal information to keep in touch.
We will use the contact information you have given us to send you important information. This may be by post, email, text message or telephone.
VISITORS TO EFCOHPA.EU WEBSITE
We use Google Analytics to find out how people interact with our site.
Google Analytics stores information about what pages you have visited, how you arrived there and how long you spend on the site. Google Analytics does not collect or store any personal information used to identify who you are such as your name or address. We do not allow Google to use or share our analytics data. For more information about Google Analytics cookies go to Google Privacy Policy.
Links to external sites from our websites contain links to other third party websites. These websites are not covered by this Privacy Policy and EFCO&HPA is not responsible for the privacy practices within any of these other websites. You should be aware of this when you leave the websites and we encourage you to read the privacy statements of other websites.
COOKIES
For information about the cookies we use, and your ability to refuse them please refer to our separate Cookie Policy
CHANGE OF PURPOSE
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
However, if we need to use your personal data for a new purpose and the law allows us to do so, we will notify you and explain the legal basis for our actions.
DISCLOSURES OF YOUR PERSONAL DATA
Personal information is held on our servers. Access is restricted through the use of passwords. Records may be retrieved, consulted, adapted, modified, copied or deleted from time to time. We will endeavour to take all reasonable steps to keep all data accurate and up to date but we rely upon you to inform us of any material changes.
We may share your personal data with third parties set out below for the purposes set out below:
Name
Lawful basis for processing including basis of legitimate interest
Service providers for IT and system administration.
Necessary for our legitimate interests (using your data as we have described in this notice).
Our professional advisers including lawyers.
Necessary for our legitimate interests (complying with our legal obligations).
Government bodies that require us to report processing activities and other authorities.
Necessary for our legitimate interests (complying with our legal obligations).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
We do not transfer your data outside the European Economic Area.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those staff, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the confines of the law.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?
We will only retain your personal data 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.
You can ask us about the retention periods for different aspects of your personal data by contacting efco@bhhpa.org.uk.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We do not knowingly collect data relating to children.
No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CHANGES TO THIS PRIVACY POLICY
We keep our privacy policy under regular review. This privacy notice was last updated on 22 June 2018.