DATA PROTECTION POLICY

1. Introduction

The Orders governed by Mark Masons Hall have collectively produced a Data Protection Policy covering all Orders which operate or is in connection with the Bailiwick of Guernsey.  

There are two sections for the document:

Data Protection Agreement (between all representatives of the Orders).

Data Protection Policy (to be followed by members)

2. Definitions

MMH+ means collectively the Grand Lodges, or their equivalent, managed from the Mark Masons’ Hall, whose offices are at 86 St. James Street, London, SW1A 1PL as the ultimate Governing body of the Orders and including the Royal Order of Scotland, 23 St John Street, Edinburgh so defined.

ORDERS, refers to all Orders operating under MMH+, known as the Progressive Orders of Freemasonry, having members and operating in the Bailiwick of Guernsey as delineated in Appendix A.

UNIT(S) means any masonic organisation, known as Lodge, Chapter, Conclave, Consistory and Preceptory or equivalent acting under the jurisdiction of any Grand Lodge governed by MMH+ and any subordinate Province or District, or equivalent, including The Bailiwicks of Guernsey and Hampshire and IOW, Jersey, Grand Lodge together with any associated event or associated group as delineated in Appendix A.

HEADS means any representative duly and lawfully appointed and holding delegated authority from MMH+, to act in the name of, and on behalf of, the Order by whom so appointed.

DATA means any data collected, held, or processed which may identify a living individual.

REGULATIONS mean the Constitutions and Regulations, or the equivalent, for the government of any of the UNITS in force from time to time.

  1. ODPA means the Office of Data Protection Authority who regulates the Data Protection Law in the Bailiwick of Guernsey.
  2. DPO means the Data Protection Officer, who oversees this Policy.
  3. SECRETARY means the Secretary, Scribe, Recorder or individual within each UNIT who is the central communication contact for that Unit.
  4. OFFICERS means Secretarial and Treasurer handling of membership, directing of ceremonies and events, almoner care, dining management, charity collection and processing and historian recording and research officers and any individual who may have a requirement to process DATA under this Policy.

It should be noted that all words expressed as plural shall have the same, or similar, purport or meaning when in the singular.

Data Protection Agreement

1. Purpose

This Data Protection Agreement is an agreement made between the various ORDERS under the jurisdiction of MMH+ allowing them to operate under a single umbrella for Data Protection purposes. 

This Data Protection Policy defines and regulates how each ORDER processes and stores the DATA of its members by the PROCESSORS. It applies to all OFFICERS, members, and ASSOCIATES of the ORDERS. It is to be understood by all parties in addition to the members they represent that DATA may be held in different forms and areas and under the control of more than one person. Each PROCESSOR is under a legal obligation to carry out the tasks required of him in a timely and efficient manner and will take all steps to ensure the DATA so processed shall at all times be accurate and kept up to date.

Their purpose is to ensure that ORDERS comply with the regulatory framework and encourage high standards of data protection.

2. Data Protection Officer

The HEADSshall appoint a Data Protection Officer (DPO) who will oversee compliance with the Data Protection Law and will act for its members as a central point of contact with the ODPA and will advise the HEADS of any issues or recommendations.

He shall have, or shall undergo, training to ensure that he has knowledge of Data Protection Law and practices.  He will provide training, information and assistance to the OFFICERS which should be performed on a regular basis and at least once a year.

In the event of a request for information the DPO will request from the SECRETARY information from each UNIT and will co-ordinate the reply.

In the event of a breach the DPO will take whatever action is necessary and will report the breach to the ODPA.

The HEADS will appoint a Deputy DPO to support the DPO and to assume the function in the event of the DPO becoming unable to carry out his duties, being ill, on holiday or following resignation until a successor has been duly appointed.

3. Unit Secretary

The SECRETARY will notify the DPO of any change in OFFICERS within their Unit from time to time.  He will ensure that any new OFFICER will receive a copy of the Data Protection Policy and the procedures to follow.

The SECRETARY is expected to check and verify the DATA held by the OFFICERS of his UNIT on a regular basis.

