1. Introduction
 
This Privacy Policy describes how Fitzmaurice House Ltd. trading as, and hereinafter referred to as the Lansdowne Club processes your personal information. It deals with how we collect information, what we do with it, how we protect it and what controls and rights you have over your Personal Data. 
 
We are committed to protecting the privacy of anyone interacting with us and will treat all information you give us carefully.
 
Where possible, our policies are written under the guidelines of the Plain English Campaign for ease of reading and interpretation. 
 
This Privacy Policy explains how we collect, use and protect personal data, and your rights in relation to that data.
 
Please read this Privacy Policy carefully to understand how we process your Personal Data. By providing your Personal Data to us or using our services or this website, you accept and consent to the practices in this Privacy Policy.
 
We may update this policy from time to time. The date this policy was last updated is shown at the end of this document.
 
As the Data Controller, we fully comply with the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (as amended) and the UK General Data Protection Regulation (UK GDPR). 
 
We are registered on the ICO Data Protection Register under registration number ZA394080 and at Companies House (England & Wales), Company number 00358247 as Fitzmaurice House Limited, trading as The Lansdowne Club. Our registered address is: 9 Fitzmaurice Place, London, W1J 5JD


2. Who we are
 
In this policy, all references to "The Lansdowne Club", “The Club”, "we," "us", and "our" are to the Lansdowne Club.
 
The Data Controller is The Lansdowne Club. 
 
The Person Responsible for Data Protection is The CEO and Club Secretary, David Herbert.  
 
We have not currently appointed a Data Protection Officer.  
 
 
3. What information do we collect?

We collect personal information about you to provide our services, manage our relationship with you, and operate the Club effectively. The information we collect may include:
 
• Name, address and contact details (including email address and telephone number)
• Membership information, including services used and preferences
• Payment information provided when you make payments to us
• Identity verification and screening information, including the results of sanctions, politically exposed person (PEP) and adverse media checks where applicable
• Information relating to your use of the Club, bookings and interactions with us
• CCTV images and, where applicable, audio recordings for security purposes
• Biometric data where used for access or time recording systems
 
For employees and applicants, we also process:

• Employment and recruitment information, including work history and interview records
• Identification information such as date of birth, nationality, National Insurance number and passport details
• Payroll and banking information
• Contact details, including personal email address and telephone number
 
Where screening checks are carried out, we retain only the outcome and any associated decision record. Full screening reports are not retained.
 

4. How do we collect personal information?
 
We collect personal information in the following ways:

• When you make contact to enquire about membership or employment 
• When you provide information by filling in a form on registration or information provided at any other time
• Through the provision of our services to you
• When you participate in discussion forums or other social media on our site or sites managed by us
• When you contact us by email, telephone, social media or any other way
• When you visit our website
• When you sign in and out of The Club.  

 

 5. How we use the information and why we need it  

We use your personal information to provide our services, manage our operations and maintain the security and integrity of the Club.
 
We process your personal data for the following purposes and legal bases:
 
To provide membership services and manage our relationship with you
Including administering membership, bookings, events and communications.
Lawful basis: Performance of a contract.
 
To manage our business operations and improve our services
Including maintaining records, responding to enquiries and carrying out internal analysis.
Lawful basis: Legitimate interests.
 
To protect the Club, its members and its operations
Including identity verification and screening checks, such as sanctions, politically exposed person (PEP) and adverse media screening, where necessary and proportionate.
Lawful basis: Legitimate interests.
 
Where such processing involves information relating to criminal convictions or offences, it is carried out in accordance with data protection legislation and subject to appropriate safeguards.
 
To comply with legal and regulatory obligations
Including employment, financial and law enforcement obligations.
Lawful basis: Legal obligation.
 
To communicate with you about services, events and offers
Including marketing communications where permitted. You can opt out at any time.
Lawful basis: Consent or legitimate interests, depending on the circumstances.
 
We do not make decisions about individuals solely by automated means. Any screening results are subject to human review before a decision is made.
 
 
6. Legitimate interests
 
We rely on legitimate interests where this is necessary for the operation and protection of the Club, including identity verification and risk screening, and we ensure these interests are balanced against your rights.
 

7. Who will see the information?
 
Your information will only be accessible to our staff and only where appropriate to their specific role. We will never sell your information or let other organisations use it for their purposes. We will only share your personal information:

• Where consent is necessary, we will have obtained your consent to us doing so and will provide information for the specific reason your consent was given. 
• Where it is necessary to protect your vital interest (i.e. your life or health)
• Organisations or people whom we must share your personal information with by law or regulations
• The police or other law enforcement agencies for them to perform their duties if we are obliged to by law or under a court order
• Where (for employees) we use other organisations to provide services on our behalf for processing, such as Payroll, pension accountancy and other outsourced HR administration
• When using auditors and professional advisors and with your pension administrator
• With our Shareholders
• If we merge with another organisation, form a new entity, sell our business, or purchase a business.
• We may share personal data with third-party service providers who carry out identity verification and screening checks on our behalf.

8. Security

• The security of your personal information is important to us. We protect all Personal Data we hold and ensure we have appropriate organisational and technical measures in place to prevent unauthorised access or unlawful processing of Personal Data and to prevent Data from being lost, destroyed, or damaged.
• All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. 
• The transmission of information via the internet is not completely secure. Whilst we will do our best to protect your Personal Data, we cannot guarantee the security of your Data before it reaches our site.
• Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
• Personal Data is processed in the UK; your information may be stored outside of the United Kingdom (UK) for IT hosting and maintenance.​

9. Your rights

You have the following rights:

• A right to transparency concerning how we use your personal information (right to be informed)
• To request a copy of the information we hold about you, which will be provided to you within one month (right of access)
• To require an update or amendment of the information we hold about you (right of rectification)
• To ask us to stop using your information (right to restrict processing)
• To ask us to remove your personal information from our records (right to request erasure of your personal data where applicable)
• To request us to remove your information for marketing purposes (right to object)
• To obtain and reuse your Data for your purposes (right to portability)
• Not to be subject to decision-based automated processing.

 
You can contact us concerning any of your rights at the following address:  The Club Secretary, David Herbert (the Person Responsible for Data Protection), 9 Fitzmaurice Place, London, W1J 5JD.  
 
To protect your privacy, we may ask you to prove your identity before we formally respond to any request. There is no charge for a request, and we will respond to the request within one month.
 
If you are dissatisfied with how we deal with your request, contact the Information Commissioners Office at 0303 123 1113 or their website, www.ico.org.uk.
 
 
10. Cookies
 
Our website uses Cookies to distinguish you from other users of our website. This helps us provide a valuable experience when you browse our website and allows us to improve our site. 
 
More information concerning our use of cookies can be found on our Cookie Policy by following this link [Hyperlink to Cookie Policy]
 

11. Retention of information

We keep your information only for as long as necessary for each purpose we use it. We use the following guidelines:

• Any time limits set by law or recommended by regulators, professional bodies, or associations
• For as long as we have a reasonable need to manage our relationship with you.

12. CCTV 
 
CCTV monitors our premises for the safety of visitors and staff and the security of the property. Images are retained for a limited period in line with operational requirements.
 
More information concerning our use of CCTV can be found on our stand-alone CCTV Policy. Please contact us for access.


13. How to contact us
 
If you have any questions about how we collect, store, and use personal information, or if you have any other privacy-related questions, please contact us by any of the following means:
 

1. Telephone: 0207 629 7200
2. Mail: The Lansdowne Club, 9 Fitzmaurice Place, London, W1J 5JD
3. Email: [email protected]