Privacy Policy

Please also refer to the Information Commissioners Office: www.ico.org.uk

Data Protection Officer
The FABC’s Data Protection Officer is:  Jennifer Nellist.

GDPR Training
This document covers all of the FABC’s responsibilities and procedures regarding data protection and is therefore also considered the FABC’s GDPR training document. This is intended to guide the FABC Administration and the FABC Data Protection Officer.

GDPR Registration
Application number:  A8742193

Individual’s Rights
Under the European Union General Data Protection Regulations 2018 individual persons have the following rights:

The Right to:

• Be informed
• Access to personal data
• Rectification
• Erasure
• Data portability
• Object
• Not to be subjected to automated decision making including profiling

Personal Information Audit
What personal data does FABC hold?

• Names
• Email Addresses
• Phone Numbers
• Addresses (Home and Business)
• Records of Academic Achievement e.g. degree transcripts and certificates
• Curriculum Vitae
• Credit/Debit card details

Where does it come from?
Voluntarily and actively submitted via:

• Membership application
• Subscription to newsletters
• Registration for FABC events and webinars: https://fabclinicians.org/webinars/ (e.g. Eventbrite)
• Media release forms – regarding participation in filmed training material
• Non-disclosure forms – regarding viewing of filmed training material
• Online contact form
• Email communication to the FABC office and committee
• Written communication to the FABC office and committee
• Telephone communication to the FABC office and committee

Who is it shared with?
FABC volunteers, employees (no current employees), and contractors carrying out FABC business (for example: office administration, accounts manager, events organiser, webinar technician, web developers).

Members can opt to make their details known to members of the public via the FABC website and via the Animal Behaviour and Training Council (ABTC) who on application by the member, displays the member’s details on their registers which are available to the public.

All members can opt to make their name, email address, telephone number(s) and address to other FABC members via the members’ section of the FABC website. This area of the website is not publicly accessible.

Members details may be shared with other organisations or individuals provided they grant their permission to the FABC office administrator or volunteer to do so.

Subject Access, Withdrawal and Destruction Requests Procedure
All natural persons have the right to request to see their personal details held on record by the FABC. They also have the right to withdraw their personal details by requesting their return and/or permanent destruction.

Requests to view personal details: These may be made by email to office@fabclinicians.org . They must be fulfilled within 28 days of receipt via email or postal correspondence of all copies held of the individual’s personal data. For example: contact file held in Outlook, copies of membership application forms, copies of paperwork arising from complaint procedure.

Requests to withdraw personal details: These may be made by email to office@fabclinicians.org .  Provided reasonable grounds are presented as to the reason for withdrawal, the requests must be fulfilled within 28 days of receipt. Any information that is requested to be returned must be emailed and/or posted back to the individual. Electronic copies must be deleted, the recycle bin emptied and the cloud (Microsoft OneDrive) updated. Paper copies must be shredded. The individual must be notified once this has been done, and within 7 days all correspondence with them must also be destroyed unless for some reason it is unreasonable to do so. In the event of any unreasonable request the Data Protection Office must inform the committee who should provide guidance as to the next course of action.

Lawful Bases for Processing Person Data
The FABC’s lawful basis for collecting data from members is a contractual obligation to deliver its membership services.

All other data is collected, stored and used by FABC to enable its members and members of the public to access information, goods or services, or to bring a complaint against an FABC member.

Children
The FABC does not accept membership applications from persons under 18 years of age.

The FABC public newsletter contains written and pictorial content appropriate for all age groups who have the reading ability to understand the information contained within. Only email addresses are collected, stored and used for the purpose of distributing the FABC public newsletter – no names, addresses or dates of birth are required for this purpose.

Children and young people under the age of 18 may make telephone and/or email enquiries about animal behaviour and the related profession to the FABC office. The office responds to signpost to or provide the information requested and then the correspondence is destroyed. The office does not ask for personal details beyond those volunteered by the individual making the enquiry.

Data Breaches

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/personal-data-breaches/

It is important for the FABC office to be aware of where its records are held and the security thereof. In the event of a security incident (e.g. break in, accidental alteration of records, misplacement of records, cyber-attack) it must be ascertained whether or not there has been any breach of personal data. This is the responsibility of the Data Protection Officer (DPO).

If there has been a breach of personal data, the breach must be recorded in the FABC Data Breach Record document and the impact of that breach on the individuals concerned must be assessed. If the impact to the individuals’ rights and freedoms is severe, then they must be notified by the DPO or person delegated by the DPO within 72 hours of the breach or sooner.

A severe breach must also be notified to the Information Commissioner’s Office (ICO) – by the DPO or other authorised person.

After the event there must be an investigation into how the breach occurred and measures put in place to prevent a recurrence – these must also be recorded in the Data Breach Record.

Data Protection by Design and Data Protection Impact Assessments
All new FABC projects must be designed with privacy and data protection in mind from the start. When scoping new projects all staff, contractors and volunteers must conduct Data Protection Impact Assessments.

https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-by-design/

International
The FABC currently does not have any offices outside of the UK.