Privacy Policy

1. Introduction


1.1. The Kennel Club Limited (we or us) is committed to protecting your personal information and respecting your privacy.
1.2. This Privacy Notice, together with any other documents referred to in it, sets out the basis on which any personal data that we collect from or about you, or that you provide to us, will be processed by us.
1.3. For the purpose of the Data Protection Act 2018 and UK General Data Protection Regulation [UK GDPR], the data controller is The Kennel Club Limited (company number 8217778), whose registered office is 10 Clarges Street, Piccadilly, London W1J 8AB.
1.4. We may update this Privacy Notice from time to time. Any changes we make in the future will be posted on our website at www.thekennelclub.org.uk/privacy-policy. Please check back regularly to see any updates or changes to this Policy.

 

2. Data Protection Team
2.1. The contact details for our Data Protection Team are as follows:
2.1.1. dataprotectionteam@thekennelclub.org.uk
2.1.2. 01296 318 540
2.1.3. The Kennel Club, 10 Clarges Street, London, W1J 8AB
2.2. It is the responsibility of the Data Protection Team to keep our organisation and our staff informed and advised about their obligations to comply with data protection laws, to monitor compliance with those laws, to train staff and conduct internal audits, and to be the first point of contact for supervisory authorities and for individuals whose personal data we are processing.
3. Particulars of processing
3.1. We process personal data about Petlog registrants, Authorised Agents and implanters in a range of ways, and for a range of purposes.
3.2. The categories of person about whom we process personal data are described in more detail in the Particulars of Processing that are set out in the Schedules to this Privacy Notice.
3.3. It may be the case that you have contact with us in more than one capacity, so please read this notice and then look at all the relevant schedules that may apply to you if you wish to know more about how we process your personal data, including the purposes and legal basis. The specific Schedules are as follows:
3.3.1. First Keepers [Schedule 1];
3.3.2. New Keepers (Transfers) [Schedule 2];
3.3.3. Authorised Agents & Welfare Organisations [Schedule 3];
3.3.4. Implanters [Schedule 4];
3.4. Note – we will use personal data sometimes for statistical purposes but retain anonymity so you cannot be identified.
3.5. The Kennel Club will generally process your personal data for contractual necessity in providing our products and services or its legitimate interests. The Kennel Club will use personal information for additional relevant purposes where you might reasonably expect us to do so, where the benefits of doing so are not outweighed by your own interests or fundamental rights or freedoms. The law calls this the “Legitimate Interests” condition for processing. Where we rely on it, the benefits being pursued are:
3.5.1. To monitor, analyse and improve our services and websites, including enhancing and personalising your customer service.
3.5.2. Managing your account including order completion.
3.5.3. Complying with/supporting compliance with legal and regulatory requirements. 
3.5.4. Internal training purposes.
3.5.5. To maintain our records and other administrative purposes, including updating your details and preferences. 
3.5.6. To assist with queries and complaints.
3.5.7. To improve data accuracy and completeness - when you register for our services you may supply us with additional information about yourself which we will use to improve our data accuracy and completeness.
3.5.8. To ensure network and account security.
3.5.9. Email tracking – in order to improve our communications with you. 
3.5.10. Invitations to participate in market research in order to improve animal welfare and/or to improve our services; we may ask you to participate in research for time to time. This may be with partnered respected research organisations and universities.
3.5.11. Invitations to provide Kennel Club product and services feedback – in order to improve our services, we may contact you for your feedback from time to time.
3.5.12.
3.5.13. Providing you with information on relevant legislation (including amendments to such legislation).
3.5.14. To investigate, analyse and resolve any issues with services, databases and associated platforms.
3.6. The Kennel Club may process your personal data where there is a legal necessity to help the relevant authorities to prevent and detect crime such as animal welfare offences, trading standards offences and fraud and money laundering.
3.7. We may monitor and record communications with you (such as telephone calls) where there is a contractual necessity for the purpose of quality assurance, training and compliance. All calls received into the Kennel Club General Enquiries, Petlog General Enquiries and Petlog Lost and Found teams will be automatically recorded for these purposes, as specified in our Call Recording Policy (available on request from our Data Protection Team). All call recordings will be processed and stored in compliance with the Data Protection Legislation.
3.8. Where we ask for your consent this will usually be for marketing purposes by email. Where our processing of personal data is based on your having given consent, you have the right as a data subject to withdraw that consent at any time. Please note that the withdrawal of your consent will not affect the lawfulness of any processing based on that consent before its withdrawal.

