We, Trowse Total Fitness, are the ‘controllers’ of the information we collect about you (‘personal data’).
Our contact details are set out in section 15 of this policy.
As controllers of your personal data, we are responsible for how your data is processed. The word ‘process’ covers most things that can be done with personal data such as the collection, use, storage, sharing and erasure of that data. We are committed to complying with data protection legislation in our handing of your personal data.
You have certain rights in relation to your personal data including the right to object to the processing of your information in certain circumstances. Further information about your rights is included in section 12 of this policy.
2. PERSONAL DATA
‘Personal data’ is any information that relates to a living, identifiable person. This data can include your name, contact details, and other information we gather as part of our relationship with you.
It can also include ‘special categories’ of data, which is information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation. The collect and use of this type of data is subject to strict controls. Similarly, information about criminal convictions and offences is also limited in the way it can be processed.
We will collect your personal data mostly through our contact with you and the data is usually provided by you but in some instances.
3. WHAT INFORMATION DO WE COLLECT AND WHY?
We are committed to protecting your personal data and will only process the data if we need to for a specific purpose and providing we have a legal basis, as explained below.
There are various legal bases on which we may collect and process your data. We may have your consent, for example, you have informed us that you are happy for us to process your information for a specific purpose such as providing a service to you or receiving further information about what we do. Sometimes there is a contractual reason such as being able to process a monthly direct debit payment and deliver our services to you. If so, we will not be able to enter into a contract with you in the absence of the data. Occasionally there may be a legal reason for collecting or sharing data, such as for employees when we have to collect the information for the HMRC, or, should you have an accident, we may need to provide details of this to the relevant health and safety authorities. We may also process your data based on our legitimate business interests, for example, in order to operate and improve our business.
Personal Data Description Purpose(s) for Processing
Information you type into our websites or provide to one of our colleagues such as when you become a member, create your profile, update your member profile, provide activity data from other devices, make a booking, during one of our services. This information may include your personal contact data, fitness-related data which has been obtained in order to create personalised fitness workouts for you, health related data including current and past medical history as well as any medical conditions with in your family.
Any personal details you give us or we obtain from third parties
We use this data to provide you with the services you request, tell you about services you are eligible for, to keep in contact with you, manage your account and the services we provide. If you contact us by email, via the website, in person or by telephone we may keep a record of your contact information and enquiry and may subsequently use your contact details to respond to your enquiry. We will store and provide on request attendance and associated contact information to the Government’s Test and Trace authorities to assist them in identifying those who may have come into contact with Covid-19 infected individuals. Any personal data used solely for Test and Trace will only be retained for 21 days.
Information which allows us to recognise you.
Such as a unique ID number or user names; storing this data saves you from re-entering your details again when you return to the website.
Details of your transactions
We collect data for any transactions you carry out through our websites and services, so that we can administer the services you have with us. Please note that we never store your payment details on our website.
Sensitive health data.
We collect any personal health data you provide to us when registering and signing up for our health services.
We collect this information to ensure we are offering you the right services and so your progress can be tracked by yourself and us. We may ask you for information about your health in order to recommend appropriate exercise regimes or offer our other services. We may ask for any current or past medical history as well as any medical condition within the family in order to recommend appropriate services and/or referee you to another medical/health professional if needed.
All transactions on owe website/app or in person are conducted using PayPal, Stripe or cash. their policy's can be found below:
We will record customer comments and surveys about how we are performing, some of which may be displayed apron our website/app or social media page
Other Sensitive data
We are sometimes required to collect information about your ethnicity and other sensitive data in order to provide aggregated reports to your local authority or commissioning group. This information is used only for statistical purposes and is always kept secure. If you prefer not to provide us with this data we will not hold this data.
Information about website visits including IP address
We use your IP address to capture information about website visits, so we can learn more about how our customers use the website in order to find ways to improve the website and our products and services for your benefit.