4. Unit Officers

The OFFICERS will be responsible for ensuring that the Data Protection Policy is strictly adhered to at all times. In the event of any issues, potential or actual breach, the DPO must be informed immediately.

5. The Member

A member, or past member or affiliated person, is entitled to receive a copy of the Data Protection Policy statement and may request the DPO to do the following. 

The DPO will:

Provide him with a copy of all DATA that the ORDERShold about him.  This shall be provided within a reasonable amount of time and will include copies of all information required to be disclosed by law.

Rectify immediately any incorrect DATA held by the OFFICERS, in whole or part, as appropriate. 

Every member is required to ensure compliance of any material he may be given as part of his membership.  i.e., Yearbook, Summons

6. An Associate

An associate to the ORDERS must comply with the Data Protection Policy as defined.  This includes, but is not limited to, the Caterers, Temple Caretaker, Island Archives Centre, Yearbook printers, Ladies event guests, White table guests.

7. Deletion of PERSONAL DATA

A member may resign from any or all UNITS at any time.  After it has processed such resignation(s) the ADMINISTRATORS shall archive that DATA, for historical reference purposes and will stop such DATA that it holds about that member from being used as set out in the Data Protection Policy.

8. Sharing of data with third parties.

From time to time the AUTHORITIES may process, store, and share the DATA with third parties to fulfil their duties.  This includes but not limited to accounting systems, cloud-based storage, printing, event organisers.  The processing of information must be under the control of the AUTHORITY and within the restrictions of the Data Protection Law.

9. Data Security Compliance Check

The DPOshall periodically review the security of any of the UNITS records and processing activities and shall take appropriate steps to ensure the confidentiality, integrity, and proper availability of the DATA that it holds. He will be required to make a regular Report to the HEADS when any review has been completed.

The HEADS may call upon a questionnaire or compliance check at any time as recommended by the ODPA.

Appendix A – Agreement by ORDER

For the purposes of this legislation and its Regulations, the ORDERS shall comprise the following Orders of any unit of which is established and practices within the Bailiwick of Guernsey as of April 2021.  (See Appendix B).

The agreement is signed by the following HEADS in acceptance of this agreement.  Signed confirmations letters are attached.  Where a new HEAD maybe appointed from time to time then the letter of confirmation by the new HEAD may be included.

  1. Provincial Grand Lodge of Mark Master Masons of the Channel Islands.
    W. Bro. Derek Upton – Provincial Grand Master

  2. the Inspectorate of the Channel Islands for Royal and Select Masters
    V. Illus. Comp. Ken Rondell – Grand Inspector

  3. The Inspectorate of the Channel Islands for the Allied Masonic Degrees
    V. W. Bro. Ken Rondell – Grand Inspector

  4. Provincial Grand Conclave of the Channel Islands in the Order of the Secret Monitor or the Brotherhood of David and Jonathan
    R. Wy. Bro. Stephen Regal – Provincial Grand Supreme Ruler

  5. Provincial Grand Senatus of Hampshire, Isle of Wight and Channel Islands in the Ancient and Masonic Order of the Scarlet Cord
    R. Dist. Comp. Ian Campbell – Provincial Grand Summus

  6. The Provincial Grand Lodge of the Channel Islands in the Royal Order of Scotland.
    R. W. Bro. Jim Sinclair – Provincial Grand Master

10.    Appendix B – UNITS of the ORDERS

The UNITS of the ORDERS are defined as at April 2021.  In the event of new UNITS or ORDERS  being included then the details may be attached to this Appendix :

  1. The Grand Lodge of Master Masons and Honourable Fraternity of Royal Ark Mariners
    Province of Mark Master Masons and Honourable Fraternity of Royal Ark Mariners of the Channel Islands.
    Sarnian Lodge of Mark Master Masons No.425
    Sarnian Lodge of Royal Ark Mariners No.425
    Guernsey Lodge of Mark Master Masons No.1614
    Channel Islands Installed Mark Master Masons Lodge No.1788
    Channel Islands Installed Commanders Lodge of Royal Ark Mariners No.1788