If you wish to invoke this right, please notify our Data Protection Department using the contact details set out in Section 2 above. Please include the words DATA PRIVACY REQUEST in the subject line of your email, or at the top of your letter.
4. Your rights as a data subject
4.1. This Section 4 sets out the rights that you have as a data subject, by reason of the General Data Protection Regulation.
4.2. The General Data Protection Regulation provides the following rights (subject to some exemptions):
4.2.1.  The right to request access to the personal data that we hold about you;
4.2.2. The right to request rectification of the personal data that we hold about you;
4.2.3. The right to request erasure of the personal data that we hold about you;
4.2.4. The right to request restriction of processing about you;
4.2.5. The right to object to processing; and

4.2.6. The right to data portability.

If you wish to exercise any of the above rights, please notify our Data Protection Department using the contact details set out in Section 2 above. Please include the words DATA PRIVACY REQUEST in the subject line of your email, or at the top of your letter.

 4.3.  You have the right to lodge a complaint with a supervisory authority. In the United Kingdom, the supervisory authority is the Office of the Information Commissioner, full contact details for which can be found at ico.org.uk/global/contact-us
5. Retention of Data
5.1. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
6. Recipients of Data
6.1. We use service providers to help us provide you with our services. Personal data may be transferred to these outsourced data processors, who act for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed. We only disclose your data to third parties for a limited number of reasons, these include: services delivery, communications, marketing, data management, technical support, evaluating our services and processing payments.
6.2. Such third parties have contracted with us as data processors under the requirements in the DPA 2018 and UK GDPR. They are contractually bound to only use personal data for the agreed purpose(s). Relevant persons working for these third parties will have access to your personal data under the terms of the data processor contract, but only to the extent necessary to perform their services for us.
6.3. These data processors agree to implement reasonable contractual and technical protections, to keep your data confidential, not sell your personal data to third parties and to not disclose your personal data to third parties except as may be required by law, as permitted by us or as stated in this Privacy Policy.
6.4. In appropriate circumstances we may disclose data to authorised bodies as required by law. This may include (but is not limited to) the Police, HMRC, Local Authorities/Trading Standards and so on.
6.5. We may provide personal data to our partners for administrative purposes where necessary and compliant.
7. Visitors to Kennel Club Websites

We use cookies to monitor how people use our websites.

7.1. We collect these cookies in order to provide you with our online services and to analyse visitor behaviour on our websites.
7.2. Cookie information is held on your browser and you can amend your browser settings at any time. However, please be aware that blocking or deleting all cookies will affect the usability of our websites.
7.3. Please see our Cookie Policy for further information on data we collect through our websites and how you can block and delete cookies
7.4. We may collect your Internet Protocol (“IP”) address, which is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, web servers can identify your computer by its IP address. In addition, web servers may be able to identify the type of browser you are using. The Kennel Club collects IP addresses for the purposes of internal security, website analysis, and system administration, including to assess the traffic on the website, and to maintain and make improvements to the website. We do not link IP addresses to personal information, but we can and will use IP addresses to identify a user when we feel it is necessary to ensure compliance with this Privacy Notice or our Terms and Conditions, to protect the website, users, or other visitors, or to comply with applicable laws.
8. Facebook Inc. – Custom Audience Ads
8.1. We may work with Facebook to display interest-based ads to you or to your friends on Facebook through a tool offered by Facebook called the Custom Audience Tool. This tool allows us to personalise our ads based on you or your friends’ experience on our services in order to provide ads tailored for each specific recipient.
8.2. We may share personal information with Facebook, which will then be hashed. This permits Facebook to identify our advertising audience based on the information that Facebook collects from its users. If you do not want to receive interest-based ads on Facebook, you can adjust your ad preferences through your Facebook settings.
9. Google Ads – Interest Based Ads
9.1. We may work with Google to display interest-based ads to you on Google Search through a tool offered by Google called Google Ads. This tool allows us to personalise ads based on your experience on our services in order to provide ads tailored for each specific recipient. A remarketing tag pixel uses your IP address as the unique identifier; however, it will not contain data such as your name, home address or phone number.
9.2. We may also share personal data with Google, which will be hashed to keep your data secure. This means that data is scrambled before being utilised to ensure nobody else can gain access to it. This sharing enables Google to identify our advertising audience and allows us to offer you the best possible online user experience and improve the relevancy of our advertising. It allows us to provide you with more of the content you want to see and allows us to evaluate the effectiveness of our marketing campaigns.
9.3. You can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings or the Google Marketing Platform opt-out page. Alternatively you can control the use of device identifiers by using your device’s settings.
10. Contact details

10.1. You can contact us at the Data Protection Team details above if you have any questions or concerns about personal data and privacy matters.

