Privacy notice (draft)

Who we are

Somersfield Academy Parent Teacher Association is a Bermuda registered charity, number 1030, at 107 Middle Road, Devonshire DD 06. Email us at somersfieldpta@somersfield.bm. Our privacy officer is Pam Fraser, President of the PTA, at the same address. This notice explains what we collect through our website, why, and what you can ask us to do.

What we collect and why

Orders, tickets and donations: your name, email and, if you give it, your phone number. We use them to take payment, send your receipt and tickets, let you in at the door, and tell you about changes to what you bought.
Guests' names on tickets, for the door list. Please tell your guests you have given us their names.
Children: first name and class, only for lunch orders and items delivered to a class.
Dietary needs and allergies: only if you tick the separate consent box at checkout, or tell the committee member recording your order that you agree, and only for that event or lunch. We record that you agreed, and who recorded it. You never have to answer.
Enquiries, volunteer offers and waiting lists: your name, email, phone and message, so we can reply.
Records of what the committee does: sign-ins to the editing area, changes, and downloads of lists, with who did them. Kept two years, to show who saw what.
Card payments: you type your card into Authorize.Net's own form. We never see or keep your card number. We keep the card type, the last four digits and Authorize.Net's reference for the payment. Please never send us a card number by email or in a message; our forms refuse one.
Technical: your IP address goes to Authorize.Net and Cloudflare, which check for fraud and automated abuse.

Supporters list

If you make a donation and tick "list me as a supporter", your first name and the initial of your surname appear on our website. The box starts unticked. Buying tickets or other items alone does not put you on the list. To come off the list, write to us.

The anniversary programme

Sponsors and buyers of tickets that come with a programme listing (such as the Couples ticket) are named in the printed event programme and in publicity for the event. The checkout has a "keep me anonymous" box; if you tick it, we do not name you. Guest names you give for these tickets are used for the door and the seating only.

Who sees your information

Committee members, each only for their role. Door volunteers see names and ticket references, never email addresses.
Class lists show the child, the lunch choice and any allergy note to [roles].
We do not sell your information or use it for marketing.

Service providers and where your information goes

dotbm, Bermuda, builds and runs the website for us under a written agreement.
Hetzner, Finland: the servers and our backups. [Backup location to be confirmed.]
Authorize.Net, United States: card payments.
Resend, United States: sends our emails.
Cloudflare, United States: bot checks and our web addresses.
Microsoft 365, [country to be confirmed]: messages you send us and our replies.

The website sends parents to Classlist for volunteer sign-ups and messages between parents. Classlist is a separate service under its own terms; this notice covers only this website.

We stay responsible for your information while these providers handle it. [How we judged that their protection is comparable to Bermuda's].

How long we keep it

Payment records (orders, tickets, refunds): until seven years after the end of the financial year in which the order was made (our financial year ends in [month; June until the committee confirms]), as the Charities Act requires, then deleted.
Dietary and allergy information: 30 days after the event or the last lunch date, including on orders that were never paid.
Checkouts that failed or were abandoned: 30 days, or 180 days where money may have moved, so we can put it right. At 180 days we remove your name and contact details from such a checkout automatically and keep only the money record, so that we can still account for the payment.
Enquiries: 180 days after we answer, and no more than 12 months if we never do. Waiting-list requests: 30 days after the event; if the event is removed from our records before then, 180 days from when we last updated the request.
Record of committee actions: the website keeps a log of what committee accounts did (for example who issued a refund or downloaded a list), with the account's name, for two years.
Backups: copies expire within a further 12 months.

Emails we send you

Receipts, tickets, refunds, and messages about something you bought: a change, a cancellation, what to bring. We never send fundraising appeals to people who bought from us. Every email names the charity and its registration number.

Your rights

You can ask to see the information we hold about you, to correct it (a mistyped email address, for example), to stop a use of it, or to have it blocked, erased or destroyed. Write to the privacy officer. We confirm we have your request, with the date, and answer within 45 days. If we need longer, we tell you why and extend once, by up to 30 days. If we refuse, we tell you why in writing. We must keep payment records until seven years after the end of the financial year; if you ask, we remove your name and contact details from them and keep only the money record, which is the order's own number, what was paid, how, and our card provider's reference for it. Once we have done that on an order we cannot put anything back into those boxes, so if you also want something corrected, tell us before we erase rather than after. You can complain to the Privacy Commissioner at privacy.bm.

Security and breaches

Card details stay with Authorize.Net. Committee members see only what their role needs, anyone who can see payments uses a two-step sign-in, and every download of a list is recorded. If a breach of security is likely to harm you, we tell the Privacy Commissioner and then you, without undue delay.

Cookies

The public website sets no cookies. Your shop basket is kept in your own browser until you pay or clear it, and never sent to us until you check out. The website's fonts and pictures come from our own servers, not from third parties. The committee's editing area uses one essential sign-in cookie.

Photos

[Our policy on photos of children].

Changes to this notice

Last changed [date]. We post any change on this page.