Although this appears to grant an exemption, clubs still need to get positive
consent from each member that they can hold their information on computer and
must have a process to deal with members who object. The guidelines suggest
holding objectors' details separately on paper.
The other issue, with DiveData and many of the home-grown systems I've seen,
is that they retain information about ex-members. The registration exemption
only applies to current members so, strictly, the minute someone's membership is
overdue you should delete their data ... and type it all back in again if they
rejoin! For that reason alone I would recommend registering with the Data
Protection Register to hold data on prospective, current and ex members.
There is also a requirement to publicise to members that their records will
be held on computer. Dive Data attempts to respond to this requirement with the
Data Protection report. If sent out with membership renewal documents it gives
members an annual reminder that their data is held on computer, that they have
the right to check it and an indication of the key information held (dates,
contact details etc).
