The Freemen hold only very limited data about individuals – name, postal (and perhaps email) address and phone number. This information is used only for the purposes for which it was provided, namely to maintain contact between the Freemen of Oxford. It is not shared with any other organisation. Details will be deleted on request. The Information Commissioners Office’s advice on consent to contact people contains a category called ‘legitimate interests’. A private-sector organization like the Freemen can process personal data without specific consent from the individual, if it has a genuine and legitimate reason, unless this is outweighed by harm to the individual’s rights and interests. This category covers the Freemen’s activities.
The Freemen will normally only process that personal data so as to produce a mailing list. This very limited use would come within the scope of a legitimate interest.