Privacy Notice

Last updated 29 November 2019

This privacy notice tells you how we, Digital Membership System (D-Member), will collect and use your personal data to provide our service which allows you as a user, educators (instructors), of any kind and centres, to create a private space online, filled with tools that easily collect and process information.

Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Why does Digital Membership System (D-Member) need to collect and store personal data?
In order for us to provide you with the correct information concerning your certifications and other data we need to collect personal data for correspondence purposes and/or to allow us to provide you our service. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose. Digital Membership System (D-Member) is a company which values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make the Digital Membership System (D-Member) services work for you.

Will Digital Membership System (D-Member) share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Digital Membership System (D-Member) Program in the course of dealing with you. We do this because there are some services, such as certification specific information, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on your-behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Digital Membership System (D-Member) procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Digital Membership System (D-Member) use the personal data it collects about me?
Digital Membership System (D-Member) will process (collect, store and use) the information you provide in a manner compatible with the EU's General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Digital Membership System (D-Member) maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. Digital Membership System (D-Member) is required to retain certain information in accordance with the Law, such as information needed to determine a specific certification. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices.

Can I find out the personal data that the organisation holds about me?
Digital Membership System (D-Member) at your request, can confirm what information we hold about you and how it is processed. If Digital Membership System (D-Member) does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of our data protection officer in the EU, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Digital Membership System (D-Member) or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?
Digital Membership System (D-Member) accepts a request made through a Digital Membership System (D-Member) account while the person making the request is logged in. In certain circumstances Digital Membership System (D-Member) could ask for additional information and the following forms of ID when information on your personal data is requested:

• A colour copy of a Passport, driving licence or National ID Card.

DATA POLICY

1. Scope
   All data subjects whose personal data is collected, in line with the requirements of the General Data Protection Regulation – GDPR.


2. Responsibilities
   All data subjects whose personal data is collected, in line with the requirements of the General Data Protection Regulation – GDPR.
   1. Where Digital Membership System (D-Member) is hosting a website on its own behalf, it is the Data Controller for all the data collected. Where Digital Membership System (D-Member) is hosting someone else’s installation of the Digital Membership System (D-Member) Platform it is the Data Processor for the Site Admin for that installation.
   2. When Digital Membership System (D-Member) is not hosting an installation of the Software Platform, it is neither the Data Controller or the Data Processor and those duties fall on the people or organisations who have installed Digital Membership System (D-Member) and are hosting those installations.


3. Privacy notice
   
   1. Who are we?
      Digital Membership System (D-Member) is a software company which allows companies, to maintain a digital registration system, filled with tools that easily create personal registration, certifications and activities.
      We collect personal data relating to you for specific purposes. The nature of the data collected is depending on your interaction with Digital Membership System (D-Member).
      
      Our legal basis for processing for personal data:
      • Article 6.1(a), GDPR, Consent
      • Article 6.1(b), GDPR, Contract
      • Article 6.1(f), GDPR, Legitimate Interest
      Any legitimate interests pursued by us, or third parties we use, are as follows:
      • Recruitment and Induction of new Candidates
      • Emergency Contacts for people who work with us, such as employees and Contractors for Health and Safety purposes.
      • Business Development
      • Providing login systems to users via their existing social media accounts
      The special categories of personal data concerned are:
      • Biometric Data in the form of facial images
      • Health Data in respect of employees, Contractors and other people who work with us
      • Any special categories of special personal data which any user volunteers while using the Digital Membership System (D-Member) systems or any Digital Membership System (D-Member) website- for example in a forum.
   
   
   2. Consent
      By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for Digital Membership System (D-Member) to process both standard and sensitive types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used. Agreement with this Privacy Notice and its accompanying Terms and Conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.
      You may withdraw consent at any time by identify your role in relation to Digital Membership System (D-Member) (if you are a User, Instructor, Centre, Staff member, Digital Membership System (D-Member) Partner, Site Admin etc.), and the data you wish to withdraw consent to be processed.
   
   
   3. Disclosure
      Digital Membership System (D-Member) will pass on your personal data to certain third parties. Digital Membership System (D-Member) is a global company and it uses cloud services which may be accessed by Digital Membership System (D-Member) employees in any part of the world, including our Head Office in the Netherlands.
   
   
   4. Retention period
      Digital Membership System (D-Member) will processes different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact privacy@d-member-system.com.
   
   
   5. Your rights as a data subject
      At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
      • Right of access – you have the right to request a copy of the information that we hold about you.
      • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
      • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
      • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
      • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
      • Right to object – you have the right to object to certain types of processing such as direct marketing.
      • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
      • Right to judicial review: in the event that Digital Membership System (D-Member) refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
      
      Where Digital Membership System (D-Member) is your Data Controller, you may make a request directly to the Data Protection Officer using the email address dpo@d-member-system.com.
      
      Where Digital Membership System (D-Member) is a Data Processor, and act on behalf of responsible third party (such as an instructor or centre) any requests received by Digital Membership System (D-Member) will be passed on to the Data Controller of that third party.
   
   
   6. Complaints
      In the event that you wish to make a complaint about how your personal data is being processed by Digital Membership System (D-Member), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority or with the Digital Membership System (D-Member) data protection Officer.
      
      If you wish to make a complaint about how your personal data has entered into Digital Membership System (D-Member) by a third party (as described in clause 3.5), you should contact the data processor of that third party. (For example, an instructor or centre).
      
      Contact details for where Digital Membership System (D-Member) is the Data Controller:
      
      ‘Digital Membership System’ (D-Member) Data Protection Officer
      PO Box 171
      NL – 7940 AD Meppel
      The Netherlands
      E-mail: dpo@d-member-system.com
      
      European Data Protection Supervisor
      Rue Wiertz 60
      B – 1047 Brussel
      Belgium
      E-mail: edps@edps.europa.eu