Your communication preferences
We keep a record of any permissions and preferences you give us about what types of communication you are happy to receive from us.
When you visit our website, 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.
Third party standard internet log information collected by Google Analytics and Facebook Pixel
5. DATA RELATING TO CHILDREN
Our services are used by people of all ages. Trowse Total Fitness may accept website registrations and collect personal information from individuals under the age of 16. If you are under 16 we do not allow you to post information about yourself in any Trowse Total Fitness blog, forums or community areas. Trowse Total Fitness accepts no liability if this instruction is ignored.
Children aged under 16 years must have a parent or guardian’s consent before providing personal information to us. We do not wish to collect any personal information without this consent.
Trowse Total Fitness will not knowingly market to children aged under 16 years.
Proof of age maybe required and retained for access to some services.
Parent or Guardian are required to accompany and stay with any individuals under the age of 16 during any service.
6. HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?
These are the basic guidelines we use to look after your personal data.
We maintain secure systems to protect your personal information
We respect your wishes about how we contact you, whether by post, telephone, email or text message
We will update your information or preferences promptly when you ask us to
We will respond fully to requests from you to see the information that we hold on you.
We will not hold your personal information for longer than is necessary for our legitimate business purposes.
We follow strict procedures when storing or handling information that you have given us. Some information is encrypted, such as payment transactions and password.
We will never sell your personal information to a third party.
7. RETENTION POLICY
We retain personal information as long as we consider it useful to contact you, or as needed to comply with our legal obligations. Where data is not needed for legal or statutory purposes we will delete this information if you request. See the contacts section to request your data to be deleted.
8. SHEARING YOUR INFORMATION WITH THIRD PARTIES
It may become necessary for Trowse Total Fitness to share your information with third party organisations such as GP, or other medical/health care professionals. Trowse Total Fitness will only share this information with your consent, unless it is deemed that not sharing this information could result in harm or death to the individual.
Information held for individuals under 16 years of age will not be shared without parental/guardians consent unless it is deemed that the individual under 16 welfare is at risk under the children act 1989.
NSPCC - Telephone: 0808 800 5000
9. MARKETING PARTNERS
Trowse Total Fitness will never sell your personal information to any third party for marketing or other purposes.
10. HOW DO WE USE YOUR INFORMATION?
We use your information to help us provide and improve our services for you. We may use your information in the following ways.
to provide you with any services that you have purchased or receive free as part of a health or other scheme
to check your identity
to check your eligibility where appropriate
to update our records with any new information you give us
to notify you if we will be unable to provide a service you have booked before
to provide marketing communications (if you have given us your permission)
for research and analysis so we can develop and improve our services for your benefit
to tailor our communications to you to ensure relevance (if you do not want us to do this please contact us using the details below)
to comply with legal requirements.
To safeguard users of our services
11. KEEPING YOU UPDATED
There are certain communications we need to send to you so we can provide our services. We call these service communications and include for example notices about your direct debit payments, change of password, registration confirmations, appointment reminders and waiting list announcements. We would not be able to provide you with services if we did not send these.
We may from time to time contact you about our services or products we think you might find interesting by email, by post, telephone or SMS, but only if you have given us your permission to do so.
If you buy a service from us for a fixed period of time with a specific end date, such as an annual membership, we will contact you at the appropriate time to tell you that the service is coming to an end and how you can renew.
If you do not want us to contact you other than for service emails let us know when you next visit us or contact us.
12. YOUR RIGHTS TO MANAGE YOUR PERSONAL DATA
Accuracy of data
We will always try to ensure the data we hold about you is accurate and relevant. If you believe the information we hold about you is out of date or incorrect, please tell a member of staff or see the contacting us section below. You will need a form of identification to request any changes.
Seeing your data – subject access request
You have the right to know what personal information we hold about you. This is called a Subject Access Request.
Removing your data
If you no longer use our services and products and wish us to delete your personal data we will do this if there are no legal or statutory regulations requiring us to keep this information.
