Effective 1st September 2023 V.2
Doncaster Culture & Leisure Trust is committed to respecting and protecting your privacy. This policy explains when and why we collect personal information about people who visit our website and access our facilities, how we use that data, the conditions under which we may disclose it to others and how we keep it secure. It explains how you can control your information.
Our website is not intended for children, and we do not knowingly collect data relating to children.
Doncaster Culture & Leisure Trust is a controller and responsible for your personal data. All references to “we”, “us” and “our” refer to Doncaster Culture & Leisure Trust (DCLT) or the wholly owned trading subsidiary Doncaster Conferences, Catering & Events (DCCE).
References to “our website(s)” or “the website(s)” are to our main website, or any number of brand or venue subsites as noted below:
Doncaster Culture & Leisure Trust is a registered Charity, and our registration number is: 1103465
Doncaster Culture & Leisure Trust
Contact number: 01302 370777
Doncaster Culture & Leisure trust provide leisure and hospitality services across the City of Doncaster.
INFORMATION WE COLLECT
The UK GDPR applies to the processing of personal data that is:
- wholly or partly by automated means; or
- the processing other than by automated means of personal data which forms part of, or is intended to form part of, a filing system.
Personal data only includes information relating to natural persons who:
- can be identified or who are identifiable, directly from the information in question; or
- who can be indirectly identified from that information in combination with other information.
We gather, use, store and transfer your personal data to provide services to you. This data can include your name, contact details, address details, financial and other information we gather as part of our relationship with you. It can also include some ‘special categories’ of data, such as your ethnic origin and health. The collection and use of all the data we collect about you is subject to strict controls and is limited to a specific purpose(s).
We collect data in the form of cookies, from our website and social media activity. This allows us to analyse the activity of our customers and offer a better service.
We are committed to protecting all of your personal data, whether it falls into ‘special categories’ or not, and we only process data if we need to for a specific purpose, as explained below. We collect your personal data mostly through our contact with you, and the data is usually provided by you, but in some instances, we may receive data about you from other people/organisations. We will explain when this might happen in this policy.
IF YOU FAIL TO PROVIDE PERSONAL DATA
You do not have to provide personal data but where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with membership). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
HOW AND WHEN WE COLLECT INFORMATION FROM YOU
Any personal information we collect will be managed in accordance with the Data Protection Act 2018 and the UK retained version of the General Data Protection Regulation (GDPR). All electronic communications are made in accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Most of the personal information we process is provided to us directly by you for one of the following reasons:
Membership management – data is provided by you and then used to provide the services. It is necessary for this purpose for us to input the data into our CRM systems and to process your direct debit collection. We also request data regarding your ethnic origin and disability status for demographic information, however this is optional, and you can decide not to provide this information.
Bookings – we use multiple bookings systems depending on the activity. Your information will be used to communicate with you regarding details of your upcoming booking and any beneficial information to enhance your visit. Your personal details will be required if an activity waiver needs to be completed.
Customer Enquiries and Feedback – We gather personal information when customers inquire about our products and services or wish to provide feedback. This allows us to respond in a timely manner.
Data management – We may use information provided by our customers to measure the success of our programme and services. When we analyse this data, it will not be shared with a 3rd party unless anonymised.
CCTV/Closed-circuit camera surveillance – We use CCTV within our centres for the safety of our staff and customers.
Grant/Funding applications – We request information for the purpose of the administration of grants, and our compliance with our legal and contractual obligations relating to the administration of the grant. Grant information may also be shared with other relevant partner agencies that prevent and detect fraud. We may share information as part of funding returns; details of this will be provided at the time you apply for the grant. The information is retained for 6 years from date the project to which the grant relates finishes.
We routinely collect data on children in order to undertake the delivery of its services. This may include personal information including name, address, date of birth, school, etc. This information will only be used for the purpose for which it was collected. E.g. swimming lessons, youth membership and gathered from a parent or guardian. Parental or Guardian consent is requested for usage of our youth fitness memberships.
