The protection of your personal information is extremely important to Renfrewshire Leisure. We will only collect, process and store your personal data as set out in this Privacy Policy and in compliance with applicable data protection legislation.

This Privacy Policy explains what personal information Renfrewshire Leisure collects, how we use it to provide services to you and how you can check and update any of your personal information. 

This Privacy Policy is reviewed annually and was last updated in June 2019.

Controller

Renfrewshire Leisure Ltd is the Data Controller of any personal information collected by Renfrewshire Leisure. We need to handle personal information about you so that we can provide better services for you.

When we ask you for personal information, we will:

• make sure you know why we need it
• ask only for what we need
• protect your personal information and make sure nobody has access to it who shouldn’t
• take proportionate precautions to prevent the loss, misuse or alteration of your personal information
• let you know if we share it with any other organisations
• make sure we don’t keep it longer than necessary, and
• not use your personal information for marketing without your permission

In return we ask you to:

• give us accurate information, and
• tell us as soon as possible if there are any changes, such as a new address

This helps us to keep your information reliable and up to date.

Why do we need your personal information  and what do we do with it?

We only ask for the minimum personal data necessary to provide the service you request or are entitled to, and in most cases, this includes but is not limited to, your name and contact details.

The purpose of processing is the service or entitlement for which the information is being collected, and your personal data will not be used for another purpose, unless further specified on the form collecting the information, or otherwise provided to you as appropriate or as provided for by law.

Please refer to the specific purposes on the form for further processing of your information.

We also use your information to verify your identity where required, contact you by post, email or telephone and to maintain our records.

The precise legal basis for us using your personal information will vary depending on which service we are providing to you, but processing personal information is always carried out under one or more of the following:

a) Necessary for the performance of a task carried out in the public interest by Renfrewshire Leisure

b) Necessary for the performance of a contract with you (or take steps to enter into a contract with you)

c) Necessary for compliance with a legal obligation to which Renfrewshire Leisure is subject

d) On the basis of your consent

e) Necessary to protect the vital interests of you or another person.

f) Necessary for the legitimate interests of Renfrewshire Leisure or a third party, except where such interests are overridden by your interests, rights or freedoms

Where do we get your information?

We collect information when you sign up with us, contact us, and when you use or purchase our services.

For example: when you sign up for a gym membership, join our mailing list, enter any promotions, competitions or prize draws through one of our services and you agree to be contacted.

How we use your information

We use your personal data to keep in touch with you, to provide services to you, and to improve our services.  We will also use your information to make you aware of any changes to the service you signed up for or to ask for your thoughts on the service we offer (e.g. customer surveys).

From time to time we may contact you with other information that we think are appropriate to you e.g. contacting gym members to advise them of a new fitness class coming into operation in our gyms.

We will also use your data to process financial transactions for the services you have purchased, to make sure that all amounts owed are paid on time.  In relations to outstanding amounts owed, we may also share your data with trusted Debt Management Partners including Renfrewshire Council and the Courts.  Where we do share this information, we will ensure that a data processing agreement is in place to safeguard your data and that all data sharing is in line with data protection legislation.

Consent

Where possible, we will only process your information with your consent.  In most cases, we will presume that by providing us with your details in order to obtain a service from Renfrewshire Leisure, that you are giving your consent to us in order to provide that service to you.  We will ask you to give your consent to the use of your personal data, when you take a membership or join our mailing or marketing lists.

Consent is not always required to process personal information, and there may be legal reasons why we may have to process personal information without your consent.

If we have asked for your consent to process your information, you have the right to withdraw this, in whole or in part, at any time. We will explain any consequences of this to you including any impact on the service we are delivering.

Legal obligations

By law, we are required to provide information to other public bodies and charities including HM Revenues and Customs, courts, and other formal bodies dealing with legal processes, and various external regulatory bodies. We also have an obligation to assist in the prevention of crime and we will, therefore, supply information which we are asked to provide to the police or other crime prevention agencies, provided that we are satisfied that disclosure is lawful and proportionate.

How we share your information

We work closely with a number of other public bodies and charities including Renfrewshire Council, NHS Greater Glasgow & Clyde, Sports Scotland, Macmillan Cancer Support.  Information will generally only be shared with these partners with your consent and always in line with data protection legislation.

