Our full privacy policy (Agency)

Places for People Leisure Management Ltd Privacy Notice

This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by Places for People Leisure Management Ltd and its subsidiary company Places for People Leisure Limited (referred to in this Privacy Notice as “Places Leisure”).

Places Leisure is committed to protecting your privacy when you use services and facilities operated by Places Leisure referred to in this Privacy Notice as the “services”.

The Privacy Notice below explains how we use information about you and how we protect your privacy.

We have a Data Protection Officer who makes sure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, please contact the Data Protection Officer, at datacontroller@pfpleisure.org

Who Are We?

Our principal address is 305 Grays Inn Rd, London WC1X 8QR but you can search for your local centre here: Find a centre

Places Leisure are part of Places for People Group. More information about the Places for People Group can be found at www.placesforpeople.co.uk and by clicking on ‘About Us’.

We may update our Privacy Notice from time to time. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.

Our Agency Relationship with Local Authorities

Important: Places for People Leisure Management Ltd operates certain leisure centres as an agent on behalf of local authorities. This means:

·       Where we operate a centre under an agency agreement, the local authority is the data controller for personal information relating to your membership and use of the centre;

·       We act as a data processor on behalf of the local authority, processing your personal data in accordance with their instructions and data protection legislation.

·       The contract for your membership or use of services is between you and the local authority, with us performing those contractual obligations as their agent.

·       For certain activities (such as our own marketing, group-wide services or additional services not covered by the agency agreement), we may act as a separate data controller.

Which Local Authority is Your Data Controller?

The data controller for your personal information depends on which leisure centre you use. The following centres are operated under agency agreements:

Centre Name	Local Authority (Data Controller)	Local Authority DPO Contact
Albany Outdoors	Royal Borough of Kingston upon Thames Council	dpo@kingston.gov.uk   Privacy notice and data protection | Royal Borough of Kingston upon Thames
Chessington Sports Centre
Balham Leisure Centre	Wandsworth Council	dpo@richmondandwandsworth.gov.uk   Data Protection Policy - Wandsworth Borough Council
Battersea Leisure Centre
Latchmere Leisure Centre
Putney Leisure Centre
Roehampton Sports & Fitness Centre
Tooting Bec Lido
Tooting Leisure Centre
Wandle Recreation Centre

 

For centres operated under agency agreements, your local authority is responsible for determining the purpose and means of processing your personal data. You can contact your local authority’s Data Protection Officer using the details in the table above.

We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business, both when acting as agent for local authorities and in our own capacity.

How to contact us

If you need to contact us in connection with our processing of your personal data, you can contact us in the following ways:

For centres operated under agency agreements:

·       Contact your local authorities Data Protection Officer (details in the table above) for questions about how your data is used and your rights.

·       Contact our Customer Service team for operational queries about your membership.

·       Contact our Data Protection Officer for questions about how we process your data on behalf of the local authority.

For general enquiries:

• Via our Customer Service team, details of which you can find in your membership contract.
• Via your local Privacy Officer by letter Data Controller, Places for People Leisure Management Ltd, The Gurney Office, Building Three, Riverside Way, Camberley, Surrey, GU15 3YL.
• By email datacontroller@pfpleisure.org

We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes of improving services to you. 

Why we collect your Personal Information

Do you know what personal information is?

Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.

Information we may collect about you may include (but is not limited to):

Name

Address

Telephone numbers

Email addresses

Data of birth

Gender

Occupation

Ethnicity

Bank details

Employment Status (only if applying for concessionary memberships)

Health data

CCTV images

Computer IP address

Dependent Details (only where applicable)

Photo image (required as part of the provision of your membership card and is essential for safety and access control purposes)

Did you know that some of your personal information might be classified as ‘special’?

Some information is ‘special’ and needs more protection due to its sensitivity. It’s often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal information relating to your: 

Sexuality and sexual health

Religious or philosophical beliefs

Ethnicity

Physical or mental health

Trade union membership

Political opinion

Genetic/biometric data

For agency operated centres: The local authority (as data controller) will only collect this type of information if it is necessary for your contract so that we can provide the right services to you on their behalf.

We will only collect this type of information if it is necessary to your contract so that we can provide the right services to you.

