Not sure if this is the correct section, please move if not.
Just out of curiosity...
1) How is it that other associations and societies have not redacted back issues of their publications, which are available online? From what I can find, ont the 009 Society has done so.
2) As it is a EU law, must the UK still abide with it, post brexit?
Thanks.
Jim F
Hi Jim,
When we started to design the website I contacted the Information Commisioner's Office to ascertain how best we comply with the General Data Protection Act (GDPR) regarding the storage and use of member's personal information. This law is UK law and not an EU law we no longer need to obey.
The publishing of back issues of the 009 News online was discussed. The ICO representative raised the issue of permissions to display member's details online in the back issues. The problem is that anyone can insist that their personal details, e.g. addresses, email addresses and phone numbers be removed under GDPR if their permission to do otherwise has not be recorded. There is NO time limit on GDPR requests.
The problem is that members had not given their permission to publish their details on an online system, only in a published paper journal. We could have asked all present members to give permission, but as it could not be mandatory, we would still have had problems publishing online and still be liable for request to expunge historical data.
In light of this, and the possibility that any previous member going back to 1973 could make such a legally binding GDPR request, the Committee decided that all personal information in the digital copies of 009 News on our website should be redacted of personal information.
I proposed and supported that decision, despite my having to redact over 250 copies of 009 News so far! We live in a litigious age and I have no doubt that there may be an ex-member of the Society who may decide one day to wish the Society harm. A prosecution under GDPR carries penalties of up to £50,000 per offence and even if we should succeed in a defence, the legal costs alone could severly damage the Society.
I do not know what other groups and societies are doing to comply with GDPR, but I do know from having several hours conversation with the ICO that we should now be fully compliant with the terms of that act now, and for the future. Paper copies of every back issue of 009 are held by the Society Archivist and I am sure if it was neccesary he could provide contact details from a back issue to someone with the right to know that information.
I can understand why you did that and you were probably wise to do so, but our lawyers (Scout Association) advised that ADULT member's names in a news letter were legitimate interest so we should be fine.
I have to admit that the SHOULD didn't fill me with confidence.
Quote from: Stephen Rainsbury on March 22, 2021, 23:30
I can understand why you did that and you were probably wise to do so, but our lawyers (Scout Association) advised that ADULT member's names in a news letter were legitimate interest so we should be fine.
I have to admit that the SHOULD didn't fill me with confidence.
I can understand your trepidation Stephen.
This is the problem, there is virtually no case-law to set precedent on GDPR and the ICO will not tell you what to do, they will only guide you to making your own mind up regarding how you will comply. A very wooly approach that means that you cannot cite them as a defence in a GDPR case I suppose.
Displaying member's names I was told would be acceptable in the context of a club or society as legitimate use but anything of a personal nature such as an address, email address or telephone number could be classed as personal information under GDPR and as such could be challenged under the 'right to be forgotten' provisions. In the end the Society had a binary choice, do nothing and risk a problem in the future where we could have a constant trickle of GDPR requests that we would have had to respond to within 48 hours as per the GDPR rules, or redact the information to ensure that we did not have a cause for concern.
It has taken a lot of effort to redact the 20+ years of back issues but it only takes 5 minutes a month to redact each new copy as it arrives. At least I don't have to redact the whole membership list of 400+ members contact details which was published in 1973/4 in the days when the News was the only method by which members knew who else was a member!
Some may say we are over the top in our reaction, but I don't think so. It will only take a single case brought by a member or ex-member of an organisation to set a precedent regarding personal information in online journals and the proverbial will hit the ventilator for those that have not done what we have already done!
Perhaps could add a little to this.
In the 1970's and 1980's the full list of society members including their membership number, names addresses and even phone numbers were regularly distributed to all members of the society and these lists also appeared in 009 News from time to time. Lists of local members details were also given out to area group coordinators so they could contact them direct to either start a group or to increase attendance.
Times have changed and regardless of the legal situation this would be unacceptable to most members today as would making available any personal details that are in 009 News ins years past.
My personal opinion is that removing all the personal details from the 009 News editions that are available to members via the society web site is the only way forward in this regard.
Perhaps we need to look at this question in more depth.
1/. Only a minority of society members use this forum and possibly the sales dept itself on line. Why is that ?
2/. To help in the future, why not add a question ( tick the box) on the enrolment form.
Would you like your details to be known to other society members or kept secret ?
3/. If you go into the members list on this forum you can e-mail these members and I have always found them to be a very friendly
bunch of people.
Stan.
I think the problem here Stan is that your suggestion is sound but would be rather difficult to implement.
