Last updated: 05/10/25
1. Introduction
1.1 Elgin Miniature Rifle Club (“we”, “our”, “us”) is committed to safeguarding the privacy of our website visitors, members, and service users. This policy explains how we handle your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1.2 You will be asked to consent to our use of cookies in accordance with this policy when you first visit our website.
2. Credit
2.1 This document includes elements based on a template from SEQ Legal (http://www.seqlegal.com), adapted for UK data protection law and for our specific club operations.
3. How We Use Your Personal Data
3.1 This section explains:
-
The categories of personal data we may process;
-
The purposes for which we process personal data; and
-
The legal bases for that processing.
3.2 Usage Data
We may process data about your use of our website (“usage data”), including your IP address, geographical location, browser type, operating system, referral source, visit duration, and navigation patterns.
Purpose: To analyse and improve website performance.
Legal basis: Legitimate interests – monitoring and improving our website and services.
3.3 Account Data
We may process your name, email address, and login credentials (“account data”).
Purpose: To operate our website, provide account access, and maintain security.
Legal basis: Consent and legitimate interests – managing member access.
3.4 Profile and Membership Data
We may process personal data such as your name, address, date of birth, contact details, and membership information (“profile data”). This may also include identification or reference details required for membership approval under Home Office guidelines.
Purpose: To manage club membership, verify eligibility, communicate about renewals, and maintain member records.
Legal basis: Performance of a contract (membership management), legal obligation, and legitimate interests – ensuring the integrity and safety of our membership base.
3.5 Disclosure to Police Scotland for Background Checks
As part of our compliance with Home Office regulations for approved shooting clubs, we may share relevant personal data with Police Scotland to conduct mandatory background checks for new and renewing members.
Purpose: To verify member suitability and meet statutory obligations.
Legal basis: Legal obligation – compliance with firearms legislation and Home Office guidance.
3.6 Service Data
We may process data you provide in connection with the use of our services (“service data”), such as name, address, telephone number, and email.
Purpose: To deliver and support our services, ensure security, and maintain backups.
Legal basis: Legitimate interests – proper administration of our website and services.
3.7 Enquiry and Correspondence Data
We may process data contained in any enquiry or correspondence you send to us.
Purpose: To respond to your queries, manage records, and improve communication.
Legal basis: Consent or legitimate interests – proper administration and correspondence management.
3.8 Notification Data
If you subscribe to club newsletters, updates, or notices, we may process your name and email address (“notification data”).
Purpose: To send relevant notifications, membership communications, and club updates.
Legal basis: Consent.
3.9 Financial Data
We do not collect, store, or process any financial or payment data through this website.
All membership fees and other payments are handled via direct bank transfer, cash or cheque between members and the club’s bank account.
Purpose: Not applicable – no online payment processing is performed.
Legal basis: Not applicable – no financial data is collected.
3.10 Legal and Compliance
We may process personal data where necessary to comply with legal obligations, protect vital interests, or defend legal claims.
4. Providing Your Personal Data to Others
4.1 We may disclose personal data to:
-
Police Scotland, for background checks under firearms legislation;
-
Our insurers, regulators, or professional advisers, where necessary for legal, compliance, or insurance purposes.
4.2 We do not share or sell any personal data to third parties for marketing purposes.
4.3 We will only share your data where required by law or where necessary to protect your vital interests or those of another person.
5. International Transfers of Personal Data
5.1 Our website hosting and email services are provided by Hawkhost, with our servers based in Amsterdam, Netherlands.
The European Commission has issued an adequacy decision for the EEA, which ensures that transfers of data from the UK to these servers are lawful and protected.
See Hawkhost’s GDPR statement:
https://support.hawkhost.com/index.php?/Knowledgebase/Article/View/192/0/general-data-protection-regulation
5.2 You acknowledge that personal data submitted for publication (e.g. event results or competition standings) may be accessible worldwide. We cannot prevent misuse by others.
6. Retaining and Deleting Personal Data
6.1 We retain personal data only for as long as necessary for the purposes described in this policy.
6.2 Membership and account data are generally retained for:
-
The duration of active membership; and
-
Up to three (3) years after membership expiry, for administrative or legal compliance purposes.
6.3 We may retain data longer where required to comply with legal obligations or for the establishment or defence of legal claims.
7. Amendments
7.1 We may update this policy periodically by publishing a new version on our website.
7.2 You should check this page occasionally to stay informed of any changes.
7.3 We may also notify you of significant changes by email.
8. Your Rights
Under the UK GDPR, you have the following rights regarding your personal data:
-
Access to your data;
-
Rectification of inaccuracies;
-
Erasure (“right to be forgotten”);
-
Restriction of processing;
-
Data portability;
-
Objection to processing;
-
Withdrawal of consent; and
-
Complaint to the Information Commissioner’s Office (ICO).
For more information, visit: https://ico.org.uk/your-data-matters/
You can view or amend your member profile by logging into your account at:
https://www.elginrifleclub.co.uk/your-profile/profile?layout=edit
If you wish to exercise your rights, please contact us using the details in Section 11.
9. Cookies
We use cookies to:
-
Authenticate users;
-
Maintain website security;
-
Personalise content; and
-
Analyse website performance.
You can manage or delete cookies through your browser settings. Blocking cookies may impact your experience on our website.
10. Our Details
10.1 This website is owned and operated by Elgin Miniature Rifle Club.
10.2 We are a Home Office–approved sports club, affiliated with Scottish Target Shooting (STS) and the National Small-Bore Rifle Association (NSRA).
10.3 Our principal address is:
9 Perimeter Road, Elgin, Scotland.
10.4 You can contact us:
-
By post (to the address above, marked for the attention of the DPO);
-
Through our website contact form; or
-
By email (as published on our website).
11. Data Protection Officer
We have appointed a Data Protection Officer (DPO).
You can contact the DPO:
-
By post at the address in Section 10.3 (marked “For the attention of the DPO”); or
-
Via the website contact form.