  2. Order of Royal and Select Masters
    Inspectorate of the Channel Islands
    St. Appoline Council No.202

  3. Order of Allied Masonic Degrees
    Inspectorate of the Channel Islands
    La Vallée Council No.163

  4. Order of the Secret Monitor or Brotherhood of David and Jonathan
    Provincial Grand Conclave of the Channel Islands
    Le Marchant Conclave No.421

  5. Ancient and Masonic Order of the Scarlet Cord
    Province of Hampshire, Isle of Wight and the Channel Islands
    Guernsey Lilly Consistory No.125

  6. Royal Order of Scotland
    Provincial Grand Lodge of the Channel Islands

 

Data Protection Policy

Pursuant to Data Protection (Bailiwick of Guernsey) Law, 2017, as amended.

Data Protection Policy

To be provided to each member, current or on application

1. Application for joining or re-joining.

As a candidate, you consent to the processing, retention and sharing of your personal data (DATA) submitted on or with your application, for the purpose of assessing your membership application and any other membership applications you may make to other ORDERS and UNITS. 

The assessment of your application will include printing some of your DATA on the summons which is sent to all the members of the UNITS to which you are applying.  Those details may include your full name, age, profession, or occupation (if any), place or places of abode, business address, residential address, phone numbers, email addresses, photo and names of your proposer and seconder.  Your details will be checked against records of current members and of members who have resigned or been expelled for the purpose of verifying that you are eligible to make your application.  

 You can withdraw your consent and request erasure of your application data at any time prior to you joining or re-joining by notifying your proposer and seconder that you wish to cancel your application.

Your application and membership details will also be recorded in the Regional and Governing authorities.

2. Use of your data when you are a Freemason.

As a Freemason your DATA will be processed, retained, and shared for any reasonable purposes required by the ORDERS regulations and the UNITS by-laws which may vary from time to time.  These purposes include, but are not limited to, the following purposes:

  1. Assessing any membership applications, you make to the UNIT;
  2. Registering you as a member of the UNIT;
  3. Sending communications which you are entitled to receive.
  4. Recording the progress of your career in the various ORDERS;
  5. Annual publication of a membership Yearbook;
  6. Dining requirements.
  7. Charity donation recording.
  8. Checking on a Brother’s wellbeing.
  9. Masonic disciplinary processes*;
  10. If you resign or are expelled from membership, maintaining records to prevent you from improperly re-applying for membership*; and
  11. Maintaining records of your career in Freemasonry for archive and historical purposes*.

You may stop your DATA from being used for all purposes except those marked with an *. above by resigning from the ORDERS.  Other Masonic entities may also keep historic records, for example once you cease to be a member of a UNIT your personal details will remain in UNIT minute books which cover the period in which you were a subscribing member. 

Your DATA may also be used within one year of your resignation from a UNIT to contact you for the purposes of understanding why you resigned and if applicable to assist you in finding an appropriate UNIT to join.  

You may request access to the DATA held about you by each UNIT, and rectification of that DATA if applicable, or object to the processing of that DATA, by submitting a request to the Data Protection Officer (DPO) who can be contacted on dpo@MMHorders.org.gg.  If you need to speak to the DPO then the SECRETARY of your Lodge, or equivalent and will provide you with their contact details. 

Where you provide your DATA to a UNIT, it may be shared with other UNITS of which you are a member so that your DATA is kept up to date.  For example, if you move to a new house and provide your new address to your UNIT, that DATA will be shared with the Almoner, Province and the Mark Masons’ Hall so that they can update their records. 

         The legal bases on which your DATA will be used in accordance with this Section 2 are:

  1. the legitimate interests of UNITS as not for profit membership organisations; and
  2. the fulfilment of contractual obligations owed to you by your UNIT supported by its affiliated UNITS.
  3. for processing the management of Masonic charity collection and processing.
  4. the checking of your wellbeing.