For example, it would only take one member to tick the box saying that his/her details are not for public dissemination and the poor individual who has the job of finding this guy/gal's details in 009 News back numbers would still have to wade through all sorts of stuff to do this - as we don't seem to have a magic HAL type supercomputer with all 2000 member's details in it that will automatically seek out all details published in 009 News, so I imagine that it is easier to redact everything that might be victim of of the Data Protection Secret Police in the first place.
Just an observation, I don't think it's worth opening up a big debate about it as it's already been decided by the Committee that this is the way the Society intends to proceed, irrespective of how it is viewed by other Associations and Societies who may have decided to either ignore or be less cautious of possible implications.
Mick
Quote from: Stan Williams on March 23, 2021, 10:57
Perhaps we need to look at this question in more depth.
1/. Only a minority of society members use this forum and possibly the sales dept itself on line. Why is that ?
2/. To help in the future, why not add a question ( tick the box) on the enrolment form.
Would you like your details to be known to other society members or kept secret ?
3/. If you go into the members list on this forum you can e-mail these members and I have always found them to be a very friendly
bunch of people.
Stan.
I 100% agree Stan I have also found members of the 009 Society to be a very friendly bunch of people.
However, in regard to old copies of 009 News it would be near impossible to separate those that wanted their details secret and those that would not.
There will also be many that are no longer members and others that have sadly passed away, who's surviving relatives may not want the details published, it would be far easier to just remove all the personal details.
You can indeed send a direct message to each member of this group, but this is done through the website, you do not get to see their e-mail address if it is withheld by the group member.
Other organizations use a system where you put your name, post code and email and then it sends an invite for anybody with a certain radius to contact you by return through the web page. Nobody gets to see somebody else's address.
Having said that I could just say here, does anybody within 20 miles of Banbury fancy meeting up for tea and cake with a view to working together?
Quote from: Stephen Rainsbury on March 23, 2021, 13:23Having said that I could just say here, does anybody within 20 miles of Banbury fancy meeting up for tea and cake with a view to working together?
You'd be lucky to get any response on here, Stephen. As several of us have advised others who have posed the same question this is what you must do:
1. Set up a separate thread saying you intend to try to set up a new group based around Banbury.
2. Write to the Editor of the News giving your contact details and asking that they publicise the proposed new group in the next News.
3. Contact the membership Secretary (details in the News) and ask for his assistance.
Off you go, now!!
I am certain there is still an Oxford Group which would be around 30 miles from Banbury, so maybe start there.
Remember it is compromise and you may have to travel, but that goes for everyone if they are interested enough.
If your are flexible there is no reason why it could not happen.
Stan.
There is Stan, the Oxfordshire group, and as Banbury is in Oxfordshire!
http://www.oxngm.org.uk/
Quote from: Stan Williams on March 23, 2021, 10:57
1/. Only a minority of society members use this forum and possibly the sales dept itself on line. Why is that ?
It's a good question, Stan, and I'm sure there are a number of answers. It's not so long ago that Society
Officers were almost unknown on the forum, let alone members, though I'm happy to say that this situation has greatly improved in recent times with Committee members frequent visitors these days. One answer must be that the relatively low volume of traffic here - certainly lower than on NGRM-online, which caters for a wider variety of tastes - is perhaps a disincentive to visiting the site - members may feel they're not missing much by not visiting the forum. Clearly this is a vicious circle, as the fewer visitors the less content and hence probably even fewer visitors. However, the opposite is also true, and the more people who do visit and contribute the more members may feel they are missing out by not checking the forum regularly (FOMO!), which has to be a Good Thing.
While I have no data to support it (does anyone have a counter anywhere to show site traffic?) my impression is that there has been a distinct upturn in forum traffic over recent months, and certainly there appear to have been quite a welcome number of new names and faces here of late. So maybe things are moving in the right direction, and long may that continue.
As for online Sales, while I think it's fair to say the response to the initiative has been gratifying to date there will always be members who perhaps just prefer not to buy online for various reasons. All we can do is make the offering as attractive as possible. The response to the launch of online Sales has presumably been helped by there not having been any exhibitions or shows in recent months where members could spend their pocket money, and once these resume online sales figures may dip accordingly. We shall have to wait and see. But it would not be a problem as long as members still have access to the service by either route.
David.
P.S. I'm sure I'll be corrected if I'm wrong, but I'm not sure there are any legal issues with divulging members' personal details
solely to other members in a 'private' association [the
News is only sent to members]. (What happens after that is another question.)