Hope Fitness Privacy Policy

Key details

  • Policy prepared by: Angela Hope

  • Next review date: 25th May 2020

Introduction

In order to operate, Hope Fitness needs to gather, store and use certain forms of information about individuals.

These can include members, suppliers and business contacts and other people the group has a relationship with or regularly needs to contact.

This policy explains how this data should be collected, stored and used in order to meet Hope Fitness data protection standards and comply with the General Data Protection Regulations (GDPR).

Why is this policy important?

This policy ensures that Hope Fitness:

  • Protects the rights of our members

  • Complies with data protection law and follows good practice

  • Protects members from the risks of a data breach
     

Who and what does this policy apply to?

This applies to all those handling data on behalf of Hope Fitness e.g.:

  • Members

  • Contractors/3rd-party suppliers

It applies to all data that Hope Fitness holds relating to individuals, including:

  • Names

  • Email addresses

  • Postal addresses

  • Phone numbers

  • Any other personal information held (e.g. financial)

Roles and responsibilities

Hope Fitness is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Hope Fitness is Angela Hope. They are responsible for the secure, fair and transparent collection and use of data by Hope Fitness. Any questions relating to the collection or use of data should be directed to the Data Protection Officer.

Everyone who has access to data as part of Hope Fitness has a responsibility to ensure that they adhere to this policy.

Hope Fitness uses third party Data Processors (see 'Third Party Data Processors') to process data on its behalf. Hope Fitness will ensure all Data Processors are compliant with GDPR.

a. We fairly and lawfully process personal data in a transparent way

Hope Fitness will only collect data where lawful and where it is necessary for the legitimate purposes of the group.

  • A member’s name and contact details will be collected when they first join the group, and will be used to contact the member regarding group membership administration and activities. Other data may also subsequently be collected in relation to their membership, including their payment history. Where possible Hope Fitness will anonymise this data

    Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Hope Fitness completing tasks expected as part of the individual’s membership).

  • An individual’s name and contact details will be collected when they make a booking for an event. This will be used to contact them about their booking and to allow them entry to the event.

    Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Hope Fitness completing tasks expected as part of the booking),

  • An individual’s name, contact details and other details may be collected at any time (including when booking tickets or at an event), with their consent, in order for Hope Fitness to communicate with them about and promote group activities. See ‘How we get consent’ below.

    Lawful basis for processing this data: Consent (see ‘How we get consent’)

  • Pseudonymous or anonymous data (including behavioural, technological and geographical/regional) on an individual may be collected via tracking ‘cookies’ when they access our website or interact with our emails, in order for us to monitor and improve our effectiveness on these channels. See ‘Cookies on the Hope Fitness website’ below.

    Lawful basis for processing this data: Consent (see ‘How we get consent’)

    b. We only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes.

  • When collecting data, Hope Fitness will always provide a clear and specific privacy statement explaining to the subject why the data is required and what it will be used for.

c. We ensure any data collected is relevant and not excessive

Hope Fitness will not collect or store more data than the minimum information required for its intended purpose.

e.g. we need to collect telephone numbers from members in order to be able to contact them about group administration, but data on their marital status or sexuality will not be collected, since it is unnecessary and excessive for the purposes of group administration.

d. We ensure data is accurate and up-to-date

    Hope Fitness will ask members to check and update their data on an annual basis. Any individual will be able to update their data at any point by contacting the Data Protection Officer.

    e. We ensure data is not kept longer than necessary

    Hope Fitness will keep records for no longer than is necessary in order to meet the intended use for which it was gathered (unless there is a legal requirement to keep records).

    The storage and intended use of data will be reviewed in line with Hope Fitness' data retention policy. When the intended use is no longer applicable (e.g. contact details for a member who has left the group), the data will be deleted within a reasonable period.

    f. We keep personal data secure

    Hope Fitness will ensure that data held by us is kept secure.

    • Electronically-held data will be held within a password-protected and secure environment

    • Passwords for electronic data files will be re-set on a regular basis

    • Physically-held data (e.g. PARQ forms) will be immediately transferred to TeamUp (see 'Third Party Data Processors') and destroyed once the member has signed the online waiver

    When Hope Fitness collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Hope Fitness will ensure its data processes comply with those rights and will make all reasonable efforts to fulfil requests from an individual in relation to those rights.

    Individual’s rights

    • Right to be informed: whenever Hope Fitness collects data it will provide a clear and specific privacy statement explaining why it is being collected and how it will be used.

    • Right of access: individuals can request to see the data Hope Fitness holds on them and confirmation of how it is being used. Requests should be made in writing to the Data Protection Officer and will be complied with free of charge and within one month. Where requests are complex or numerous this may be extended to two months

    • Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. Hope Fitness will update their data on an annual basis. Any requests for data to be updated will be processed within one month.

