Forest of Dean Gymnastics & Fitness
Privacy policy
Forest of Dean
Gymnastics Club (FODGC) is the data controller and is committed to complying
with our legal responsibilities under data law in ensuring your personal
information is kept secure.
It is important
that staff and members are aware of this policy and read this privacy notice
carefully as it contains key information about how and why we process (collect,
store, use and share) information about you and your associated rights.
About us
Forest of
Dean Gymnastics & Fitness is a ‘not for profit’ organisation constituted as
a Charity and a Company Limited by Guarantee.
Our members
are gymnasts and fitness members who affiliate to the Forest of Dean Gymnastics
Club and Fitzone Fitness Gym. We
provide a number of benefits to members including the opportunity participate
in our activities, which include classes, challenges, competitions, fundraising
events and other learning and development activities.
How we use
personal information
We collect personal
information about members of Fitzone & the Gymnastics Club including
coaches, gymnasts, and any people associated with gymnasts, e.g. parents,
guardians/carers, people with parental responsibility for gymnasts and also for
coaches, officials, trustees, volunteers and people who provide services on our
behalf. We also collect personal
information on Fitzone Fitness members.
Our core purposes include:
·
To conduct business and manage membership; to
inform club members about activities in which they or their families can
participate;
·
To provide gymnastics training, events and
competitions and to invite individuals to participate, judge, coach, officiate
or assist at relevant events;
·
To inform you of the activities that are
offered;
·
To support learning and development of those
involved in gymnastics and fitness;
·
To comply with applicable laws and protect
legitimate regional interests and legal rights. This includes, but is not
limited to the use of your information relating to legal claims and regulatory
and compliance activity.
·
To support our county and regional associations
we may provide information on the names and contact details of judges and to confirm
that all participants meet the criteria to participate in County events.
Affiliation
to the Club
If you affiliate a child as a
gymnast at the club, we will need the name and contact details of the person
registering the child (parent/guardian).
This is required for contact in case of emergency.
If you are an adult, we will
need your contact details and those of another emergency contact.
To enable you to make payment
for Club fees by BACS or Direct Debit we may need your bank details or the
person making the payments bank details
We will use this information to
process payment and to communicate with you about your club membership, invite
you to participate in activities and to vote at our AGM. It will enable us to send you information
about activities and other benefits and services to which your affiliation
provides.
If you cancel or do not renew
your membership we will delete your information after one year, apart from
details of any financial transactions which we need to retain for 6 years after
the end of the relevant financial year, in the event of a tax or banking
inquiry.
CCTV
We use closed circuit television
(CCTV) images to protect the Company’s property and to provide a safe and
secure environment for employees and visitors to the Centre. This policy sets out the details of how the Company
will collect, use and store CCTV images.
The Company’s CCTV facility,
unless there are exceptional circumstances, will only record images. There is no audio recording i.e.
conversations are not recorded on CCTV.
The data collected from the
system will assist in:
·
Prevention or detection of crime or equivalent
malpractice
·
Identification and prosecution of offenders
·
Monitoring of the security of the Company’s
premises
·
Ensuring that health and safety rules and
Company procedures are being complied with
·
Monitoring the well being of Fitness member’s
working out in the gym
·
Identification of unauthorised actions or unsafe
working practices
Cameras are located at strategic
points throughout the Club, principally at the entrance, reception, downstairs
Fitzone and the upstairs mezzanine. The
cameras only cover communal or public areas on the premises and they have been
sited so that they provide clear images.
No camera focuses, or will focus on toilets, shower facilities, changing
rooms or private offices.
All cameras are also clearly
visible. Appropriate signage is
displayed so that employees, members and other visitors are aware they are
entering an area covered by CCTV.
Images produced by the CCTV
equipment are intended to be as clear as possible so that they are effective
for the purposes set out above.
Images may be recorded either in
constant real-time (24 hours a day throughout the year), or only at certain
times, as the needs of the Company dictate.
As the recording system records
digital images, any CCTV images that are held on the hard drive of a PC or
server are deleted and overwritten on a recycling basis and, in any event, once
the hard drive has reached the end of its use, it will be erased prior to
disposal. Access to, and disclosure of,
images recorded on CCTV is restricted.
This ensures that the rights of individuals are retained. Images can only be disclosed in accordance
with the purposes for which they were originally collected.