3. Masonic charities

Masonic charities need to keep their donor databases accurate and up to date and in compliance with the latest legislation concerning Charity funding.  If you choose to provide your name and residential address to a Masonic charity, then UNIT may permit those Masonic charities to verify their donor databases against your name and address data that UNIT hold.  The legal basis for this processing is the legitimate interests of that charity. 

Masonic charities provide, among other work, support to Masons, former Masons and their relatives.  UNITS would like to be able to share your personal data with recognised Masonic charities so that the charities can process it:

  1. on receipt of an application for relief, to determine whether you or your relatives are eligible beneficiaries; and
  2. where you have separately consented to a Masonic charity contacting you with fundraising materials, to allow that charity to update your contact details in their fundraising database by viewing your contact details held by Masonic entities.

Your data will not be processed by Masonic charities for purposes 1. or 2. of this Section III unless you have provided your consent.  You may change these two optional consents at any time by contacting the Masonic Charity concerned.

4. Criminal convictions

Criminal conviction data will only be used by your Unit, the Province or District Grand Lodge and the Mark Masons Hall to:

  1. determine your suitability to become a Freemason in the ORDERS.
  2. determine your suitability to remain a Freemason in the ORDERS; or
  3. maintain records to prevent you from improperly re-applying for membership if you have ceased to be a member of any UNIT by resignation or expulsion.

Freemasons are expected to conform to high standards.  In relation to purpose 1. above, as a candidate you must give proof of your membership as a Freemason under the governance of the United Grand Lodge of England.   The legal basis on which this DATA is processed is your consent by completing the application form.  You can withdraw your consent and request at any time by notifying your proposer and seconder that you wish to cancel your application.

If convicted of an offence, you must report certain criminal convictions to your Craft Lodge. These reports are referred to the UNITS for purpose 2 to consider. The legal basis on which this data is processed is the legitimate interests of the UNIT as membership organisations in upholding their values.  The processing falls within the “processing by not-for-profit bodies” exemption to permit processing of criminal convictions data.   

5. Archiving and historical research

Many Masonic records which may contain your DATA are archived for Masonic interest and kept for historical research.  When they are no longer needed by the relevant UNIT they may be archived in the Masonic Museum or in a secure Archive Centre.   

6. Communications

If in the event of any DATA being displayed on any form of communication which you have a concern then please notify the DPO immediately.

Correspondence – If you communicate with a UNIT they may monitor, record, store and use any telephone, email, webform or other communication with you to communicate with you in relation to your query, respond to the issues raised or deal with them in accordance with UNITS regulations, check any information you have provided, maintain records of recent communications for legal reasons and improve the quality of the services they offer.  The legal basis for this processing is the legitimate interests of each as a membership organisation.

Notice Board – Your DATA may appear on a notice board within the Temple only as part of the membership of a UNIT.  This may include photos of events, minutes, charity donations.

Website – Your DATA may appear on a Masonic Website for the UNIT only with your consent in writing or by email.  Photos taken where you are not recognisable will not be deemed as DATA.

Social Media – Your DATA may appear on Social Media only with your consent.  Consent may be given verbally or without objecting when asked. 

7. Other uses

Events – If you register for any event then you agree for your DATA to be held by the event organisers and 3rd parties assisting with the event (i.e., caterers) for the administration and recoding of the event.  This includes but not limited to Ladies Nights, White Tables, Charity raising events.

Groups – If you join any group which is associated with the ORDERS then you agree for your DATA to be held for the running of the group.  This may include but not limited to Sports activities, Research Group, Benevolent Funds and Volunteering.

Surveys – If you complete any of the surveys from any UNITS then you consent for the DATA to be used as detailed within the survey.

Contractors – From time to time it may be necessary for your data to be shared with 3rd party contractors.  This may include but not be limited to, repairs of any past master boards, jewellery etc.

8. Other Masonic Orders

As a Freemason your details may be shared with other UNITS and Masonic orders for purposes of checking your good standing, consideration for promotion, recognition of ran or achieving a membership milestone.

 

Signed

Data Protection Officer

April 2021