    • Right to object: individuals can object to their data being used for a particular purpose. Hope Fitness will always provide a way for an individual to withdraw consent in all marketing communications. Where we receive a request to stop using data we will comply unless we have a lawful reason to use the data for legitimate interests or contractual obligation.

    • Right to erasure: individuals can request for all data held on them to be deleted. Hope Fitness' data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected. If a request for deletion is made we will comply with the request unless:

      • There is a lawful reason to keep and use the data for legitimate interests or contractual obligation.

      • There is a legal requirement to keep the data.

    • Right to restrict processing: individuals can request that their personal data be ‘restricted’ – that is, retained and stored but not processed further (e.g. if they have contested the accuracy of any of their data, Hope Fitness will restrict the data while it is verified).

    Hope Fitness will regularly collect data from consenting supporters for marketing purposes. This includes contacting them to promote performances, updating them about group news and other group activities.

    Any time data is collected for this purpose, we will provide:

    • A method for users to show their positive and active consent to receive these communications

    • A clear and specific explanation of what the data will be used for

    Data collected will only ever be used in the way described and consented to (e.g. we will not use email data in order to market 3rd-party products unless this has been explicitly consented to).

    Every marketing communication will contain a method through which a recipient can withdraw their consent. Opt-out requests such as this will be processed within 14 days.

    A cookie is a small text file that is downloaded onto ‘terminal equipment’ (e.g. a computer or smartphone) when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions.

    Hope Fitness uses cookies on our website hopefitness.co.uk in order to monitor and record their activity. This allows us to improve users’ experience of our website by, for example, allowing for a ‘logged in’ state, and by giving us useful insight into how users as a whole are engaging with the website.

    We will implement a pop-up box on hopefitness.co.uk that will activate each new time a user visits the website. This will allow them to click to consent (or not) to continuing with cookies enabled, or to ignore the message and continue browsing (i.e. give their implied consent).

    It will also include a link to our Privacy Policy which outlines which specific cookies are used and how cookies can be disabled in the most common browsers.

    Data retention policy

    Introduction

    This policy sets out how Hope Fitness will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.

    It forms part of Hope Fitness Data Protection Policy.

    Roles and responsibilities

    Hope Fitness is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Hope Fitness is Angela Hope. They are responsible for the secure and fair retention and use of data by Hope Fitness. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.

    A regular review of all data will take place to establish if Hope Fitness still has good reason to keep and use the data held at the time of the review.

    As a general rule a data review will be held every 2 years and no more than 27 calendar months after the last review. The first review will take place on 25th May 2020

    Data to be reviewed

    • Hope Fitness stores data on digital documents (e.g. spreadsheets) stored on personal devices held by Angela Hope.

    • Data stored on third party online services (see 'Third Party Processors')

    • Physical data stored at the home of Angela Hope

    Who the review will be conducted by

    The review will be conducted by the Data Protection Officer.

    How data will be deleted

    • Physical data will be destroyed safely and securely, including shredding.

    • All reasonable and practical efforts will be made to remove data stored digitally.

      • Priority will be given to any instances where data is stored in active lists (e.g. where it could be used) and to sensitive data.

      • Where deleting the data would mean deleting other data that we have a valid lawful reason to keep (e.g. on old emails) then the data may be retained safely and securely but not used.

    Statutory Requirements

    Data stored by Hope Fitness may be retained based on statutory requirements for storing data other than data protection regulations. This might include but is not limited to:

    • Details of payments made and received (e.g. in bank statements and accounting records)

    • Contracts and agreements with suppliers/customers

    • Insurance details

    • Tax records

    Member data

    • When a member leaves Hope Fitness and all administrative tasks relating to their membership have been completed any potentially sensitive data held on them will be deleted – this might include bank details or medical data

    • Unless consent has been given data will be removed from all email mailing lists

    • All other data will be stored safely and securely and reviewed as part of the next two year review

    Mailing list data

    • If an individual opts out of a mailing list their data will be removed as soon as is practically possible.

    • All other data will be stored safely and securely and reviewed as part of the next two year review

    Other data

    • All other data will be included in a regular two year review.

    Third Party Processors

    We use the following third party processors to process your data and payments:

    TeamUp – to manage customer data and payments Privacy Policy

    MailChimp – to manage email marketing Privacy Policy

    SquareSpace – website provider Privacy Policy

    GoogleDrive – to store documents (invoices, accounts) Privacy Policy

    G Suite – to manage and store email Privacy Policy

    Go Cardless – to process direct debit payments Privacy Policy

    Stripe – to process debit or credit card payments Privacy Policy

    PayPal – to process other payments Privacy Policy

    Other websites

    Our website contains links to other websites. This privacy policy only applies to the Hope Fitness domain so when you link to other websites you should read their own privacy policies.

    How to contact us

    Please contact is if you have any questions about our privacy policy or information we hold about you: