Somerdale Pavilion Privacy Policy
Who we are
The Somerdale Pavilion Trust is a charity registered in England and Wales (Charity Number 1182426) and is registered with the Information Commissioner’s Office (ICO) as the Data Controller for the information that is held about you.
Our registered office is Somerdale Pavilion Trust c/o St Monica Trust, Cote Lane, Westbury-on-Trym, Bristol, BS9 3UN. If you have any questions or concerns about the way that we process your personal data, our Data Protection Officer (DPO) can be contacted via:
Craig Weeks, Head of Sports and Leisure Facilities, Somerdale Pavilion Trust, Tiberius Road, Keynsham, BS31 2FF.
Email: craig.weeks@somerdalepavilion.org.uk
Tel: 0117 332 9415 / 07495 171613
What we collect
We collect personal data about you for the purposes of processing. Personal Data means any type of data or combination of data types that may be used to identify you, these include:
• Information that you provide when you enquire about our services or become a member such as name, address, telephone number and email address.
• The name and contact details of your next of kin. Please note that it is your responsibility to make your next of kin aware that you are using their contact details for this purpose.
• Details of any services that you may have received from us or details that may have been provided to us by a third party about services that you are interested in.
• Information that you provide when taking part in a survey or when taking part in a competition or promotion.
• Recordings of any calls we receive or make.
• Feedback such as compliments and complaints.
• Financial information when you set up a membership with us or as an ad hoc payment.
• When you are a member, details of your attendance at the Somerdale Pavilion.
• Other types of information from sources such as business partners, advertising networks, analytics providers or any other third party that has obtained your permission to share information about you.
• Analytical Information that may be automatically collected when you visit our website such as information about the device you use, i.e. IP address, platform, operating system, browser type. Information about products you searched for, page response times, download errors, length of visits, page interaction details.
• When we collect information to register you, we may for particular reasons related to health and safety or demographic assessments, capture special categories of personal data, these categories are more sensitive than standard personal information and may include the following:
o Health data.
o Racial or ethnic origin.
o Religious or philosophical beliefs.
When we collect information
We may gather information from you at one of the following points:
• When you visit our website (please see the cookies section below).
• By telephone when you contact us regarding any of the services that we provide. For training purposes calls may be recorded.
• When you register with us and use our services.
• When you register as a member of any associated club.
• When you carry out a financial transaction.
• When you register to receive updates from us about our services.
• When you participate in a competition, survey, or promotion.
Data from third parties
Contact details and the name of individuals booking facilities on behalf of a club may be retained.
The lawful basis for processing the information that we gather
We will only use your personal data for the purpose(s) for which it was gathered and in accordance with this privacy notice and data protection law. Your personal data will be kept confidential and securely. We use the following legal gateways to allow us to process your personal data:
• Where it is necessary for us to fulfil our obligations under contract with you or where it is part of arranging a contract with you. This includes in pursuit of the delivery of services and any related matters such as billing, accounting, and auditing.
• When our or a third party’s legitimate interests allow, taking into account your interests, rights, and freedoms. This may include providing you with information, products, or services that you request from us, managing our relationship with you, notifying you of changes to our products and services, interacting with Move GB when you are registered with them.
• With explicit consent, such as in the case of direct marketing. When we use consent, we will make it clear, concise, and transparent about why we are requesting consent and what we are using it for. You will have the right to withdraw your consent to processing at any time.
• When we process special categories of personal data we will do so under the following legal basis:
o With your explicit consent.
o We are required to by law.
o It is necessary to establish, make or defend legal claims or court action.
o When it is in your vital interests in such situations that an injury has occurred, and you are incapable of providing consent.
Security of your personal data
We protect the personal data that you provide to us by ensuring that we have the appropriate organisational and technical measures in place to prevent unauthorised access, unlawful processing or the prevention of loss, destruction, or damage of that data.
Personal data that you provide to us will be held as long as necessary having regard to the purpose for which it was collected and in accordance with the Data Protection Act and any specific relevant legislation.
Where we are required to transmit or store data outside of the UK, EU or state to which an adequacy decision has been granted we will ensure that we have the appropriate safeguards in place to allow us to do so safely and securely.
Any financial transactions that are undertaken in the course of delivering services or products to you will be via a secure third party.
How long we retain personal data
We will retain personal data for a period commensurate with the purpose for which it was collected such as a reasonable business need, managing our relationship with you and managing our business.