We may at times need to share this information. We will only do this if we have your consent or if there are legal requirements for us to do so. We may receive information about you from other data controllers, such as the police who might tell us about a crime they are investigating where this impacts on your membership contract. If you give us this information about yourself when communicating with us, you do so because you consider it forms part of a legitimate interest for us to hold this information on our records.

If we ask for any sensitive personal data about you, we will always tell you why we need it and ask for your consent to hold it.

Why do we need your personal information?

For agency-operated centres, we process your personal information on behalf of the local authority to:

·       Deliver services and support to you under the local authority's contract with you

·       Carry out the local authority's obligations arising from their contracts with you

·       Manage the services the local authority provides to you through us as their agent

·       Improve services

·       Prevent and detect crime/fraud

·       Investigate any complaints you have about services

·       Check the quality of services

·       Collate anonymised information for demographics and facility usage for service review with public bodies

For our own purposes, we may process your personal information to:

·       Provide additional services beyond the agency agreement

·       Conduct group-wide operations (such as finance and IT services)

·       Send marketing communications

·       Comply with our own legal obligations.

How the law allows us to use your personal information

There are a number of legal reasons why we need to collect and use your personal information.

For Agency-Operated Centres: when we process your personal data on behalf of the local authority, the legal basis is determined by the local authority as data controller. Generally, this will be:

·       performance of a contract – the contract between you and the local authority for leisure services

·       legal obligation – where the local authority must process data to comply with the law

·       public task – where processing is necessary for the local authority to perform its public functions

·       legitimate interests - where the local authority (or we on their behalf) have a legitimate reason to use your data and your rights are protected

·       consent – where you have given clear permission (such as for marketing communications or special category data)

For our own processing activities:  Generally, we collect and use personal information for the purposes of where:

• you are entering or have entered into a contract with us
• you, or your legal representative, have given consent
• it is necessary to protect someone in an emergency
• it is required by law or to comply with contractual obligations with local authorities
• you have made your information publicly available
• it is necessary for legal cases
• it is necessary for archiving, research, or statistical purposes

How we communicate with you

At Places Leisure we believe in putting our customers in the driving seat when communicating.

Customer service communications

For agency-operated centres, we may contact you on behalf of the local authority to tell you about:

·       service enhancements or improvements to your local centre;

·       your current membership status

·       centre closures or operational updates

·       customer surveys to help improve services.

These communications form part of the local authority's contract with you and are sent by us as their agent. We will contact you through email and SMS for these service communications.

We do not need your consent for these operational communications as they are necessary for performing the contract or are in the local authority's legitimate interests.

All customer surveys will contain an easy opt-out link.

Customer service communications via SMS/text messaging and calls

If you supply us with your telephone contact details, we may use them to call or send you operational text messages.

Examples of operational text messages include:

• Confirming an appointment, that you have requested
• Emergency site updates from your local centre
• Asking you to contact a named person or department

Marketing communications

This is important, please read carefully:

For agency-operated centres: marketing communications about leisure services at your local authority-operated centre will be sent:

·       On behalf of the local authority as data controller

·       Based on either the local authority’s legitimate interests OR your explicit consent, depending on the nature of the communication

·       Using our systems and platforms as the local authority’s processor.

From Places Leisure directly: we may also wish to send you marketing about:

·       Other services at Places Leisure operated centres nationally.

·       Places for People Group services.

·       Partner offers and benefits.

For these communications, we are the data controller and will always obtain your separate consent or rely on our own legitimate interests (with an easy opt-out).

Prospective customer communications

When you make an enquiry with us about an agency-operated centre, we collect your details on behalf of the local authority. We will keep your contact information for six months, after which we will delete your data if you have not become a member or continued communicating with us.

We will always give you an opt-out route when communicating with you. To make sure you keep receiving our latest offers beyond this time, email our central enquiries@pfpleisure.org inbox confirming your opt in or just speak to a member of our team at your local centre.

We may also contact you to follow-up on any failed online purchases where we feel we can offer assistance to you.

We do not ask for your consent to contact you for these product or Service messages as we have assessed (on behalf of the local authority) that it is in our legitimate interest to keep you informed for a limited period.  You can opt-out at any time.

