PRIVACY NOTICE FOR FULLER LIFE HEALTH AND FITNESS CENTRE MEMBERS

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The Fuller Life Health and Fitness Centre is controlled and managed by Watford Grammar School for Girls. The school is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you before, during and after your relationship with us as a member of the Fuller Life Health and Fitness Centre, in accordance with the UK General Data Protection Regulation (GDPR).

Watford Grammar School for Girls is an Academy Trust school, company number 07348254, registered office at Lady’s Close, Watford, WD18 0AE, registered as a company in England and Wales, and an exempt charity. We are well known for our rich academic curriculum, our strong and supportive pastoral care, and the wide range of extended activities that, taken as a whole, educate, encourage and empower our girls. The school motto is Sperate Parati - or ‘Go forward with preparation’ - which encapsulates our aim for every member of the school community.

We are proud of the strong academic traditions and the importance of service to others that have shaped the ethos of our school since its foundation by Elizabeth Fuller in 1704. We value hard work and nurture scholarship, always encouraging our girls to achieve excellence in all fields of study. The girls have the opportunity to excel at music, drama and sport, as well as to play an active role in the wider community by taking part in many charitable activities. Thus they learn to be their best selves: hard working, compassionate and high achieving in all areas of life.

We are a diverse and thriving community, founded on consideration, toleration and trust. Each girl is given opportunities to develop confidence and resilience both in and outside the classroom, and to develop a sense of personal responsibility that is best summarised in the maxim ‘I can do it, and I will do it' - words which every member of the school learns and takes to heart.

In support of the overall aims and advancement of our school and the wider community we open up membership of our Fuller Life Health and Fitness Centre to pupils, parents/carers and others.

As part of ensuring the effective running of our school and its associated operations it is essential that we hold and use data and information about parents/carers, pupils, staff, governors/trustees, and others with whom we have relationships including the members of our Fuller Life Health and Fitness Centre. It is important to us that we do this professionally and in line with our statutory, moral and contractual obligations, and this notice is part of how we explain how we do this. Legally the school is a Data Controller under the Data Protection Act 2018 / the UK General Data Protection Regulation. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. The responsible officer at the school is Michael Lewis who is Data Protection Officer (DPO). This notice applies to current and former members of the Fuller Life Health and Fitness Centre. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

(a) Used lawfully, fairly and in a transparent way.
(b) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those                     purposes.
(c) Relevant to the purposes we have told you about and limited only to those purposes.
(d) Accurate and kept up to date.
(e) Kept only as long as necessary for the purposes we have told you about.
(f) Kept securely.

 

THE TYPE OF INFORMATION WE HOLD ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are special categories of more sensitive personal data which require a higher level of protection. Sensitive personal data is defined in our Data Protection Policy.

We will collect, store, and use the following categories of personal information about you:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
• Date of birth;
• Gender;
• Next of kin and emergency contact information [and please note, where you provide this information to us, it is your responsibility to             ensure that those named are aware of and accept the terms of this Privacy Policy];
   July 2022
• Bank account details, and related information for us to collect membership payments via the PayPal service;
• CCTV footage (see CCTV policy for further information about this) and other information obtained through electronic means such as             swipecard records;
• Records of your reading / consenting to policies, procedures and other directives relating to your time as a member of the Fuller Life             Health and Fitness Centre
• Information about any surveys or marketing initiatives you may have participated in, or if you have signed up to our newsletter
• Details of your attendance at our site recorded by our systems, as well as the making of bookings related to your membership; we may         use membership card systems or, in future, biometric systems to administer admission to our sites
• Technical information collected during your online interaction with us, such as IP address

   We may also collect, store and use sensitive personal data including the following:

• Information about your health, including any medical condition or related records which are made known to us at the time of your                becoming a member of the Fuller Life Health and Fitness Centre or subsequently, and which may have an impact on or be relevant to           your use of the facilities made available to members.

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HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about you primarily from your membership application and from the health questionnaire normally completed at the same time. We may also gather further information in the course of your relationship with us, for example if you tell us about a change in your health while you are a member of the Fuller Life Health and Fitness Centre or when you use the Centre. If you are a member of our school community we may already hold information about you in another capacity which will be covered by the relevant Privacy Notice.

 

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information as permitted under article 6 of the UK General Data Protection Regulation, for example in the following circumstances:

(a) Where we need to perform the contract we have entered into with you;
(b) Where we need to comply with a legal obligation.

We may also use your personal information in the following situations:

(c) Where we need to protect your interests (or someone else’s interests);
(d) Where it is needed in the public interest or for official purposes; for example for the NHS Test and Trace service during the COVID-19            pandemic
(e) Where you have given your consent, for example if you choose to sign up for any additional services we may offer

We do not generally process personal data on the ‘legitimate interests’ basis allowed for under the UK GDPR. If we do ever do this, we will carry out a Legitimate Interests Assessment first in line with the requirements of the Information Commissioner’s Office, and only use this basis should it be justified under that Assessment. See our Data Protection Policy for further information

 

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you, to enable us to comply with legal obligations and/or where it is needed in the public interest or for official purposes. The situations in which we will process your personal information are listed below.

• To provide and administer your membership and use of the Fuller Life Health and Fitness Centre, and associated services
• To assess any issues relating to your fitness to use the services or equipment provided as part of your membership of the Fuller Life             Health and Fitness Centre
• To administer your payment of membership fees

In addition, the School also uses CCTV cameras around the school site for security purposes and for the protection of staff, pupils and others on site. CCTV footage may be referred to during the course of investigations should any matter requiring it arise. CCTV footage involving any individual will only be processed to the extent that it is lawful to do so. Please see our CCTV policy for more details.

 

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with access to the Fuller Life Health and Fitness Centre), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of users of the Fuller Life Health and Fitness Centre) or we may be unable to discharge our obligations which may be in the public interest or for official purposes (for example, to notify information to NHS Test and Trace if required).

 

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an
unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

HOW WE USE SENSITIVE PERSONAL DATA INFORMATION

Particularly sensitive personal data requires us to ensure higher levels of data protection. Sensitive personal data is defined in our Data Protection Policy. We need to have further justification for collecting, storing and using this type of personal information under article 9 of the UK General Data Protection Regulation. We may process special categories of personal information in the following circumstances:

(f) In limited circumstances, with your explicit written consent.
(g) Where we need to carry out our legal obligations and in line with our Data Protection Policy.
(h) Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme,         and in line with our Data Protection Policy.
(i) Where it is needed to maintain your health and safety as a user of the Fuller Life Health and Fitness Centre, and to ensure other users          remain safe, subject to appropriate confidentiality safeguards. This is most likely to involve noting any medical conditions which may be        manifest and impact your ability to use the facilities of the Fuller Life Health and Fitness Centre, or potentially contacting your GP or

    other specialist about them

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Do we need your consent?
We do not need your consent if we use your sensitive personal data in accordance with our written policy where processing is necessary:

• for reasons of substantial public interest, on the basis of UK law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and we provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

In other circumstances, we may approach you for your written consent to allow us to process certain sensitive personal data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a term or condition of your membership that you agree to any request for consent from us, although when we ask for your consent to contact your GP or other specialist if required in relation to any health conditions which may affect your use of our facilities, it will impair our ability to keep you and others safe when using our facilities if you decline. We will record our asking for the consent and your decision whether to grant permission or not.

 

INFORMATION ABOUT CRIMINAL CONVICTIONS

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.

 

DATA SHARING

We may have to share your data with third parties, including third-party service providers and other organisations.

