Privacy Notice for Cleeve School Enterprises Ltd
(“Cleeve Sports Centre”).
Individuals have a right to be informed about how we (Cleeve School Enterprises Ltd, “Cleeve Sports Centre”) use any personal data that we hold about them. We comply with this right by providing 'privacy notices' (sometimes called 'fair processing notices') to individuals where we are processing their personal data.
This privacy notice explains how we collect, store and use personal data about current, prospective and past members and users of our facilities, in line with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
We, Cleeve Sports Centre, are the 'data controller' for the purposes of data protection law. This means that we are responsible for deciding how we hold and use personal information about you.
The personal data we hold:
Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
- Contact details (including e-mail and mobile phone number)
- Date of Birth
- Bank Details
Why we use this data:
- Contact you in respect of your membership
- Manage your club access
- Facilitate member rewards (if applicable)
- Resolve any problems you may have and improve our service to you
- Comply with our legal and regulatory obligations
Use of your personal information for marketing purposes
Where you have given us consent to do so, Cleeve Sports Centre may send you marketing information by email or text promoting products and services which we believe may be of interest to you. We may also contact you to receive feedback regarding our services. We will always provide the ability to review or change your preferences or unsubscribe from marketing information with immediate effect. You can also make your request via e-mail to email@example.com.
Our lawful basis for using this data:
We only collect and use your personal data when the law allows us to. Most commonly, we process it where we have obtained explicit consent to use it in a certain way, and where we have legitimate interests in processing the data.
Where we have obtained consent, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how to withdraw it.
Where we have legitimate interests in processing your data, we will carry out a 'balancing test' to make sure our processing does not infringe your interests, rights and freedoms. We will only use the data in ways that you would reasonably expect.
The legitimate interests we have are:
- Analysing the composition of our members and service users to help us decide future services, facilities, events and activities
- Analysing the usage of our facilities and services
- Providing you with marketing communications based on what we think you'll be interested in
In addition, we may process your personal data in order to comply with our legal obligations, such as our accounting and reporting requirements, and complying with our duties under equality legislation.
Less commonly, we may process your personal data in situations where:
- We need it to perform an official task in the public interest
- We need to protect someone's vital interests (save your life, or someone else's)
Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify our use of your data.
Collecting this information
Some of the information we collect from you is mandatory, and in some cases you can choose whether or not to provide the information to us.
Whenever we seek to collect information from you, we make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice.
We will only collect the data that we need in order to fulfil our purposes, which are set out above.
How we store this data
As a prospective member that has consented for us to contact you, Cleeve Sports Centre will retain your data for up to 12 months, unless you notify us that you no longer wish to be contacted.
If you join us, Cleeve Sports Centre will retain your data for as long as you are a member.
On termination of your membership, your personal data will be stored for a maximum period of 18 months for the purposes of responding to you in the event of any future indemnity claim that may arise. After this period, your personal data will be anonymized so you can no longer be identified from the information we hold.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We will dispose of your personal data securely when we no longer need it.
For the purposes of providing our services to you, your data is passed to our data processor:
ClubWise Software Ltd, 6 Tower Court, Horns Lane, Princes Risborough, Bucks, HP27 0AJ Company Reg: 3843268.
The data processor and group companies belonging to it are required by us to process your data in strict compliance with data protection legislation.
Your data will not be shared with any other third-party service providers without obtaining your prior consent. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of your details in line with Cleeve Sports Centre procedures.
We will never pass your personal information to anyone else, except where we are required or permitted to do so by law, for any successors in title to our business and suppliers that process information on our behalf both in the UK and abroad. We may also use and disclose information in aggregate (so that no individual customers are identified) for marketing and strategic development purposes.
Where it is legally required or necessary (and it complies with data protection law) we may share your personal information with law enforcement agencies, courts, tribunals.
How to access the personal information we hold about you
Individuals have a right to make a 'subject access request' to gain access to personal information that the school holds about them.
If you make a subject access request, and if we do hold information about you, we will:
- Give you a description of it
- Tell you why we are holding and processing it, and how long we will keep it for
- Explain where we got it from, if not from you
- Tell you who it has been, or will be, shared with
- Let you know whether any automated decision-making is being applied to the data, and any consequences of this
- Give you a copy of the information in an intelligible form
You may also have a right for your personal information to be transmitted electronically to another organisation in certain circumstances.
If you would like to make a request, please contact us.
Your other rights regarding your data
Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe. You have the right to:
- Object to the use of your personal data if it would cause, or is causing, damage or distress
- Prevent your data being used to send direct marketing
- Object to the use of your personal data for decisions being taken by automated means (by a computer or machine, rather than a person)
- In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict its processing
- Claim compensation for damages caused by a breach of the data protection regulations
To exercise any of these rights, please contact us.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact our data protection officer.
Alternatively, you can make a complaint to the Information Commissioner's Office:
- Report a concern online at https://ico.org.uk/concerns/
- Call 0303 123 1113
- Or write to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact us as follows:
- Send an email to: firstname.lastname@example.org or;
- Write to us at: Two Hedges Road, Bishops Cleeve, Cheltenham, GL52 8AE