Past customer communications

If you are a past member of an agency-operated centre and have not opted out to marketing, the local authority may wish to stay in touch through us. We will send you occasional messages and keep you informed about products or Service information. We will continue to share these updates with you for six months following the end of your membership, after which time we will stop this communication.

To continue receiving offers beyond this time, email enquiries@pfpleisure.org or speak to our team.

Prospective and past member customer communications via SMS/text messaging

If you supply us with your telephone contact details as part of your original enquiry or during your past membership and have not opted out to marketing, we may use this information to send you a monthly update on products and services that we believe are of interest to you via SMS. We understand that not everyone wants to receive marketing through SMS, so if you wish to opt out to these messages please use the opt-out link in the SMS message or contact us at enquiries@pfpleisure.org, requesting to opt-out.  

Consent and your preferences centre

To support our ongoing relationship, the local authority (through us would like to send you information on other products and services may be of interest to you. We will rely on consent for the majority of direct marketing. You can remove your consent and ask us to stop at any time through:

·       Our online customer preference centre (log in to your online account);

·       Emailing enquiries@pfpleisure.org

·       Speaking to reception at your local centre

Any changes you make will be communicated to the local authority as data controller.

We only use what we need!

Where we can, we’ll only collect and use personal information if we need it to deliver a service or meet a requirement on behalf of the local authority. 

If we don’t need personal information we’ll either keep you anonymous if we already have it for something else or we won’t ask you for it. For example, in a survey we may not need your contact details, so we’ll only collect your survey responses.

If we use your personal information for research and analysis, we’ll keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.

We won’t sell your personal information to anyone else.  

We may share your information with other companies within our group for shared services (such a finance processing). Where we do this while acting as data processor for the local authority, this will be in accordance with our agreement with the local authority. Where we act as a controller in our own right, we will always ask for your consent to do this, and you can ask us to stop at any time.

What you can do with your information 

The law gives you a number of rights to control what personal information is used by us and how it is used.

For agency-operated centres: these rights are exercised against the local authority as data controller. We will assist you in exercising these rights and will forward requests to the local authority where appropriate.

Right of Access

You can ask for access to the information we hold on you.

You have the right to ask for the information we have about you. When we receive a request from you in writing, we must give you access to what personal information we’ve recorded about you (subject to certain exemptions)

For agency-operated centres:

• Submit your Subject Access Request to the local authority's Data Protection Officer (contact details are in the table at the start of this policy)
• You may also submit requests to us, and we will forward them to the local authority
• The local authority must respond within one month

For information we hold as controller in our own right:

• Submit requests to our Data Protection Officer at the address below

However, we can’t let you see any parts of a record which contain:

• Confidential information about other people; or
• May be held in preparation to defend legal claims

Making a Subject Access Request

A request for personal information can be made via email or in writing. This is known as a subject access request. In order to make a subject access request you will need to provide the following information:

• your name
• your address
• enough information to identify your records
• Proof of identity if requested

Acceptable proof of ID?

• Copy passport with signature (please remove your passport number)
• Copy driving license picture with signature (please remove your driver number)
• Copy of signed tenancy or contract with us

You can write to us at the following address:

For agency-operated centres – your local authority (see table above).

For other matters: Data Protection Officer c/o Data Control Team

Places for People Leisure Management LTD.

The Gurney Office

Building Three

Riverside Way

Camberley

Surrey

GU15 3YL

 

Alternatively, you can download a copy of our Subject Access Request Form. Please ensure you attach copies of your identity documents with the document reference numbers removed). If you have any difficulties completing the form or are unable to make a request in writing, please contact us on 01276 418200.

We will not start your subject access request until we are satisfied that you have provided us with enough information for us to identify you.

Once you have made a request you will receive an acknowledgement, and your request should be answered within one month. In certain circumstances, we are allowed to take longer but we will tell you if we feel we may need longer without undue delay from when we receive your request.

You can ask to change information you think is inaccurate

You should let us know if you disagree with something we may have recorded about you.

We may not always be able to change or remove that information, but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

Please contact enquiries@pfpleisure.org and we can deal with your request. Alternatively, you can speak to the reception team at your local Centre.