10.2. Please include the words DATA PRIVACY REQUEST in the subject line of your email, or at the top of your letter.
Schedule 1 – First Keepers

This Schedule sets out the Kennel Club’s processing of personal data relating to Petlog registrants (First Keepers).

What personal data do we process?

  • Name
  • Address
  • Email address
  • IP address
  • Telephone number
  • Breeder Licence
  • Petlog ID Number
  • Pet information (e.g. microchip number, pet details, passport number, KC Registration Number, tattoo number, collar tag numbers, deceased status)
  • Reports of missing animals

Where do we obtain your personal data from?

Personal data may be received from third parties (implanters, veterinary surgeons practice management systems) or directly from you as the data subject. For those using the Petlog Premium service, second carer information (name and contact details) and holiday/temporary contact information (name and contact details) will be provided by the keeper – these additional contacts are to aid reunification should the registered keeper be unavailable. Breeder licence number and deceased status may also be received from third parties (e.g. microchip implanters, welfare or vets).

Why do we process your personal data and what is the lawful basis?
We process your personal data for the following purposes:

Personal data type

Purpose

Administration and transactional communications.

Contractual Necessity

Provision of Petlog registration services relating to reunification.

Contractual Necessity

To maintain the Petlog database which hold information for the reunification of pets with their keepers.

Contractual Necessity

To invite and remind you to update your details.

Contractual Necessity

In respect of dogs, contractual services necessary to comply with the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).

Legal Necessity

Contacting you by email to provide animal related information and initiatives (no marketing communications).

Consent

Contacting you by post regarding related animal initiatives, and animal health and animal welfare research and information to help you enjoy and keep your pet safe, healthy and happy (no marketing communications).

Legitimate Interests

To carry out research relating to microchipping services, animal health and animal welfare.

Legitimate Interests

We also process personal data for the Kennel Club’s legitimate interests as we have outlined in the main Privacy Notice (paragraph 4.3). Please be assured that we will always take account of your personal data rights in doing so.

How long do we hold your personal data for?

Data is stored on the Petlog Database and is retained for the lifespan of the microchipped animal. Data may be removed on request thereafter.

Are you obliged to provide us with your personal data?

The provision of this personal data is a requirement necessary for the Kennel Club to administer its reunification database service through Petlog and, for dogs, compliance with the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).

Non-dog pet owners are not obliged to provide the personal data in question. However, if you do not provide the personal data, we will be unable to perform or provide Kennel Club services relating to your registration on the Petlog database.

For dogs, keepers are obliged to provide the information described in the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland). Consequences of failing to provide this information to a verified database may result in action being taken under the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).

Recipients of your personal data

  • Microchip Suppliers: Elanco Animal Health Incorporated (www.elanco.com) Elanco (the supplier of Tracer Advance) are a microchip supplier whose microchips are registered on Petlog. If your pet has a Tracer Advance microchip and if you have given your consent for such, your personal data may be provided to Elanco for them to contact you by email regarding their relevant products and services.
  • Compliant Microchip Databases: will have access to a look up tool into the Petlog database in order to check which microchip database holds the microchip record – this processing is based upon statutory requirements of the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).
  • Authorised Agents & Welfare Organisations: will have access to look up personal data in order to effect the reunification of pets and keepers – as is necessary for the provision of the service and/or law enforcement agencies e.g. the police or local authorities.
  • Statutory Authorised Bodies: we will also provide data as required upon receipt of enquiries from statutory authorised bodies e.g. the police or local authorities

Outsourced Data Processors

We disclose data to the following outsourced data processors in line with section 5 of our main Privacy Policy, for the purposes of managing our service or our communications:

  • Vetfone: (www.vetfone.co.uk) our service provider for out of hours calls, have access to a look up tool into the Petlog database in order to facilitate reunification services.
  • MBA Group: (www.mba-group.com) for Petlog Registrations and Petlog Premium Upgrades.

Do we use your data for any automated decision-making?

No automated decision making is taken using your personal data.

Any financial data arising from a transactional process will be held securely by the Kennel Club Finance Department in accordance and compliance with all statutory, HMRC and Financial Authority requirements.

