Membership processes - best practice for societies

Regulation C 3.a. (14) (Also C 3 a. (19) – Ringcraft Societies)

The Kennel Club requires that societies include in their constitution a  rule that the society must maintain an up to date list of members and their addresses, and those of branch members where appropriate, and, if so requested, make the list of names available for inspection  to the Kennel Club and members of the society.

Under the Data Protection Act UK 2018 and GDPR, there is a requirement that all personal data shall be processed fairly and lawfully.  In order to comply with this, societies should consider the lawful basis and intended purposes for which the data they hold will be processed, whether the members will be informed, understand and where necessary consent to how the data will be used and the particular intended disclosures of data, eg publication in yearbooks, on the society’s website.

The society should consider whether members are likely to understand the purposes and whether the particular disclosures can be reasonably envisaged. The more unforeseen the purpose or disclosure, the more necessary information should be given to members.

A society must comply with Regulation C 3.a. (14) which is a mandatory contractual provision.

The data protection legislation does not negate this Regulation. Members of a society are entitled to be informed of who their fellow members are. The Regulation has been revised to reflect that members should only be permitted to view the members’ names. There is no requirement for a society to provide a copy of the list, only that access to view the list of names is permitted to the members.

The Kennel Club is also entitled to be informed of who is currently a member of a society for regulatory and administrative purposes.

The lawful basis upon which a society can provide a list of members’ names for inspection is contractual necessity – for compliance with the Kennel Club Rules and Regulations.

A society must ensure that members understand and are aware that membership lists will be made available pursuant to Kennel Club Regulations. The club should therefore include a line in its Privacy Policy to reflect this and inform its members. A template Privacy Policy and further guidance on data protection can be found in The Kennel Club’s GDPR Guidance for Clubs and Societies.

A club processes personal data about its club members for a range of purposes. These should be outlined in a Privacy Notice.   

Data will be processed in the main on the basis of this being necessary for the performance of a contract between the Club and the individual, necessary for the club’s “legitimate interests” or, on occasion (but rarely, overall) relying on the individual’s consent.

Members provide contact details upon joining and renewal of their membership. Members’ names may be listed in a Yearbook as the membership has a right to know who their fellow members are.  

A member should be able to indicate the extent of publication of contact details (address, email and telephone number – all, some or indeed no detail at all) and members must be free at any point to vary what is published from all, some or no contact details.

An individual member may want to contact another member but it is not expected by members that another member would contact everyone globally, at least, not without referring to the club as to whether it was appropriate to do so. 

It is helpful to have a set of ground rules for use of the published Membership list so that expectation and legitimate use and purpose is clear.

These rules could, as a minimum, place limits on mailing frequency.

The rules can also specify that:

• The membership list is primarily intended for day to day contact of members by the club
• Other members may do so on a ‘one to one’ basis
• If other members want to contact the whole membership list or groups, then publication rules apply;
  • Make it clear/identify the sender
  • Make clear it is not an official or endorsed club communication (no connection/association with the club)
  • Nothing offensive
  • No harassment
  • No defamation of individual or the KC
  • No more than xx a year
  • No selling – dog related or otherwise
  • Not by email Preferred that it is only by post – therefore avoiding possible challenge as an unsolicited contact by email for ‘marketing’ (dissemination of views).

The best and most practical way to secure knowledge and consent (for publication of contact details) of members is to include a provision in the application for or renewal of membership.  The key is to make sure that any new members are aware of this condition before joining.

It may be that if the society has increased the way in which it discloses its list, for example publication on the society’s website, then it may be sensible to alert existing members to this fact – again to be able to demonstrate that members are aware and do consent so such disclosure.

Membership details will be incorporated into the annual membership list which will be published on [website, yearbook etc as appropriate].  In addition, Kennel Club Regulations require that membership lists will be made available for inspection by other members and the Kennel Club.

It is a condition of membership that your name will be included in the membership list to be published and disclosed as deemed appropriate by the society and in accordance with Kennel Club Regulations.

Please indicate below which contact details you wish to be published [in the Yearbook, on the website etc.]

• Address
• Email
• Telephone Number