The Centre Manager or Board of
Trustees are the only people permitted to authorise disclosure of images to
external third parties such as law enforcement agencies. All requests for disclosure and access to
images will be documented, including the date of disclosure, to whom the images
have been provided and the reasons when they are required. If disclosure is denied, the reason will be
recorded.
The Company will ensure that all
employees handling CCTV images or recordings are trained in the operation and
administration of the CCTV system and on the impact of the laws regulating data
protection with regard to that system.
Information for Participation in Activities
We recognise our
responsibility to ensure that individuals are safe to participate in, and while
participating in gymnastics or other fitness activities. We try to be accessible to people with
disabilities, we therefore may need medical information to ensure that anyone
with a medical condition is not harmed through participation in our
activities. We may need to ask
participants in some of our activities to provide details of and keep us
updated about any relevant medical conditions/injuries or disabilities.
We will use this information for the following purposes:
·
To undertake risk assessments and make any
appropriate adaptations e.g. to training programmes and to ensure your safety
whilst taking part in any activities
· To make reasonable adjustments to support people
with disabilities to access the services we provide.
We will only hold this information whilst you continue to
participate in the activity, unless we are required to retain this information
in connection with a legal claim.
Video and Photos during Training,
Competitions or Events
During training, or at competitions and events we may video or take photos at the event as part of
our legitimate interest to promote the Club's activities. We may also publish this on our website,
social media account, local media and in our communications. Any video or photos of children will be
published in line with our Safeguarding Policy. Any filming during training
will be used for coaching/ learning purposes.
Occasionally a professional photographer, approved by the Club, mat
attend events.
Please let us know if you do not wish you or your child to
be filmed or photographed or do not want your image to be published.
We will delete any images over 10 years old unless we
consider them to be of public interest and should consequently be archived for
historical purposes. Where images have
been published on social media, these platform providers may continue to
process your data after our retention period has lapsed.
Videos taken at training sessions or at coach education
seminars will be retained only for as long as they are required for that
purpose.
Website
Our website is maintained by an external company who is
responsible for ensuring the site is secure.
We do not use any tracking or analytics on our website. When you use our website, your IP address is
logged by the web server but they are not able to identify you from this
information alone.
Sharing your
information
We have a legitimate interest in
sharing personal information with British Gymnastics to ensure the sport is
safe and well-governed and where relevant to access support and advice.
We will not otherwise share your information with any other
organisations unless we have your consent to do so or to comply with a legal
obligation or in exceptional/emergency circumstances where we believe that the
sharing of information about you is vital to protect the data subject or
another person, including safeguarding a
child or another individual who is at risk. Any information that is shared will be
strictly limited to what is required to ensure those at risk are protected from
harm. This will be carried out in
accordance with the law and relevant government guidance.
Reasons we
collect and use your personal information
The legal reasons we rely on to
process information about you or your child are as follows:
·
Performance
of a contract - where you sign up to a service we provide, we will need to
use your personal information to provide that service.
·
Legal
obligations - we need to process your information to comply with legal
obligations. This will include
maintaining your account and asking you to provide information about any
disabilities or medical information so that we can support access to our
services and keep participants safe.
·
Consent
– To send out newsletters and to take and publish photographs at training and
events.
We also process personal
information for the following Legitimate
interests:
·
To respond to any general queries and
complaints;
·
To enable us to run the business of the Club and
administer Gymnastics & Fitness memberships;
·
To support our gymnasts & fitness members by
monitoring performance and individual needs;
·
To provide information to BG, SWAGA and GAGA for
regulatory and operations purposes and to enable the Club to participate in
relevant British Gymnastics activities;
·
To hold emergency contact information for
members;
·
To promote our activities by publishing
information, photographs from our regional events , news and competition
results on our website and through social and local media for publicity
purposes
· To respond to misconduct and safeguarding concerns.
If the information we are processing is a special category
of data (e.g. health/medical data), in addition to the legal bases identified
above, we require a separate agreement for processing this type of data. We would usually rely on your explicit
consent but may also, as a condition of membership, process this type of
information where the processing is required to establish, exercise or defend a
legal claim, to comply with employment law or where there is a substantial
public interest.