Schedule 2 – New Keepers (Transfers)

This Schedule sets out the Kennel Club’s processing of personal data relating to Petlog registrants (New Keepers).

What personal data do we process?

  • Name
  • Address
  • Email address
  • IP address
  • Telephone number
  • Petlog ID number
  • Pet information (e.g. microchip number, pet details, passport number, KC Registration Number, tattoo number, collar tag numbers, deceased status)
  • Reports of missing animals

Where do we obtain your personal data from?

Personal data is received direct from you as the data subject or is provided by welfare organisations. For those using the Petlog Premium service, second carer information (name and contact details) and holiday/temporary contact information (name and contact details) will be provided by the keeper – these additional contacts are to aid reunification should the registered keeper be unavailable. Breeder licence number and deceased status may also be received from third parties (e.g. microchip implanters, welfare or vets).

Why do we process your personal data and what is the legal basis?

We process your personal data for the following purposes:

Personal data type

Purpose

Administration and transactional communications.

Contractual Necessity

Provision of Petlog registration services relating to reunification.

Contractual Necessity

To maintain the Petlog database which hold information for the reunification of pets with their keepers

Contractual Necessity

In respect of dogs, contractual services necessary to comply with the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).

Legal Necessity

Contacting you by email to provide animal related information and initiatives (no marketing communications).

Consent

To invite and remind you to update your details.

Contractual Necessity

Contacting you by post regarding related animal initiatives, and animal health and animal welfare research and information to help you enjoy and keep your pet safe, healthy and happy (no marketing communications).

Legitimate Interests

To carry out research relating to microchipping services, animal health and animal welfare.

Legitimate Interests

We also process personal data for the Kennel Club’s legitimate interests as we have outlined in the main Privacy Notice (paragraph 4.3). Please be assured that we will always take account of your personal data rights in doing so.

How long do we hold your personal data for?

Data is stored on the Petlog Database and is retained for the lifespan of the microchipped animal. Data may be removed on request thereafter.

Are you obliged to provide us with your personal data?

The provision of this personal data is a requirement necessary for the Kennel Club to administer its reunification database service through Petlog and, for dogs, compliance with the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).

Non-dog pet owners are not obliged to provide the personal data in question. However, if you do not provide the personal data, we will be unable to perform or provide Kennel Club services relating to your registration as a keeper on the Petlog database.

For dogs, keepers are obliged to provide the information described in the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland). Consequences of failing to provide this information to a verified database may result in action being taken under the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).

Recipients of your personal data

  • Microchip Suppliers: Elanco Animal Health Incorporated (www.elanco.com) Elanco (the supplier of Tracer Advance) are a microchip supplier whose microchips are registered on Petlog. If your pet has a Tracer Advance microchip and if you have given your consent for such, your personal data may be provided to Elanco for them to contact you by email regarding their relevant products and services.
  • Compliant Microchip Databases: will have access to a look up tool into the Petlog database in order to check which microchip database holds the microchip record – this processing is based upon statutory requirements of the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).
  • Authorised Agents & Welfare Organisations: will have access to look up personal data in order to effect the reunification of pets and keepers – as is necessary for the provision of the service and/or law enforcement agencies e.g. the police or local authorities.
  • Statutory Authorised Bodies: we will also provide data as required upon receipt of enquiries from statutory authorised bodies e.g. the police or local authorities

Outsourced Data Processors

We disclose data to the following outsourced data processors in line with section 5 of our main Privacy Policy, for the purposes of managing our service or our communications:

  • Vetfone: (www.vetfone.co.uk) our service provider for out of hours calls, have access to a look up tool into the Petlog database in order to facilitate reunification services.
  • MBA Group: (www.mba-group.com) for Petlog Registrations and Petlog Premium Upgrades.

Do we use your data for any automated decision-making?

No automated decision making is taken using your personal data.

Any financial data arising from a transactional process will be held securely by the Kennel Club Finance Department in accordance and compliance with all statutory, HMRC and Financial Authority requirements.

Schedule 3 – Authorised Agents & Welfare Organisations

This Schedule sets out the Kennel Club’s processing of personal data relating to Authorised Agents & Welfare Organisations.

What personal data do we process?

  • Name (individual or organisation)
  • Address
  • Email address
  • Telephone number
  • PIN or Vet code

Where do we obtain your personal data from?

Personal data is received direct from you as the data subject, or may be received from third parties (microchip suppliers).

Why do we process your personal data and what is the legal basis?