We will retain information regarding your use of our services for a period of up to 8 years after you have ceased contact with us on the basis that it may be required as part of a legal claim.
Sharing your data
In the usual course of our business we may be required to share your personal data with third parties who support us in the delivery of our services. We will only ever disclose the minimum amount of information necessary to allow the third party to provide such support. Where a third party is used, we may make an assessment to provide us with assurances that they are compliant with data protection legislation.
Such sharing may include:
• Business partners, contractors, or sub-contractors for the performance of any contract that we have with you.
• Third parties for the purpose of debt collection.
• Delivery companies for the purpose of transportation.
• Third parties that are involved in the storage, retrieval, and destruction of data.
• IT companies who provide support or hosting in relation to the IT systems on which your data is processed.
• Move GB when you register for a service with us via their website.
• Medical professionals in the event of an emergency.
Cookies
Our website uses cookies to identify you from other users of the site. This helps us to provide you with a better experience when visiting our website and allows us to improve its accessibility, content, and presentation. We are required to ensure that you understand what cookies are used for and why we want to use them and that you provide appropriate consent based on your choices.
Cookies are small generally text files which are downloaded by your device when you visit any website. They are then sent back to the originating website on each subsequent visit, or to another website that recognises that particular cookie.
Cookies come in 4 categories:
1. Necessary
These are essential and required in order to enable you to access the website and use its features. Consent is not required for these cookies.
2. Performance
This type of cookie collects information about how visitors use the website, what pages they visit most often, if they receive error messages. The information that these cookies collect is anonymous as the information is aggregated into statistics. Web analytics that use cookies to gather data to enhance the performance of a website fall into this category. By using our online services, you agree to us processing the data gathered from these cookies.
3. Functionality
The choices that you make such as user name, language, or the region that you are in are retained by these cookies. They may also remember any customisation that you have made to your view of the website, such as text size. They can also be used to allow you to access a video or embedded content. By using our online services, you agree to us processing the data gathered from these cookies.
4. Targeting or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential Category 1 Cookies) you may not be able to access all or parts of our website. For information on how to delete cookies, please refer to: use https://ico.org.uk/for-the-public/online/cookies
Marketing
We engage in two types of marketing, Business to consumer (B2C) and Business to Business (B2B). if you use our services and engage with us as an individual, we will process your personal data for marketing purposes only if we have prior consent to. If however you engage with the Somerdale Pavilion Trust as a business or as a representative of a business we will process your contact information as a legitimate interest.
In either case you can stop receiving marketing communications from us at any point by emailing us. You will only need to withdraw consent or opt out once and you will no longer receive marketing communications from us.
Online advertising
We may use services such as Google Ads, Bing Ads, Facebook, Twitter and re-marketing to advertise our services across the internet. These services use code on our website and cookies from the advertising platform to allow them to anonymously know when a visitor has visited our websites from an advert and to show visitors our adverts on other websites.
• If you do not wish to participate in Google Ads Re-marketing, you can opt out by visiting Google's Ads Preferences Manager.
• You can also opt out of many third-party advertiser's use of cookies here.
• You can adjust your Facebook advertising preferences here.
• You can opt out of Twitter personalised ads in your Twitter settings here.
CCTV
Our premises are surveyed by CCTV for the purposes of security, images and videos will be retained for 30 days except where it may be used as part of an investigation or claim, this is in accordance with ICO guidance.
Your data protection rights
Under data protection law you have certain rights in relation to the personal data that we hold about you. The following rights that you may exercise are:
• Right of access
You may request a copy of your personal data from us as well as information about how we process that personal data. With certain exceptions we are required to provide this to you within 30 days of your request being made.
• Right of erasure
We will remove personal data once it reaches the end of its defined retention period.
• Data portability
The right to move, copy or transfer personal information you have provided to us.
• Right to rectification
With certain exceptions you have the right to correct any factually incorrect information held about you.
Should you wish to exercise your rights, have any comments or concerns, or want to know more about how we handle your data please send your request to craig.weeks@somerdalepavilion.org.uk or write to us for the attention of the Data Protection Officer (DPO) at:
Craig Weeks, Head of Sports and Leisure Facilities, Somerdale Pavilion Trust, Tiberius Road, Keynsham, BS31 2FF.
Email: craig.weeks@somerdalepavilion.org.uk
Tel: 0117 332 9415 / 07495 171613
Last review date: November 2019