You can ask to delete information (right to erasure)

In some circumstances you can ask for your personal information to be deleted, for example: 

• Where your personal information is no longer needed for the reason why it was collected in the first place
• Where you have removed your consent for us to use your information (where there is no other legal reason for us to use it)
• Where there is no legal reason for the use of your information
• Where deleting the information is a legal requirement

For agency-operated centres: The local authority as controller will assess whether erasure is appropriate under data protection law and their own retention obligations.

Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure.

Please note that we can’t delete your information where:

• we’re required to have it by law
• it is for historical research, or statistical purposes where it would make information unusable
• it is necessary for legal claims

You can ask to limit what we use your personal data for

You have the right to ask us to restrict what we use your personal information for where: 

• you have identified inaccurate personal information, and have told us of it
• where we have no legal reason to use that information, but you want us to restrict what we use it for rather than erase the information altogether

For agency-operated centres: Restriction requests will be assessed by the local authority as controller.

We’ll inform you before we carry on using your personal information.

You can ask to have your information moved to another provider (data portability)

You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.

However, this only applies if we’re using your personal information with consent (not where we are processing your personal information for contractual, legitimate interests, legal obligations or vital interests as a legal basis) and if decisions were made by a computer and not a human being. 

For agency-operated centres: Data portability is unlikely to apply to most services, but you can ask the local authority to consider your request.

Right to understand automated decisions made about you

You can ask to have any computer made decisions explained to you, and details of how we may have ‘risk profiled’ you.

You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you’ve consented to it. 

You also have the right to object if you are being ‘profiled’. Profiling is where decisions are made about you based on certain things in your personal information, e.g. your health. 

If and when your personal information is used to profile you, in order to deliver the most appropriate service to you, you will be informed. 

If you have concerns regarding automated decision making, or profiling, please contact the Data Protection Officer at datacontroller@pfpleisure.org  or your local authority’s DPO.

Visiting our websites

When you visit one of our websites, (placesforpeopleleisure.org, placesleisure.org, pfpleisure-pochub.org, placesgym.org and placesgym.co.uk) we collect standard internet log information for statistical purposes.

• We use cookies to collect information in an anonymous way, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
• We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
• When we collect personal information, for example via an online form, we will explain what we intend to do with it.

Using cookies helps us to improve our site and to deliver a better and more personalised service.

Our websites contain links to various third-party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.

More information is available in our cookie policy

Live Chat

Places Leisure provides an online chat facility to help visitors with their queries and navigation around the website. Where the online chat facility is present it involves setting cookies and collecting information as described in more detail in this policy. By accepting an invitation to chat, you consent to the cookies and the processing of information as described in this policy.

The online chat facility involves the collection of your personal data that you voluntarily provide via the textboxes of the entry form. The information is needed so that the chat facility can function, agents can personalise their assistance and answer your request and to monitor and improve the quality of the chat facility.

When Places Leisure invites you to chat, cookies are set on your device recording chat date, start/end-time and duration. These are session cookies so will be deleted from a device when the browser is next closed. Most browsers are initially set to accept cookies, but you can reconfigure your browser to refuse cookies or previously request a confirmation from you. For more information about cookies and how to refuse or delete them, see www.allaboutcookies.org. Please note that the chat facility may not work properly if Places Leisure invites you to a chat and you have set your browser to refuse cookies.

The online chat facility serves for pre-sales communications only and no contract is formed or altered. Please do not provide any payment data, credit card data or sensitive data via chat communications.

If you have any concerns or questions about this facility, please contact the Data Control Team at datacontroller@pfpleisure.org

Video and Photograph Consent

Places Leisure often takes and/or uses photographs or video recordings for publicity purposes. These images may appear in any of our marketing materials including printed mediums, digital (including web and social media including Facebook) and within local media.

Prior to using any personal information captured in either photographs or video recordings we will always ask for your permission and will request that you complete a consent form prior to sharing your data across any of the above marketing mediums. Consent forms will also be used for capturing your permission on behalf of your child/children.

For agency-operated centres: Consent for publicity materials may be obtained on behalf of the local authority, on behalf of Places Leisure, or both, depending on how the materials will be used. This will be made clear on the consent form.