In particular, we may share your data with organisations and individuals including, but not limited to, the following:

• the provider of the membership systems / app for the Fuller Life Health and Fitness Centre, as well as the provider of payment services        which collects your membership subscription
• with the NHS Test and Trace service during the COVID-19 pandemic, as required to co-operate with this service and to assist with

   contact tracing
• insurance providers, for example if we need to file a report of an incident
• your GP (or other specialist) only if this is necessary as a result of a medical condition made known to us which may impact your use of our facilities

We require third parties to respect the security of your data and to treat it in accordance with the law. Some of the organisations referred to above are joint data controllers with us. This means we are all responsible to you for how we process your data.

 

Why might we share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or to protect your health and safety, where it is needed in the public interest or for official purposes, or where we have your consent. 

 

Which third-party service providers process your personal information?

“Third parties” includes third-party service providers (including contractors and designated agents).
  The following third-party service providers process your personal information for the following reasons:
• PayPal Business, for the purposes of collecting your regular membership payments
• Wix.com, the website/app providers who provide and maintain the membership systems we use to interact with you; and please note that     the Wix.com membership platform may include links through to social media providers or single sign ons, and in this case if you click           through to other sites then that site’s Privacy Policy will apply
• Green Shed Creative, our website designers, may process your personal information during setup of membership systems

You should note that if you make private arrangements with one of our trainers for a session or class outside of normal membership hours and contract with them to provide that class, your contact data will be exchanged directly between yourself and the trainer and not be passed by us. You should take care to note the Privacy Policy of any provider over which your data is exchanged, for example if you make contact with them via private social media accounts then the social media provider’s policies will apply and we will not be involved in this direct contact, nor will our Privacy Policy apply.

Please see above for a full list of where third parties (whether service providers or not) may use your personal data as described.

 

How secure is your information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. You should note their own Privacy Policies which may also apply when you use the services provided by the third parties.

 

What about other third parties?

We may share your information with other third parties if we are required lawfully to do so, or if we have your consent, for example if you consent to receive marketing communications from our partners. In these circumstances your data will only be transferred securely and in accordance with the consent you have given, and as noted in this Privacy Notice you have the right to change your mind at any time where your consent is the only basis on which we are relying for processing your data in this way.

Transferring information outside the UK

Data stored electronically may be saved on a cloud-based system which may be hosted in overseas, including outside of the UK. If this happens we will take steps to ensure the data is managed and protected as if it were covered by the same protections which apply in the UK.

Personal data may be transferred to other countries, including countries outside the UK, for specific essential purposes – for example if a specific part of your use of our facilities requires this. Appropriate steps will be taken to keep the data secure.

 

DATA SECURITY

We have put in place measures to protect the security of your information. Details of these measures are available in our Information Security policy.

Third parties who are processing personal data on our behalf will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

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. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer, Michael Lewis. Please note that if you choose to communicate privately with a trainer (for example, to arrange a private session or class) from the Fuller Life Health and Fitness Centre, you will be communicating via other systems/platforms and as noted above their Privacy Policies will apply.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

DATA RETENTION

How long will we use your information for?

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, insurance or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Retention Policy which is available from the Data Protection Officer, Michael Lewis. 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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a member of the Fuller Life Health and Fitness Centre we will retain and securely destroy your personal information in accordance with our Data Retention Policy.

 

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your membership with us. In particular please ensure your contact and Next of Kin information is up to date.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (data subject access request). This enables you to receive a copy of the personal                       information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate                       information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no          good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you        have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is             something about your particular situation which makes you want to object to processing on this ground. You also have the right to object     where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal             information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer, Michael Lewis, in writing.

The legal timescale for the school to respond to a Subject Access Request is one calendar month. As the school has limited staff resources outside of term time, we encourage you to submit Subject Access Requests during term time and to avoid sending a request during periods when the School is closed or is about to close for the holidays where possible. This will assist us in responding to your request as promptly as possible. For further information about how we handle Subject Access Requests, please see our Data Protection Policy.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer, Michael Lewis. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO, Michael Lewis.
 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact Michael Lewis, Data Protection Officer.

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July 2022