Legitimate Interest Assessment

Under UK GDPR, an organisation can use personal data without consent when it has a legitimate interest, but only if it has checked that the use is necessary and fair to the people involved. This page records those checks, as promised in our data privacy policy.

For each use we answer three questions, following the Information Commissioner's Office (ICO) approach:

• Purpose: what are we trying to achieve, and is it a legitimate aim?
• Necessity: do we need the personal data to achieve it, or is there a less intrusive way?
• Balance: do people's interests, rights and reasonable expectations outweigh ours?

1. CCTV for safety and security

Who it affects: members, guests, visitors, staff and volunteers, suppliers and members of the public on or near the club premises.

What we record: video images of the clubhouse, its interior, the boatyard and the approaches to our buildings. We do not use CCTV in toilets, showers or changing areas.

Purpose

To keep people safe, protect the clubhouse, boats and equipment from theft and damage, prevent and detect crime and anti-social behaviour, and support our duties as a licensed bar. Protecting people and property is a legitimate interest, and the club's premises are on an open beachfront that is unattended for much of the week.

Necessity

The site cannot be staffed at all times, and locks and lighting alone do not give a record if something goes wrong. CCTV is limited to the buildings, the boatyard and their approaches, and is not pointed at private homes or used to monitor the beach in general.

Balance

People visiting a licensed clubhouse and boatyard would reasonably expect CCTV to be in use for security. We tell people it is in use and avoid private areas. Recordings are kept only for a short period and then overwritten, unless they are needed to investigate a specific incident. Only directors and people they authorise can view recordings, and footage is only shared with the police or insurers where needed for an incident.

Outcome

We rely on legitimate interest for CCTV. The safeguards above keep the impact on people low.

2. Administrative messages to members

Who it affects: current members, and people whose membership has recently lapsed.

What we use: name, email address, phone number, membership number and type, and for boat storage members the boat name and sail number.

Purpose

To run the membership: confirm applications and payments, send renewal reminders and membership cards, tell members about changes to club rules, opening times or facilities, and send important safety notices. A members' club cannot function without being able to contact its members about their membership.

Necessity

We use only the contact details members give us when they join. These messages are about the membership itself and are kept to what members need to know.

Balance

Members expect to hear from their club about their membership, renewals and safety. Marketing, event promotions and other non-essential messages are not sent under legitimate interest: we only send those with consent, and members can opt out at any time.

Outcome

We rely on legitimate interest for administrative messages about membership, and on consent for everything else.

3. Checking membership applications

Who it affects: people applying to join, or rejoin, the club.

What we use: the details on the application, a visual check of photo ID and proof of address, the club's own incident records, and light-touch checks of publicly available information where relevant to safety or conduct.

Purpose

To make sure applicants are who they say they are, meet the age and eligibility rules, and have not previously been barred, so that the club stays safe for members, staff and visitors. This is part of the club's duty of care and its responsibilities as a licensed premises.

Necessity

Every new member gets access to the clubhouse, bar and in some cases the boatyard, so we need to confirm identity and check our own records. We do not run credit checks or DBS checks, and we do not keep copies of ID documents: the check is done in person at the bar.

Balance

Applicants are told about these checks before they apply, in our membership application review policy (PDF). The checks are limited, proportionate and applied to everyone in the same way. We do not ask about protected characteristics such as health, religion or sexual orientation.

Outcome

We rely on legitimate interest for these checks, carried out as set out in the membership application review policy.

Your right to object

Where we rely on legitimate interest, you have the right to object. We will stop unless we have a compelling reason to continue, for example where footage is needed to investigate an incident. To object, or to ask any question about this assessment, email the Secretary at secretary@wallaseybeach.org.uk.

If you are unhappy with how we handle your data, you can also complain to the Information Commissioner's Office.

Review

The directors of Wallasey Beach CIC will review this assessment every year, and sooner if we change how we use personal data.