Please be aware that social media platforms and web publications are available world-wide, including in countries where there may be no data protection legislation.

Keeping your information secure

We store personal information both electronically and in paper form.

We implement security policies, processes and technical security solutions to protect the personal information we hold from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

For agency-operated centres: We maintain these security standards in accordance with our agreements with local authorities and their requirements as public sector data controllers.

When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.

Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.

How we use your telephone number

Text messages and contact via telephone provide a direct way to contact and share information with you about the services that can be delivered to you. It can also help you to receive important messages about your membership, important site updates e.g. temporary closures and other services that can be provided to you.

If you provide your telephone number, we may keep in contact with you by text.

Sharing your telephone number with third parties

We may pass your telephone number to third parties so that we can meet contractual obligations. We may also share your telephone numbers if we are required to by law.

We may supply the details to our approved third-party contractors who are delivering or performing services on our behalf, and these companies must not use your information for any other purpose. We never share or sell your telephone numbers to telesales/marketing companies.

Who do we share your information with?

Data Sharing Under Agency Agreements

For agency-operated centres: Your personal information is collected on behalf of the local authority as data controller. We share data with the local authority in accordance with our agency agreement, including:

·       Membership and booking information

·       Financial transaction data

·       Usage statistics and attendance records

·       Customer feedback and complaints

·       Incident reports and safeguarding matters

This sharing is necessary for:

·       The local authority to fulfil its public functions

·       Contract management and performance monitoring

·       Financial reconciliation and reporting

·       Compliance with public sector transparency and accountability requirements

We use a range of organisations to either store personal information or help deliver the services. Where we have these arrangements there is always an agreement in place to make sure that the organisation complies with data protection law. 

For agency-operated centres: Third parties we use are sub-processors appointed on behalf of the local authority. The local authority has been informed of, and where required has approved, these arrangements.

We may enter into partnerships with other organisations such as local authorities and the police. In order to protect your information, we will enter into a legally binding data sharing agreement with partner organisations before any sharing takes place. It is not always possible for us to tell you that personal information is being shared, for example when we are working with the police or other agencies to help the investigation or detection of a crime as to do so may prejudice that investigation.

We are likely to share your personal information with the following:

• Local Authorities

For agency-operated centres, the local authority is the data controller receiving regular reports and data transfers. For other matters, we may share data with the local authorities for services they process.

• Police

We may share your personal information with the police for the purposes of preventing or detecting a crime or fraud.

• Safeguarding, Support Agencies and Charities

We may share your personal information with these organisations where we suspect there may be safeguarding or welfare concerns. We will usually try to gain your consent in advance, but we may make a safeguarding referral without consent in situations where we feel there is a significant risk

• Debt Recovery Agents

We may share your personal information with debt recovery agents for the purposes of recovering any outstanding charges owed.

• Legal Services and Partners

We may share your personal information with our legal services or solicitors if we are preparing or defending a legal claim or in relation to any contractual provisions.

• Business Asset Transactions

If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. For agency-operated centres, any such transactions require local authority consent and involvement

• Places for People Group companies

We may share your information with shared service functions within the Places for People Group, such as for the purpose of financial transaction when making payments to us. Places for People Group shared services comply with and process personal information within the same privacy standards and procedures. For agency-operated centres, such sharing is conducted in accordance with our processor obligations to the local authority

For agency-operated centres, the following act as sub-processors processing data on behalf of the local authority:

Harlands Services Limited – Member payment services

Salesforce.com EMEA Limited – Marketing services, used to manage customer communications and will process data under our instructions as processor for the local authority. 

Technogym S.p.A. – Mobile Fitness App service

To support the provision of Places Locker App, our mobile fitness app we will share your personal information with Technogym S.p.A. By taking up a membership we will share your personal information to support the set-up of your Locker App invitation as we have assessed that it is in our legitimate interest to offer you this membership benefit. You can tell us to stop at any time by contacting enquiries@pfpleisure.org

GroupMove Limited – Provision of on demand exercise class services via Places Leisure Virtual Studio

To support the provision of Places Leisure Virtual Studio we will share your personal information with GroupMove Limited. This will only be shared with your direct consent as part of your Virtual Studio membership if taken up. Places Leisure are not responsible for any in-app purchases made and customers should contact MoveGB directly.