You can restrict the processing of your data including some processing we do under legitimate business interests.
Transferring your data
In some circumstances you can ask us to transfer your information to another organisation.
Objection to processing
You can object to the processing of your data in certain circumstances such as marketing.
If we are relying on consent to process your data, you may withdraw your consent at any time by contacting us.
To exercise any of the above rights please contact us using the details set out in section 15.
Complaints about how we manage your data
If you are not happy about the way we manage your data please contact us as quickly as possible. You may also write to the Data Controller – who will investigate your complaint and get back to you as soon as possible.
Information Commissioner’s Office (ICO) - The ICO is the UK’s independent authority set up to uphold information rights. You have the right to contact them should you wish. Details can be found on their website: https://ico.org.uk/
13. LINKS TO OTHER WEBSITES
Our websites may contain links to and from external websites, advertisers and affiliates. If you follow a link to other sites please note that these will be governed by their own privacy policies. We cannot accept liability for data use on those websites.
15. CONTACTING US
In the event you need to contact us you can do so using the following information:
CHILD SAFEGUARD POLICY
As a provider of children’s activities Trowse Total Fitness has a duty of care to safeguard and promote the welfare of children and young people. This policy and the procedures have been developed to comply with that duty and the relevant legislation and guidance, namely:
The Children Acts 1989 and 2004
The Sexual Offences Act 2003
The Human Rights Act 1998
Data Protection Act 1998
Sport England/Child Protection in Sport Unit Standards (2005)
High Quality Community Sport for Young People (Sports Unlimited, 2010)
Trowse Total Fitness upholds the principle that the child’s welfare is paramount and that all children whatever their age, culture, disability, gender, language, racial origin, religious belief and sexual identity have the right to protection from abuse.
The word ‘child’ or ‘children and young people’ is used to refer to anyone under the age of 18, as defined by the Children Act 1989.
Everyone in Trowse Total Fitness has a duty to raise concerns about behaviour of colleagues, volunteers, managers and others, which may be harmful to those in their care, without prejudice to their own position.
The safeguarding policy and procedure applies to all those working for Trowse Total Fitness, whether paid or unpaid. Both are referred to as colleagues throughout the policy and procedures.
Children and young people have contact with Trowse Total Fitness. For example, they attend our classes or other services. Whenever children and young people come into contact with us we want them to be safe and to enjoy their time with us. To this end we are committed to working in a child-centred way where the children we work with are valued and respected as individuals, and their views and concerns are listened to.
Trowse Total Fitness’s child protection procedures are intended to:
Offer safeguards to the children with whom we work, and to our colleagues and volunteers.
Help to maintain professionalism and high standards of practice; and Reassure and give confidence to our clients and customers.
To meet our safeguarding responsibilities Trowse Total Fitness will:
Appoint designated safeguarding officers whose specific remit will support the implementation of this policy.
Recruit Trowse Total Fitness colleagues safely, ensuring all necessary steps are taken and checks are made, in line with our recruitment and vetting procedures as outlined in our recruitment and selection policy which can be accessed through TEAMS.
Provide a code of conduct for staff and volunteers to promote best practice.
Train and supervise all staff to adopt best practice to safeguard and protect children against abuse, and themselves against allegations being made against them.
Take all suspicions and/or allegations of abuse or risk to children seriously, and responding to these swiftly and appropriately through our child protection procedures.
Share information about concerns with those relevant agencies that have a legal duty to act, involving parents/carers and children where appropriate.
Provide support to Trowse Total Fitness colleagues via the Counselling Service if necessary following their involvement in a safeguarding matter.
Store children contact information and correspondence securely
Other Trowse Total Fitness policies and procedures have aspects which relate to safeguarding and promoting the welfare of children and therefore these should be read in conjunction
with this document:
Recruitment and Selection Policy and Procedures
Disciplinary and Grievance Policy and Procedures
Nursery Policies (where applicable)
Data Protection Manual
Children’s Activities Manual