The UK's Finest Independent Forum for Shooters and Gun Owners. Est 2010.

As a Club Secretary, I've just received a request for info from the Local Firearms Licensing Co-Ordinator North. (Police Scotland), Requesting...............

1. A full list of current members names, addresses and dates of birth.
2. Confirmation of the type of membership they hold.
3. Confirmations of details of the current Secretary. (Me)
4. Confirmation of the details of the current Liaison Officer
5. Confirmation of our Scottish Government Registration number.

Please provide us with these details within the 28 days.

Surely this info comes under the GDPR??

How do I (& other local clubs) handle this diplomatically????

Re GDPR, there is certain information that you have to keep regardless of consent and also provide.

What do our representative bodies say?

I am assume that you are affiliated to one of them, surely this is an issue that they should give robust advice on.

Then again the current "national" policy across these bodies seems to be to have gun owners role over and get shafted to what ever is dumped upon us as they can't be bothered to challenge it and do their duty to their legal gun owning members.

Just thinking aloud here but they should be contacted for advice regardless of the uselessness of them.

There are six grounds for processing information under GDPR, some of them need consent from the data subjects, and some, legal obligations being one, do not.

In this instance, provided the request from the police has a legal basis, you can respond, and they can process the response, without getting caught by GDPR.

But as a club secretary myself, my greatest concern is a data breach, ie someone getting the data on the members that I hold to run the club with.

So what is Firearms Certification's legal basis for needing this information.

Oh this sounds good. Can't wait to see what Sim says on this.

I'd reply back quoting GDPR and saying you're asking for the information Commissioners Guidelines and in what context are you (they) asking for all this.?

https://www.muckle-llp.com/enews/gdpr-m ... ots-clubs/

By what authority are the police requesting mass information on club members.
What is the purpose of their request?
Have they had this info before and mislaid it?
Is there suspicion of a crime being committed, in which case you cannot tell the member his data has been requested?
Do you have the members permission to disclose this information to third parties?

What does the Club GDPR policy say about this?? I assume you have one, right????? I would think you'd need to tell every member that you're doing this.

This from a manual I helped put together...

"4.8 Law Enforcement Requests & Disclosures

In certain circumstances, it is permitted that Personal Data be shared without the knowledge or Consent of a Data Subject. This is the case where the disclosure of the Personal Data is necessary for any of the following purposes:


• The prevention or detection of crime.
• The apprehension or prosecution of offenders.
• The assessment or collection of a tax or duty.
• By the order of a court or by any rule of law.



Best bet: Advise the police you're contacting the Information Commissioner for advice under the GDPR rules.. ..........unless there's a LEGAL obligation for you to disclose mass information about the club to the police which (I assume) they already have?

Just my tuppence worth. The various Associations should have had this hammered out with the ICO /Police before now.

PS: The ICO website is full of "Ifs, unclears, buts and maybe's" and the get out that the Act is "evolving".

Not sure if this will help anyone - you need to keep a LOG all data requests too.

One of the issues is that they already have 99% of this info; just seem to want me to do half their job for them by resupplying the info. I've already done the list of members who haven't renewed or attended within last year; I actually gave them a current list of members at that time though I was under no obligation to do so. (just that it made it easier for me). Probably 90% of club members also have FAC's so they should already have all their dates of birth & addresses.
They already know, that I'm the Secretary, who the Liaison Officer is and I would have thought that they can easily find out our Scottish office/government registration number.

Hi

I based our club's GDPR policy statement on an example provided by STS (Scottish Target Shooting) and have attached it. Basically it tells members the what, why and how regarding their data. After publicising it (and making it available on our website) I have had no queries from our membership regarding their data.

I feel it is adequate to satisfy GDPR. If it would be of use to anyone else, drop me a pm and I will pass on an editable version.

Like Andy, in the past I have always supplied our local Licensing Dept. with a current list of members, along with the resignations and non-attendances. The only difference now is the addition of DOB. As members supply that when they join I don't see this as really changing what we do normally, other than the hassle factor.

I can only speculate that not all clubs supply sufficient info and that they are trying to standardise. Depending on your GDPR (or prior DPA policy) I don't see the addition of DOB as conflicting with this. I'm also assuming that they use the name, address and DOB to uniquely identify people when applying for a FAC or variation.

Donald

dromia wrote:So what is Firearms Certification's legal basis for needing this information.

I would say this is the point that matters.

David