Transfers of data out of the EEA
We may transfer your personal information to countries which
are located outside the United Kingdom & European Economic Area (EEA) for
the follow purposes:
·
In order to enter competitions and events
We will not transfer your information without your consent
to any country or organisation outside the EEA unless there is a European
Commission adequacy decision for the specific country to which the data is
transferred or where we can be certain that there are adequate safeguards
provided for your information and individual rights standards that meet the
GDPR requirements
Individual
rights
You have important rights under
data protection law. In summary these include:
·
To be informed about how your information is
processed (set out above).
·
To access any personal data held about you.
·
To have your data rectified if it is inaccurate.
·
To have your data
deleted (except if there is a valid lawful reason to retain it).
·
To have your
information restricted or blocked from processing.
·
To portability
·
To object to
direct marketing and any processing based on legitimate interests.
To object to automated
individual decision-making and profiling (we do not undertake these activities)
Click here to learn more about your rights;
https://ico.org.uk/for-organisations/data-protection-fee/
To exercise any of your
rights or if you have any questions about our privacy policy please contact: The
management of the Forest of Dean Gymnastics Club If you are concerned about the
way we are processing your personal information, you have a right to complain
to the ICO who can be contacted by telephone on 0303 123 1113.
Keeping your personal information secure.
We have appropriate security
measures in place to prevent personal information from being accidentally lost,
used or accessed in an unauthorised way.
We limit access to your personal information to those who have a genuine
reason to need to know it. Those
processing your information will do so only in an authorised manner and are
subject to a duty of confidentiality. We
also have procedures in place to deal with any suspected data security breach
and will notify you and the ICO of any personal data breaches in line with our
legal obligations.
Our links
with:
British
Gymnastics (BG), South West Gymnastics Association (SWAGA) and Gloucestershire
Amateur Gymnastics Association (GAGA)
We affiliate to other organisations who are connected with
Gymnastics. They provide competitions,
events and training opportunities for both coaches and gymnasts.
British Gymnastics (BG) is the governing body for the sport
of Gymnastics. It offers award schemes,
competitions and events in which our gymnasts and teams may participate.
British Gymnastics provides a website, Facebook account and
online entry system for competitions which requires them to handle personal
information on our behalf. They are
contractually required to ensure that your information is secure and to only
use the information to provide the services we have requested.
BG & SWAGA provide information for gymnasts, coaches and
parents as required to enable events to take place and for the sport to
operate. This is necessary as
individuals who participate in national and regional events need to hold
British Gymnastics membership. We also
need to confirm with British Gymnastics that those individuals who are signed
up for one of our activities meet the required criteria for participation, such
as age and qualification and any mandatory safeguarding requirements. This may require us to share information with
British Gymnastics in line with the regulatory requirements to which we are
subject as an affiliated association of BG.
GAGA
provides competitions and squad training for gymnasts in Gloucestershire. Information is required to enable the running
of events and grouping of individuals by age or level as for the SWAGA &
BG.
Gymnastics
Competitions and Events
Any gymnast who is a paid up
current member of the Gymnastics Club and who meets the relevant participation
criteria may be entered in external or Club competitions. To do this we will require your child's name,
date of birth, contact details and confirmation that you wish them to be
entered. We will use this information
only to administer or enter the event.
We will delete any entry information about events that you
have attended after one year. With your consent we may use your contact details
to send you information about other events that we believe may be of interest
to you.
To enter an external competition
we will need a gymnast's name, DOB and gender, especially if we have to submit
entries via the British Gymnastics online competition entry system. This will automatically verify that the
gymnast and coaches hold British Gymnastics membership and meet the required
entry criteria. The results of
competitions will also be published on the relevant website. Any publication of images of children will
be done in accordance with the British Gymnastics Safeguarding Policy and guidance
on use of images.
We will try to
ensure that the gymnast and where relevant the person with parental
responsibility has agreed for the child
to be entered into the event and understand how their personal information will
be used.
Regional Squads and Residential
events
If a gymnast is selected to
participate in a county, regional or national squad, we will need to collect
the gymnast’s contact details, emergency contact details and any relevant
information including specific needs, emergency medical information and dietary
requirements (if required).
We may also collect information about potential and existing
squad members’ performance, including results in competitions, trials and
assessments.
We will only hold this information while the gymnast is a
current member of squad except where we are obliged to retain the information
as part of a legal or insurance claim.
Changes to the privacy notice
We keep our privacy notices under regular review. We
may need to change this privacy notice from time to time, if changes are made
members will be informed via the membership portal.