We process your personal data for the following purposes:

Personal data type

Purpose

Administration and transactional communications

Contractual Necessity

Maintaining the Petlog database which hold information for the reunification of pets with their keepers

Contractual Necessity

In respect of dogs, contractual services necessary to comply with the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).

Legal Necessity

Provision of Petlog registration services for keepers of microchipped animals relating to reunification.

Legitimate Interests

Facilitation of the reunification of registered animals

Legitimate interests

To carry out research relating to microchipping services, animal health and animal welfare

Legitimate Interests

We also process personal data for the Kennel Club’s legitimate interests as we have outlined in the main Privacy Notice (paragraph 4.3). Please be assured that we will always take account of your personal data rights in doing so.

How long do we hold your personal data for?

Data is stored on the Petlog Database and is retained for as long as you remain an authorised agent.

Are you obliged to provide us with your personal data?

The provision of this personal data is a requirement necessary for the Kennel Club to administer its reunification database service through Petlog. You are not obliged to provide the personal data in question. However, if you do not provide the personal data, we will be unable to perform any Petlog services relating to reunification.

Recipients of your personal data

  • Statutory Authorised Bodies: we will also provide data as required upon receipt of enquiries from statutory authorised bodies e.g. the police or local authorities.
  • Pet Keeper: if you report an animal as found and the keeper contacts Petlog directly, we will provide your details to aid the reunification.

Outsourced Data Processors

We disclose data to the following outsourced data processors in line with section 5 of our main Privacy Policy, for the purposes of managing our service or our communications:

  • Vetfone: (www.vetfone.co.uk) our service provider for out of hours calls, have access to a look up tool into the Petlog database in order to facilitate reunification services.

Do we use your data for any automated decision-making?

No automated decision making is taken using your personal data.

Any financial data arising from a transactional process will be held securely by the Kennel Club Finance Department in accordance and compliance with all statutory, HMRC and Financial Authority requirements.

Schedule 4 – Implanters

This Schedule sets out the Kennel Club’s processing of personal data relating to Authorised Agents & Welfare Organisations.

What personal data do we process?

  • Name (individual or organisation)
  • Address
  • Email address
  • Telephone number
  • PIN or Vet code

Where do we obtain your personal data from?

Personal data is received direct from you as the data subject, or may be received from third parties (microchip suppliers).

Why do we process your personal data and what is the legal basis?

We process your personal data for the following purposes:

Personal data type

Purpose

Administration and transactional communications

Contractual Necessity

Provision of Petlog registration services for keepers of microchipped animals relating to reunification.

Contractual Necessity

In respect of dogs, contractual services necessary to comply with the Compulsory Microchipping Regulations (England and Wales/Scotland and Northern Ireland).

Legal Necessity

Implementing the backtrack service, to facilitate reunification if there is no recorded keeper of a microchipped animal.

Legitimate interests

For Petlog registration queries, in order to maintain the Petlog database which holds information for the reunification of pets with their keepers.

Legitimate Interests

For invoicing purposes to the respective microchip supplier.

Legitimate Interests

We also process personal data for the Kennel Club’s legitimate interests as we have outlined in the main Privacy Notice (paragraph 4.3). Please be assured that we will always take account of your personal data rights in doing so.

How long do we hold your personal data for?

Data is stored on the Petlog Database and is retained for as long as you remain registered implanter.

Are you obliged to provide us with your personal data?

The provision of this personal data is a requirement necessary for the Kennel Club to administer its reunification database service through Petlog. You are not obliged to provide the personal data in question. However, if you do not provide the personal data, we will be unable to perform any Petlog services relating to reunification.

Recipients of your personal data

  • Statutory Authorised Bodies: we will also provide data as required upon receipt of enquiries from statutory authorised bodies e.g. the police or local authorities.
  • Microchip Suppliers: we will provide your data to our respective contracted microchip suppliers, as confirmation you have implanted the microchip.

Outsourced Data Processors

We disclose data to the following outsourced data processors in line with section 5 of our main Privacy Policy, for the purposes of managing our service or our communications:

  • Vetfone: (www.vetfone.co.uk) our service provider for out of hours calls, have access to a look up tool into the Petlog database in order to facilitate reunification services.

Do we use your data for any automated decision-making?

No automated decision making is taken using your personal data.

Any financial data arising from a transactional process will be held securely by the Kennel Club Finance Department in accordance and compliance with all statutory, HMRC and Financial Authority requirements.