Privacy Policy
Introduction
Manchester Makers Ltd, trading as Manchester Hackspace or HacMan, needs to gather and store the personal data of its members, supporters and donors for administration purposes.
This data is collected by the Board of Directors and shall be handled in accordance with the UK General Data Protection Regulation (GDPR). This Privacy Policy describes what personal data is collected, where it is stored, who can use it and how the rights of the individuals are protected.
Manchester Makers Ltd is registered with the Information Commissioner’s Office (ICO).
What Person Data is Collected and Used?
Manchester Makers Ltd collects personal details and contact details in order to administer membership, communicate information and organise events.This information is provided by the individual during sign up.
The organisation creates and maintains records of disciplinary incidents and actions.
As a membership organisation, we are legally required to keep a record of your name and address for ten years.
Manchester Makers Ltd has a digital entry control system allowing access to the building with key fob or access code. A digital log tracks date, time and fob/access code ID.
Manchester Makers Ltd uses closed circuit television (CCTV) video to protect the hackspace’s property and to provide a safe and secure environment for our members and visitors. Further information on this can be found at the end of this document.
Who is Your Data Shared With?
Your membership data may be passed onto communication and organisational services used by Manchester Makers Ltd (e.g. our external mailing list) for the purpose of the administration and running of the space. These services are not authorised to disclose data to 3rd parties.
If you have been subject to disciplinary measures and asked to leave Manchester Hackspace, your name, email address, postal address and reasons for your membership termination, including records of incidents, may be stored by Manchester Makers Ltd for the lifetime of the organisation. This is to protect the organisation and its members.
Payments are handled by a third party – GoCardless Ltd. Please see their privacy policy for further information on what they collect and store. Manchester Makers Ltd can see information about the frequency of payments, the status of payments and the amount paid. The financial details of members are not accessible to Manchester Makers Ltd.
Your personal data is not passed on by us to organisations other than in the ways indicated above.
Who is Responsible for Ensuring Compliance with the Relevant Laws and Regulations?
Manchester Hackspace is not required to have a named data protection officer (confirmed by ICO, July 2024). The directors take responsibility for ensuring compliance.
What is the Legal Basis for Collecting this Data?
Manchester Makers Ltd. collects personal data (e.g. Name, email address) that is necessary for purposes of its legitimate interests as a membership organisation. For some data (e.g. Home Address), the basis for its collection and retention is to comply with our legal obligations.
We ask for emergency contact details during sign up to comply with our commitment to health and safety under the basis of vital interest. This information may be passed on to the emergency services or a third party at the scene in a situation where you are injured and unable to tell them yourself.
Some members may subscribe to additional services for which their consent is collected and recorded in the members database (e.g. Newsletter).
A CCTV system is used for the following legitimate purposes:
- Prevention and detection of theft/crime against the Hackspace and its property
- Protection of members while using hackspace
- In the event of a health and safety incident/gross negligence/gross malfunction of machinery
Rights of Individuals
Under the UK’s data protection laws, including the General Data Protection Regulation (GDPR), individuals have the right on request to receive a copy of the personal data that the Manchester Makers Ltd holds about them, including CCTV recordings if they are recognisable.
You have the right to request all information held about you be deleted, though this may affect your eligibility to continue membership of Manchester Hackspace. Should you discontinue your membership, your data will be stored for up to three years, incase of your return, after which point it will be deleted.
If you wish to access any data relating to you, you must make a written request to the directors: [email protected].
For CCTV requests, please include the date and time of the recording as well as the particular CCTV camera making the recording. The directors will aim to respond within 28 days of any request, however this may increase to 90 days where a request is complex.
There will not usually be a charge for such a request, but we may charge an administrative fee if the request is thought to be manifestly unfounded, excessive, or repetitive.
The directors will always determine whether disclosure of recordings or information will reveal third-party information, as you have no right to access relating to other people. In this case, the directors may refuse the request if it would otherwise involve an unfair intrusion into the privacy of others.
Where is personal data stored and who can access it?
Personal data is stored on a secure membership database. It is visible to and used by the directors and those appointed to help manage digital infrastructure. Information may also be stored on director’s personal computers, servers and paper files. Wherever possible this is encrypted or password protected.
Information shall only be held by a director while they hold office.
Additional Information in relation to CCTV
Location of cameras
Exterior cameras monitor the main entrance/exit to hackspace onto Pollard Street East. Cameras feature infrared lighting to allow recording in darkness.
The locations of interior cameras are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. Cameras are positioned to only cover communal or public areas on the premises and such that they provide clear images. No camera is positioned inside toilets, shower facilities, or changing rooms.
All cameras are clearly visible and no covert recording is permitted in Hackspace.
Appropriate signs are prominently displayed so that members, the public and other visitors are aware they are entering an area covered by CCTV.
Recording and retention of data
The CCTV system incorporates motion detection, when this is triggered recording will begin and will end 10 seconds after motion ceases. Our CCTV and surveillance systems will not record sound. All data is encrypted before being stored on a physical harddrive kept behind lock and key.
Unless in the event a recording is required for the legitimate purposes outlined above, data is stored for 21 days before it is automatically deleted or overwritten.
A monitor has been provided by the main exit of Hackspace to allow members a real-time view of an external analogue CCTV. This monitor does not store any data, and members cannot use this to access any recordings.
Access to and Disclosure of Data
Access to the CCTV digital storage is restricted to the named directors of Manchester Makers Ltd, who each have a separate login to the system. The system is only accessible from within Hackspace, remote access is not possible. An automated logbook will record the date, time and name of each login to view recordings.
In certain cases, the directors may ask the opinion of a more experienced third party, authorising the disclosure of relevant recordings in accordance with the purposes stated above.
In appropriate circumstances, we may allow law enforcement agencies to access CCTV footage where this is required in the detection or prosecution of crime.
No recordings from CCTV will ever be posted online or disclosed to the media.
Contact
If you have questions about the privacy aspects of your dealings with Hackspace Manchester, or would like to make a complaint or request, please contact us at [email protected]
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF.
Version 2.1, 9th September 2024