GDPR 2018 PRIVACY NOTICE
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain. The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1. SPACE FITNESS & WELLBEING, based at Moor Cottage Studio, Moor Road, Burley Woodhead, Ilkley LS29 7BE, which hereafter for the purposes of this Privacy Notice will be referred to as Space, is pleased to provide the following information:
2. Who we are:
Space offers online fitness classes, private exercise sessions both online and in the studio and with fully qualified instructors and practitioners. We also offer events, courses and workshops in various health, fitness and wellbeing related topics. We do not diagnose and treat health conditions. Space may also offer other services, about which our instructors and practitioners will be pleased to provide more details.
3. Personal Data:
a) For the purposes of providing appropriate exercises and wellbeing sessions, Space may require relevant medical information. We will only collect what is relevant and necessary for your exercise or wellbeing sessions. When you visit Space, we will make notes, which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your exercise or wellbeing sessions, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of participating in activities at Space that you give your explicit consent to allow Space to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide information relevant to your sessions.
b) For marketing purposes, Space may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which Space believes may be of interest to you.
c) In making initial contact with Space you consent to Space maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Space may occasionally also act on behalf of its clients in the capacity of data processor, when we may promote other instructors or practitioners based at our premises, who may not be employed by us. Space does not broker your data and you can ask to be removed from our marketing database by emailing or phoning Space using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
f) Space will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
4. Legal basis for processing any personal data:
To meet our obligations obtained from explicit Physical Activity Readiness Questionnaire (PARQ) and legitimate interest to respond to enquiries concerning the services provided.
5. Legitimate interests pursued by Space:
To promote health, fitness and wellbeing activities for clients given consent (where applicable) by medical practitioners to pursue such activities.
Through agreeing to this privacy notice you are consenting to Space processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
Space will keep your personal information safe and secure, only staff, instructors and practitioners engaged in providing your exercises sessions and treatment will have access to your client records, although our administration team will have access to your contact details so that they can make appointments and manage your account. Space will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. Space may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staffor instructors.
8. Retention Policy:
Space will process personal data during the duration of any valid pass and will continue to store only the personal data needed for one year after the contract has expired to meet any legal obligations. After one year all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have engaged in classes or treatments will be retained until the child has reached the age of 25.
9. Data storage:
All Data is held in the United Kingdom. Space does not store personal data outside the EEA.
10. Your rights as a data subject:
At any point whilst Space is in possession of, or processing your personal data, all data subjects have the following rights
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling. In the event that Space refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Space can confirm what information it holds about you and how it is processed.
11. You can request the following information:
Identity and the contact details of the person that has determined how and why to process your data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Space and information about these interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
How long the data will be stored.
Details of your rights to correct, erasure, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12. To access what personal data is held, identification will be required:
Space will accept the following forms of identification (ID) when information on your personal data is requested:
A copy of your driving licence, passport, birth certificate and utility bill not older than three months.
A minimum of one piece of photographic ID listed above and a supporting document is required.
If Space is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to:
firstname.lastname@example.org or by phoning +44 (0)7999 835660 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by Space you have the right to complain to us. The details for this contact is:
Telephone +44 (0)7999 835660 or email: email@example.com
Space Fitness and Wellbeing, Moor Cottage Studio, Moor Road, Burley Woodhead, Ilkley LS29 7BE