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we need to process personal information about you so we can:
- provide you with services.
- review and improve the services we provide.
- keep track of our spending across services.
- train and manage our employees who deliver those services.
- process payments to and from us.
- meet our statutory obligations.
- investigate and respond to complaints and reports.
To protect your privacy, we put safeguards in place to ensure that:
- we only collect what we need.
- the information we hold about you is accurate.
- your information is only used for the stated purpose.
- your information is only kept for as long as we need it.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
(a) We have a contractual obligation. When you have become a customer, we need to collect and use personal information to provide services to you and to claim our right to be paid in return for our services under our standard terms of business/contract with you.
(b) We have a legal obligation.
(c) We have a legitimate business interest; we will gather personal data when we have a legitimate business interest. This will be clearly explained when we gather the information.
(D) Explicit consent, we openly request information, with clear direct agreement between parties.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW WE STORE YOUR INFORMATION
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation).
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those people processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.
While we will use all reasonable efforts to keep your personal data safe, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet.
In some instances, it may be necessary for us to share data with other 3rd party organisations for administrative purposes. These purposes may include processing and sorting data, monitoring how customers use the Website and issuing our e-mails for us. The categories of recipients with whom we may share your data for these purposes include:
- [other entities in the DCLT group and service providers who provide membership administration services, including debt recovery services and management reporting];
- [service providers who provide IT, system administration and data analytics services];
- [professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services];
- [HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances];
- [potential funders, grant application reviewers and fraud prevention agencies in connection with grant applications].
Third parties will not be allowed to use your personal information for their own purposes.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit them to process your personal data for specified administrative purposes and in accordance with our instructions.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Your right of access –you have the right to ask us for copies of the personal data we hold about you by completing a subject access request. There may be information that cannot be provided for certain circumstances, and this will be communicated to you.
Your right to rectification - you have the right to ask us to rectify information we hold about you which you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure –you have the right to ask us to erase your personal information where there is no good reason for us continuing to process it or where you have successfully exercised your right to object to processing. Applications for the Right to Erasure must be completed and the identity confirmed. We will retain copies of the request for administration purposes. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Please contact us at firstname.lastname@example.org 01302 370777, DCLT, Bawtry Road, Doncaster DN4 7PD if you wish to make a request.
You are not required to pay any charge for exercising your rights unless your request is clearly unfounded, repetitive, or excessive in which case we may charge a reasonable fee. Alternatively, we could refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. Details of retention periods for different aspects of your personal data are available upon request.
HOW TO COMPLAIN
You can also complain to the Information Commissioner’s Office if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Cheshire, SK9 5AF
Helpline number: 0303 123 1113
What are cookies?
Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the website, or another website, to recognise your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term "cookies" in this policy to refer to all files that collect information in this way.
There are many functions cookies serve. For example, they can help us to remember your username and preferences, analyse how well our website is performing, or even allow us to recommend content we believe will be most relevant to you.
Certain cookies contain personal information - for example, if you click to "remember me" when logging in, a cookie will store your username. Most cookies won't collect information that identifies you, and will instead collect more general information such as how users arrive at and use our websites, or a user's general location.
What sort of cookies do we use?
Generally, our cookies perform up to four different functions:
1. Essential cookies
Some cookies are essential for the operation of our website. For example, some cookies allow us to identify members and ensure they can access the members only pages. If a member opts to disable these cookies, the user will not be able to access all of the content that a subscription entitles them to.
2. Performance Cookies
We utilise other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website.
3. Functionality Cookies
We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site when you log in. We also use functionality cookies to provide you with enhanced services such as allowing you to watch a video online.
4. Advertising Cookies
Can a website user block cookies?
As we've explained above, cookies help you to get the most out of our websites. Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly.
Do we track whether users open our emails?
Our emails may contain a single, campaign-unique "web beacon pixel" to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users, to query whether users who do not open our emails wish to continue receiving them. The pixel will be deleted when you delete the email.
If you wish to learn how to disable and control cookies, visit this website.