Places for People Leisure Management Ltd Privacy Notice
Places for People Leisure Management Ltd, also known as Places Leisure, together with their subsidiary companies are committed to protecting your privacy when you use our 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 firstname.lastname@example.org
Who Are We?
This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by Places for People Leisure Management Ltd.
Our principal address is 305 Grays Inn Rd, London WC1X 8QR but you can search for your local centre here: www.placesleisure.org/find-centre
Places for People Leisure Management Ltd 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 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.
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.
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:
- Via our Customer Service team, details of which you can find on your contract with us.
- 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. Alternatively you can email email@example.com
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):
Data of birth
Employment Status (only if applying for concessionary memberships)
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
Physical or mental health
Trade union membership
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 contract with us. 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?
We may need to use some information about you to:
- deliver services and support to you;
- to carry out our obligations arising from any contracts entered into between you and us;
- manage those services we provide to you;
- service improvement
- prevention/detection of crime/fraud
- help investigate any complaints you have about our services;
- check the quality of our services;
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.
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
- 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 for People Leisure Management Ltd we believe in putting our customers in the driving seat when communicating. When we communicate with you we will do so either because it forms part of your contract with us, we have your consent or where we have a legitimate interest to communicate with you.
We have outlined our primary communication activities below which tells you how we may communicate with you and how you can update your preferences
Customer service communications
We may contact you or send communications to tell you about a service enhancement such as improvements to your local site or to keep you informed of your current membership status. We won’t need your consent to communicate with you this way because we have assessed that it forms part of our agreement with you. We will contact you through email and SMS for these service communications.
Customer communications may also include customer surveys as we feel understanding your experiences to help us improve the service we provide you forms an integral part of our relationship. We do not ask for your consent to contact you for these surveys as we have assessed that it is in our legitimate interest to contact you in this case. You can tell us to stop at any time – all our customer surveys will always 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
Prospective customer communications
We would like to send you occasional messages and to keep you informed about products or service information when you make an enquiry with us. We will keep your contact information for six months after which time we will delete your data from our systems if you have not become a member or have not been communicating back 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 firstname.lastname@example.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 that it is in our legitimate interest to keep you informed for a limited period. You can tell us to stop at any time – all our communications will always contain an easy opt-out link.We will also contact you where we believe you may require support for abandoned online purchases.
Past customer communications
If you are a past member and have not opted out to marketing we would love to stay in touch. 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.
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 email@example.com inbox confirming your opt-in or just speak to a member of our team at your local Places Centre.
We do not ask for your consent to contact you for these product or service messages as we have assessed that it is in our legitimate interest to keep you informed. You can tell us to stop at any time – all our communications will always contain an easy opt-out link.
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 firstname.lastname@example.org, requesting to opt-out.
Consent and your preferences centre
To support our ongoing relationship, we would like to send you information on other products and services we offer, and which we think will be of interest to you. We will rely on consent for the majority of our direct marketing. We will ask for your consent to communicate this type of information to you. You can remove your consent and ask us to stop at any time. At Places Leisure we have updated our online customer preference centre to enable customers to update their marketing consents. This provides easy access for you to update your consents to marketing and you can update your preferences at any time by logging on to your online account here:
If you do not want to sign up for an online account but you want to update your preferences or remove your consent, please contact email@example.com and we can process your request. Alternatively, you can speak to the reception team at your local Places Leisure Centre.
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.
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, we will always ask for your consent to do this and you can ask us to stop at any time.
We will always provide an option for updating your marketing preferences on our communications with you.
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 by us.
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.
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
This applies to personal information that is in both paper and electronic records. If you ask us, we’ll also let others see your record (except if one of the points above applies).
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
If we have doubts about your identity or we are finding it difficult to locate your personal information we may ask you to provide us with proof of identity.
What types of documents could I submit as 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:
Data Protection Officer c/o Data Control Team
Places for People Leisure Management Limited
The Gurney Office
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 firstname.lastname@example.org and we can deal with your request. Alternatively, you can speak to the reception team at your local Places Leisure 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 us to use it)
- Where there is no legal reason for the use of your information
- Where deleting the information is a legal requirement
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
We will assess whether you have a right to a restriction and where restriction of use has been granted, we’ll inform you before we carry on using your personal information.
Where possible we’ll seek to comply with your request, but we may need to hold or use information because we are required to by law or we have a legal basis to do so, such as a contract.
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.
It’s likely that data portability won’t apply to most of the services you receive from Places for People Leisure Limited.
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 email@example.com who will be able to advise you about how we are using your information.
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 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.
Places Leisure and it’s subsidiaries provide 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.
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 firstname.lastname@example.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.
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
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 we can deliver 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 we provide 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 our contractual obligations with you. 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?
We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements there is always an agreement in place to make sure that the organisation complies with data protection law.
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
We will share your personal information with local authorities usually for the purposes of providing services processed by that local authority e.g. Places for People Leisure Limited acts as a Leisure Management Contractor on behalf of many Local Authorities.
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 to us.
- 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.
- 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.
- 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.
Although this is not an exhaustive list the following third parties process data on Places for People Leisure Limited’s behalf which may include your personal data for the specific purposes identified. Places for People Leisure Limited has appropriate contracts in place to ensure third party data processors comply with necessary regulations:
Harlands Services Limited – Member payment services
Salesforce.com EMEA Limited – Marketing services
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 with Places Leisure 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 email@example.com
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.
Better Health Rewards private policy (Better Health Rewards members, relating to Wolverhampton Swimming & Fitness Centre only) -
The following information will be reported back to HeadsUp Labs, (the developers of company that administers the Better health:Rewards app)
- The code you entered
- The time and date which you activated this pass
- Your assigned membership number
Upon completion of the scheme, we may combine your data with others that have taken part in this project to determine its success. This may include the information you have given us about yourself, how many day passes you used, which activities you took part in and if/your interactions with the centre, following on form your 1-day pass usage.
Please note you will not be able to be identified individually in this report. We may share this report with partners including but not limited to Wolverhampton council, the Office for Health Improvement and Disparities, HeadsUp Labs and other partners we work with. We may also publicise this on our media channels
If you have any questions about please feel free to contact us on firstname.lastname@example.org
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.
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)
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.
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. We will keep your information for the duration of providing a service or product to you under the terms of a contract, such as your membership 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
How to tell us of a data breach
Places for People Leisure Management Ltd and Places for People Group takes 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.
Where can I get advice?
If you have any worries or questions about how your personal information is handled please contact our Data Protection Officer at: email@example.com
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
Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.