External contractors are appointed from time to time by Renfrewshire Leisure to process information on our behalf under our instruction.  When they are appointed, data processing agreements (legal contracts) are put in place which requires the contractors to keep this personal data safe and secure and prohibits them from using this data for any other purpose.

Renfrewshire Leisure also carries out survey and carries out statistical analysis of the information that we hold so that we can monitor our performance to improve service delivery.  Anonymised statistics which do not identify individuals may be published or shared with other parties.

Why we keep hold of your information

Renfrewshire Leisure will only keep your information for as long as is necessary. Once we no longer need to keep your information, it will be securely destroyed.

We keep information while you’re our customer or after you’ve left us, but only as long as we need it for the purposes described above. How long we keep it depends very much on the type of information and purpose.

For example, we might need to sort out payment arrears on a gym membership.

In each case, the length of time that we need to keep the information may be different.   Our data retention policy is available on our website.

Use and disclosure of staff information

Employee information is held by Renfrewshire Leisure to carry out our duties as an employer.  We will hold personal, financial and sensitive information as defined in the section above in order to comply with our legal obligations and role as employer. 

We share this data with trusted partners including: Renfrewshire Council, as a data processor for Renfrewshire Leisure, to manage the payroll service; HMRC to allow for deduction of PAYE and national insurance contributions; trade unions to allow trade union subscriptions to be collected and; other recipients of payroll deductions or salary sacrifice schemes. 

Full details of the use and disclosure of staff information is available in our employee privacy notice.

Your information rights

You have a number of legal rights in relation to the information that we hold about you, including:

• The right to request details of the information we have about you. There are a couple of ways to do this and some requests have to be writing for legal reasons. You can contact us using the contact details in the section below.
• The right to withdraw your consent to the use of your information where we are relying on that consent (for example, you can opt out of receiving marketing messages from us). Please note that we may still be entitled to process your information if we have another legitimate reason for doing so.
• The right to ask that we update your information if it is inaccurate or incomplete.
• The right to ask that we erase your information in certain circumstances.
• The right to request that we restrict the processing of your information in certain circumstances.
• The right to make a complaint with the Information Commissioner ico.org.uk, if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contact us” section below. These are not absolute rights as there may be circumstances where the Renfrewshire Leisure is legally obliged to process your information in a particular way.

Children

Depending on age requirements or the nature of service requested, where it is necessary to process a child’s personal information on the basis of consent, we may need the consent of the person with parental responsibility for the child. This will be specified on the form if applicable.

Transferring our information outside the UK or European Economic Area

Renfrewshire Leisure will not transfer personal data outside the European Economic Area (EEA) unless this can be avoided. Renfrewshire Leisure will only transfer data outside the UK and the EEA when it is satisfied that the party which will handle the data and the country it is processing it in will provide adequate safeguards for personal privacy.

Profiling and automatic decision-making

Renfrewshire Leisure do not use profiling or automated decision-making processes. Some processes are semi-automated (such as anti-fraud data matching) but a human decision maker will always be involved before any decision is reached in relation to you.

Contact with you (marketing)

You may choose to opt in or restrict the collection or use of your personal information for direct marketing purposes. Whenever you are asked to fill in a form, look for the box that you can tick to indicate that you consent to hear from us. If you have previously consented for marketing purposes, you can withdraw your consent by contacting us, or for every electronic marketing message we send you, there is also an unsubscribe link, and where applicable, a link where you can update all your preferences and personalisation options in a user preferences control portal.

Keep in mind, even if you unsubscribe, we may still need to contact you (for service notification purposes)

Right to complain

When we ask you for information, we will abide by all relevant legislation. however, if you are unhappy with the way we process your personal data you have the right to complain. Any complaints regarding your data should be addressed to the Data Protection Officer, Heather Syme (contact details below). If the matter is not resolved, you can contact the Information Commissioner’s Office, who can also provide independent data protection advice (www.ico.org.uk)

Contact us

If you have any queries, please contact us at:                            

fiona.naylor@renfrewshire.gov.uk