Metropolitan Grand Lodge (MetGL) and, by extension, Metropolitan Grand Chapter is committed to protecting the privacy and security of your personal information.
This privacy notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe, in accordance with the General Data Protection Regulations (GDPR).
MetGL is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
The Metropolitan Deputy Grand Secretary is designated the Data Protection Officer.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
- (‘lawfulness, fairness and transparency’) processed lawfully, fairly and in a transparent manner in relation to individuals;
- (‘purpose limitation’) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- (‘data minimisation’) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- (‘accuracy’)accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- (‘storage limitation’)kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;
- (‘integrity and confidentiality’) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
- (‘accountability’) The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1(a-f above).”
THE TYPE OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection. MetGL does not hold sensitive personal data about any of its members.
We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
- Date of birth
- Occupation
- Masonic contact details such as rank, style, offices held, roles and responsibilities and lodge/chapter information.
- In some instances, photographs
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about London freemasons from the registration forms submitted for new memberships as well as updates accumulated through the Installation and Annual Returns process. We may also ask for further information as part of the honours nomination process.
The Registration forms include a consent form and previous submissions remain valid under the legitimate purpose basis.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to adjust your central membership record due to a change in circumstance. This might be change of address, change of membership, etc
- Where we need to comply with a legal obligation
- Where we have your consent.
Please see our Data Security Policy.
If you fail to provide personal information
If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations or we may be unable to discharge our obligations which may be in the public interest or for official purposes.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be to evaluate prospective members’ suitability where such processing is necessary to carry out our obligations and provided we do so in line with our [data protection policy].
Less commonly, we may use information relating to criminal convictions comes to light and/or is already in the public domain where it is pertinent in relation to possible masonic disciplinary action.
AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
DATA SHARING
We hold the vast majority of your data on the central United Grand Lodge of England (UGLE) database [ADelphi2]. We access this data through a formal data sharing agreement with UGLE. We have limited permissions to add and/or amend entries about you.
This data may be shared with the Masonic Charitable Foundation where you have given your express consent, which is annotated on your record. Extracts of the central data may also be uploaded onto Rosetta for the information of other members of your Lodge as well as the visiting officer structure in its entirety.
We require third parties to respect the security of your data and to treat it in accordance with the law. Some of the organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might we share your personal information with third parties?
We will share your personal information with third parties where required by law, where it is needed in the public interest or for official purposes or where we have your consent.
Which third-party service providers process your personal information?
“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: database design and upgrade, IT and web-site management and design.
How secure is your information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. Third parties, such as IT specialists, will invariably be asked to sign a non-disclosure agreement prior to being given any access to personal data. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
From time to time, we may disclose your personal data in response to a data subject access request. We may approach you for your consent but, in any event, we will only disclose your personal data if we are satisfied that it is reasonable to do so in all the circumstances. This means that we may refuse to disclose some or all of your personal data following receipt of such a request.
Transferring information outside the EU
Currently no data is transferred out of the EU.
DATA SECURITY
We know how much data security matters and we will treat your data with the utmost care and take all appropriate steps to protect it.
Together with UGLE, we have put in place appropriate security measures to protect the security of your personal information. In addition, we limit access to your personal information to those who have a specified need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected and secured by SSL encryption.
UGLE regularly monitors their system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
DATA RETENTION
How long will we use your information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal and reporting requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a member of the Craft we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Due to the way we ensure business continuity through back-ups, our data and personal information is never completely removed. The backup copies of data are not available for direct access and would only be accessed in the event of data loss or to restore information and access is restricted to essential personnel. As a result, you should not expect that all of your personally identifiable information will be completely removed from our systems in response to such a request.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes (e.g. MCF).
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact The Data Protection Officer in writing.
The legal timescales for us to respond to a Subject Access Request is one calendar month. As we have limited staff resources, we encourage you to submit any Subject Access Requests during the working week and outside of closure periods of Freemasons’ Hall. This will assist us in responding to your request as promptly as possible. For further information about how we handle Subject Access Requests, please see our Data Protection Policy.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact The Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
DATA PROTECTION OFFICER
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will make available a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the Data Protection Officer at [email protected]