1. PURPOSE OF THIS NOTICE

This notice describes how we collect and use personal data about you, in accordance with the UK General Data Protection Regulation (GDPR), the Data Protection Act and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. ABOUT US

People’s Gym & Fitness Centre (PG&FC) is a not-for-profit gym and fitness centre run by a committee of volunteers on behalf of the community of Sedbergh and District.

For the purpose of the Data Protection Legislation and this notice, PG&FC is the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

The Data Protection Point of Contact with responsibility for assisting with enquiries in relation to this privacy notice or our treatment of your personal data is the PG&FC Secretary. The contact details are: Email: secretary@sedberghgym.club

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain personal data about you, for example, when:

• you request information in respect of the services provided by PG&FC;

• you fill in our online registration forms as part of our joining process;

• you contact us by social media, email, telephone, or post (for example when you have a query about your membership or PG&FC services);
• your photo is taken at induction;
• the gym has a CCTV system, and the images it records, and any images downloaded from it, are data.

4. THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include the following:

• your personal details which may include your name, date of birth, photograph, address, email address, or phone number;

• health information which is classed as special category personal data where the data is necessary for our duty of care for your safety using the equipment or taking exercise;

• details of contact we have had with you in relation to the provision, or the proposed provision, of PG&FC services;

• details of your membership of PG&FC;

• correspondence and communications with you;

• information about any complaints and enquiries you make to us, or we make to you;

• details of any disciplinary actions we take against you;

• CCTV images.

5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data to administer your membership, and to provide the membership services you are signing up to when you register with the club. Our lawful basis for processing your personal data is that we have a contractual obligation to you as a member to provide the services you are registering for.

Reasons we need to process your data include:

For membership and club management

• processing of health information which is classed as special category personal data where the data is necessary for our duty of care;

• processing of your online membership forms and payments;

• club newsletter to advise members of changes to subscriptions or administration of the club, events such as a temporary closure, and incidents that have broken club rules;

• review of CCTV images to investigate incidents causing damage or injury and to check whether club rules have been broken;

• sharing data with committee members to provide information about membership renewals and club activity.

For funding and reporting purposes

• sharing anonymised data with a funding partner as a condition of grant funding

• analysing anonymised data to monitor club trends;

• sending a club survey to improve your experience as a club member

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for statistical and management purposes.

Any special category health data we hold on you is only processed for the purpose of fitness or health checks to allow the safe use of the equipment. We process this data on the lawful basis of consent. Therefore, we will also need your explicit consent to process this data, which we will ask for at the point of collecting it during completion of the online PAR-Q (Physical Activity Readiness Questionnaire).

When an incident is reported where CCTV images would assist in establishing what happened, a nominated committee member or member of staff is responsible for identifying relevant footage. The downloading of any images required onto a password-protected memory stick, deciding on who should be allowed to see the images for the purposes required, and any other reviewing or discussion of the footage will be carried out in private, away from the gym. Depending on the incident the people authorised to see the data may be other committee members, staff, gym members involved in the incident, and police officers if a criminal offence is suspected.  When the investigation is complete, the downloaded data is deleted.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.?

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.?

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have with you and may refuse membership.?

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data retention?

We will retain your personal data for as long as you are a member of PG&FC. Any personal data we hold on you will be securely destroyed within one month of the cancellation date of your membership.?

CCTV is in operation throughout the gym areas, with the exception of the toilet facilities. CCTV images obtained are automatically overwritten after 21 days. Where they have been saved to investigate an incident, the images will be destroyed when the incident has been resolved.

Change of purpose?

Your data is not processed for any purposes other than those detailed in this policy.

6. DATA SHARING

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers:

• IT and cloud services

• Inductions

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions and it may be retained within their cloud services.

The PG&FC has the following social media pages:

• Facebook and WhatsApp.

All members are free to join these pages. If you join one of the social media services please note that the provider of the social media platforms have their own privacy policies and that the PG&FC does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data on the PG&FC social media pages.

7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We will not transfer the personal data we collect about you outside of the EEA.

8. DATA SECURITY

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. All data held about you is held in password protected accounts. In addition, we limit access to your personal data to those agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Any paper-based information produced for the purposes of a new member induction will be destroyed after the induction is complete and any information has been uploaded to the membership records. Photographs taken of you at the induction are also uploaded to your online record, and the original is deleted from the device used.

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.

9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify the PG&FC secretary of any changes of which we need to be made aware of using the contact details below.

Your rights in connection with personal data

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

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.

• Request correction of the personal data that we hold about you.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below).

• Object to processing of your personal data 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 basis.

• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

• Members have a right to see images of themselves on CCTV as they would with any other data. Members requesting access are required to state the time and date involved to enable the data to be more easily isolated.
• Exceptions to the right of access. The images of other members on the footage can only be downloaded and shared with their written permission. The member requesting access is responsible for gaining permission from such third parties where that is required. If permission is not obtained and third-party data cannot be excluded, the PG&FC reserves the right not to release the data.

Please note that we may not be able to fulfil a right to be forgotten request if we have other valid reasons for retaining your data.

If you want to exercise any of the above rights, please email secretary@sedberghgym.club.?

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

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.

10. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email secretary@sedberghgym.club

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. We may not then be able to perform the contract we have entered into with you, and your membership may be terminated.

11. CHANGES TO THIS NOTICE

Any changes we may make to our privacy notice in the future will be provided to you by email to the latest address that we have on our files for you.

This privacy notice was last updated on 22 January 2025.

12. HOW TO COMPLAIN

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email secretary@sedberghgym.club , the Data Protection Point of Contact, or telephone 07399 854 659 leaving your name and contact number stating you are making a GDPR related enquiry.

You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:

Information Commissioner's Office Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone - 0303 123 1113 (local rate)

Website -?https://ico.org.uk/concerns