High-Risk Processing

Where there is a high risk to your personal information, we will complete a privacy assessment before we share personal information, to make sure we protect privacy and comply with the law.

For agency-operated centres: Privacy impact assessments are conducted in conjunction with the local authority as controller.

Legal Duties and Serious Risks

Sometimes we have a legal duty to provide personal information to other organisations, this is often because we need to give that data to the police, courts, local authorities or government bodies.

We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:

• in order to detect and prevent a crime and fraud; or 
• if there are serious risks to the public, our staff or to other professionals;
• safeguarding of vulnerable individuals

If we’re worried about your physical safety or feel we need to take action to protect you from being harmed in other ways, we’ll discuss this with you and, if possible, get your permission to tell others about your situation before doing so.

For all of these reasons the risk must be serious before we can override your right to privacy. 

We may still share your information if we believe the risk to others is serious enough to do so.

There may also be rare occasions when the risk to others is so great that we need to share information straight away. 

If this is the case, we’ll make sure that we record what information we share and our reasons for doing so. We’ll let you know what we’ve done and why if we think it is safe to do so and will not cause harm, distress or further risks to you, our staff, other professionals and/or the public.

How do we protect your information?

We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them. Examples of our security include:

• Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
• Pseudonymisation, meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of the Places for People Group could work on your information for us without ever knowing it was yours
• Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
• Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong
• Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)

For agency-operated centres: We maintain security standards in accordance with public sector requirements and our contractual obligations to local authorities. Local authorities have the right to audit our security measures.

Where in the world is your information?

The majority of personal information is stored on systems in the UK. But there may be some occasions as our technology services progress where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the EU. 

We will always have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party. 

We’ll take all practical steps to make sure your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.

For agency-operated centres: Any international transfers are conducted in accordance with public sector requirements and the local authority's instructions. We will only transfer data outside the UK/EU where the local authority has approved appropriate safeguards.

 

How long do we keep your personal information?

There’s often a legal or a contractual reason for keeping your personal information for a set period of time.

For agency-operated centres:

• Retention periods are determined by the local authority as data controller
• The local authority must comply with public sector retention requirements, including the Local Government Transparency Code
• We will keep your personal data for the duration of providing services under the contract between you and the local authority
• When your contract has ended, we will keep data for the period specified by the local authority for auditing, reporting, and legitimate interest purposes
• After that time, we will either anonymise or destroy your information in accordance with the local authority's instructions

For information we hold as controller in our own right:

·       We will keep your information for the duration of providing a service or product to you under our contract.

·       When your contract has ended, we will keep your personal data for a set time for auditing and reporting purposes and for legitimate interest purposes.

·       After that time, we will either anonymise or destroy your information.

You can ask us for a copy of our retention periods by contacting us at:

Data Protection Officer c/o Data Control Team

Places for People Leisure Management Limited

The Gurney Office

Building Three

Riverside Way

Camberley

Surrey

GU15 3YL

 

For agency-operated centres, you can also request retention schedules from your local authority's Data Protection Officer.

 

How to tell us of a data breach

Places Leisure and Places for People Group take responsibility to protect the personal information we hold about those with whom we work seriously. We are accountable for our processing and take necessary technical and operational steps to maintain information security protections.

If you suspect your personal information or that of others may have been at risk of a data protection breach, please contact us.

For agency-operated centres: We have a duty to report data breaches to the local authority as data controller. The local authority is responsible for assessing whether to report the breach to the Information Commissioner's Office and affected individuals. We will cooperate fully with any breach investigation.

Where can I get advice?

If you have any worries or questions about how your personal information is handled:

For agency-operated centres:

• Contact your local authority's Data Protection Officer (details in the table at the start of this policy)
• Contact our Data Protection Officer at datacontroller@pfpleisure.org

For other matters please contact our Data Protection Officer at: datacontroller@pfpleisure.org

For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at: 

Information Commissioner's Office

Wycliffe House 

Water Lane 

Wilmslow

Cheshire SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

Alternatively, visit ico.org.uk or email casework@ico.org.uk.