This policy covers data protection, electronic marketing, and the retention of information within the administration of the British Association of Vedic Astrology (“BAVA”). It is applicable to the activities of BAVA in the UK and internationally and BAVA’s committee. It also applies to events organised and promoted by BAVA and to its publications.
BAVA’s policy is to adhere to the requirements of the General Data Protection Regulation (“GDPR”), the Privacy and Electronic Communications (EC Directive) Regulations 2003, and such other legislation as may be applicable.
BAVA also aspires to follow best practice in so far as it relates to its activities.
BAVA needs to hold information about:
• Its members (“Members”);
• members of the public who (1) attend events undertaken or arranged by BAVA; or (2) express an interest in their activities; or (3) visit BAVA’s websites; or (4) otherwise wish to receive materials published or distributed by BAVA.
Hereinafter, the following terms shall have the following meanings:
• “we” and “us” shall mean BAVA;
• “you” and “your” shall mean or apply to all those persons listed above;
How we collect your information
We may collect your personal data in a few limited ways, namely:
• Directly from you, when you join BAVA, enrol on a course or participate in an event, when you make enquiries on our website, when you subscribe to receive BAVA’s newsletter, when you seek or gain employment with BAVA, when you interact with us during your time as a student or employee or Member or recipient of communication in various other ways (for example, where you alert us to a change in your contact details).
• From someone else who has enrolled you on a course or signed you up to an event on your behalf or (for example a family member, a fellow student or fellow Member who has provided us with your contact details for that purpose).
• From a third-party organisation in specific circumstances such as when they are assisting with or organizing an event or activity for or in conjunction with us.
We will not store or capture personal data through our website(s) without your prior knowledge and consent. Where personal information is so captured it will be used for the purposes set out in this policy.
When collecting data generally we will endeavour, whether by reference to this policy or otherwise, to ensure that you:
• understand why the information is needed, what it will be used for and what the consequences are in case you decide not to give consent to processing;
• so far as reasonably practicable, grant specific consent, either written or verbal for data to be processed; and
• have received sufficient information on why your data is needed and how it will be used.
The types of information we collect
We may collect the following types of personal data about you:
• Contact and communications information, including your contact details (including name, address, email address, phone numbers) and records of communications and interactions we have had with you);
• Demographic information, such as postcode, preferences and interests;
• Website usage data;
• Other information relevant to course enquiries;
• Certain other information, which you volunteer when participating as a student, employee or Member in our activities (for example, when attending courses, or events or in volunteering to assist in the operations of BAVA).
We may also collect data about your health or medical conditions, where you have volunteered this, for example so that we can cater for you when you attend a course or event or act as a volunteer for and on our behalf. We do not currently do this but may in the future.
This is held electronically by BAVA’s administration familiar with the rights and obligations surrounding your data.
Mailing groups are used for communications with students, Members and subscribers for events, activities, notifications and publications.
How we use personal data
Unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, personal data provided to us will be used for the purposes set out at the time of collection (which may consist of those purposes set out in this policy) and, where relevant, in accordance with any preferences you express.
If you require any information as to how processing for the new purpose is compatible with the original purpose, please contact BAVA through https://www.bava.org/contact/.
We will only use your personal data where the law allows. In general terms, save as set out elsewhere in this policy:
• personal data we hold is used for the purposes of administering or improving courses or events or other activities and publications; and
• your details will not be passed to any other organisation for any purpose.
If we are so permitted, you may receive from us details of activities run by or in conjunction with other organisations by post or email. You are free to opt out of receiving such communications from us at any time.
Where we have your consent and / or (if within the law) where this is necessary for our legitimate interests (or the legitimate interests of a third party), as applicable, we use your personal data for the following purposes:
• in the administration of courses, events, and activities including:
• general notifications to you about them; and
• receiving payment of course fees and other charges;
• where this is necessary for the performance of a contract (including any written terms and conditions relating to the same) with you;
• research and statistical analysis about the courses or events or activities we offer;
• communication about our activities or events and activities outside of BAVA that we think may be of interest to you;
• sending you the BAVA’s newsletter and journal, Gochara;
Please note that we may also use your data and share it with others where it is necessary:
• for us to comply with a legal obligation to which we are subject;
• to protect the vital interests of the data subject or of another natural person.
Personal data collected and processed by us may be shared with the following third parties, where necessary:
• Our employees and volunteers, for the purposes of administering courses, events, publications and activities organised by or in conjunction with us and giving you access to the benefits to which you are entitled.
• Our contractors, professional advisors, auditors or suppliers, including those providing IT services or data management services.
We do not sell your personal data to/with other organisations to use and, save as set out above, do not otherwise share it with other organisations.
We also use Constant Contact or MailChimp for promotional emails featuring BAVA’s news and events.
Cookies and how we use them
What is a cookie?
A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website.
Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.
• Analyse our web traffic using analytics packages: Aggregated usage data helps us improve the website structure, design, content and functions.
• Identify whether you are signed in to our website: A cookie allows us to check whether you are signed in to the site.
• Test content on our website
• Store information about your preferences: The website can then present you with information you will find more relevant and interesting.
• To recognise when you return to our website: We may show your relevant content, or provide functionality you used previously.
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.
Your marketing preferences
We will always respect your wishes in respect of what type of communications you want to receive from us and how you want to receive them. We wish to gain your prior consent to mailings including our newsletter and other transmissions by email. However, there are some communications that we may need to send you without your specific prior consent, for example, in order for us to fulfil our contractual obligations to you. Examples of these essential service communications are:
• Membership notifications such as notice of membership expiry.
• Mailings directly concerning your participation on a conference, course or at an event, notices of formal meetings, and notification about similar or related courses or events similar to one who are attending or have recently attended.
• Records of transactions, such as payment receipts or Direct Debit confirmations, booking confirmations (as applicable).
Controlling information about you
You are in control of how we communicate with you. You can update your choices and/or your contact details by sending an email to firstname.lastname@example.org.
You can also voluntarily unsubscribe from our newsletter and general announcement mailing list using the Unsubscribe feature on each mailing.
We will always hold your information securely.
We also follow stringent procedures to ensure we work with all personal data in line with the General Data Protection Regulation (GDPR).
Links from our sites
Our websites may contain links to other websites. Please note that we have no control of websites outside the www.bava.org and www.gochara.com domains.
How long your information is kept
We keep your personal data only for as long as necessary for each purpose we use it. You can voluntarily unsubscribe from mailing groups at any time.
Financial records must be retained for a period of six years after your last interaction with us (for accounting, tax reporting and record-keeping purposes).
Under certain circumstances, by law 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 information we hold about you corrected.
• 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 exercised your right to object to processing (see below).
• 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. You can also withdraw your consent, where this is the basis for our processing your data (without affecting the lawfulness of our previous processing based on consent).
• Request the transfer of your personal data to another party.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
Contact and complaints
If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner. You can find out more about your rights under applicable data protection laws from the Information Commissioner’s Office website: www.ico.org.uk.
Copyright © British Association for Vedic Astrology June 14th 2018