Privacy Policy

Privacy notice for Actif Sport and Leisure

The proper handling of personal information by Carmarthenshire County Council is very important to the delivery of our services and maintaining public confidence.

Personal data is any information that relates to a person who can be directly or indirectly identified from the information. The terms ‘information’ and ‘personal data’ are used throughout this privacy notice and have the same meaning.

To ensure that the Council treats personal information correctly, we seek to adhere in full to the requirements of Data Protection legislation.

This privacy notice has therefore been produced to explain as clearly as possible what we do with your personal data.

 1. The purposes for which we use your personal data

The information we collect about you will be used for the following purposes:

• To provide you with sports & leisure activities and facilities.
• To validate your membership eligibility and manage your account, including processing online bookings and other transactions made via our website.
• To improve members’ health by participating in the National Exercise Referral Scheme (NERS).
• To improve members’ health by participating in the Proactive Falls Prevention Programme via Gladstone Impact.

The legal basis for processing your personal data is to exercise authority to provide leisure facilities and services, a discretionary power under the Local Government Act.

We collect and use special category (sensitive) personal data about members’ health for reasons of substantial public interest in relation to the NERS and Falls Prevention on the basis of the legislation referred to above.

Your information is also used for the following purposes, where you want us to do this:

• To let you know about important changes, special offers, promotions and other products and services that we offer which may be of interest to you by post or email
• To contact you regarding your views on our services to enable us to improve and develop better products & services

We get in touch with you in this way based on your consent and you can change your mind at any time by emailing actif@carmarthenshire.gov.uk

2. What type of information do we use?

We collect the following types of personal data about our members to deliver this service:

Actif Sport & Leisure members:

• Name
• Address
• Telephone number
• Email address
• Unique Member ID and pin number
• Date of birth
• Gender
• Bank/payment details to process payments
• Employment and education details, for specific membership options
• Information about your fitness goals
• Your photograph

We also ask you to show proof of entitlement for concessionary memberships such as Free Swimming, Corporate, Student, 60+, Household, Leisure Saver and Veterans’ memberships, but we do not keep a copy of this information. We do keep a record as to why you are entitled to a concessionary membership.

NERS & Falls referral scheme members:

• Name
• Address
• Telephone number
• Email address
• Unique Member ID and pin number
• Date of birth
• Gender
• Your photograph
• Information about your health to recommend exercise regimes

As well as the above, we also information about children who take part in the Learn to Swim Scheme, Actif club and community schools programmes. We use the following personal data:

• Child’s name
• Address
• Name and contact details for a responsible adult
• Unique member ID and pin number
• Date of birth
• Gender
• Whether the child has a disability which we need to keep them safe

3. Do we use information received from other sources?

We collect information directly from you but also receive information from the following sources in relation to customers referred to us via the National Exercise Referral Scheme & Falls Prevention Programme:

• General Practitioners
• Other health professionals

The following types of personal data are obtained:

• Name
• Address
• Emergency contact name and phone
• Date of Birth
• NHS number
• GP and practice address
• Allergies
• Medications
• Information about your health that we need to provide an exercise programme

4. Transferring your information abroad

Your information will not be transferred outside the United Kingdom.

5. Who has access to your information?

Your personal data is an important part of our service.  For instance, it lets us provide our services to you, including managing your membership and bookings.

We share your information only when there is a need for us to do so and when we do, we provide the minimum that is necessary in each case:

• Swim Wales/Aqua Passport have access to names, unique reference numbers and postcodes, if your child is in the Learn to Swim Scheme.

We also use private companies to process personal data.  We have binding agreements in place with them and they only process your information according to our strict instructions:

• Gladstone provides our database and has access to the data on it when they carry out maintenance on the system.
• Upshot analyses attendance of community and school activities has access to names, unique reference numbers and postcodes.
• Fitronics LTD (The Retention People) provide us with software which we use to get in touch with you about your use of our services and to carry out satisfaction surveys. We use this feedback to seek to continuously improve our services. The software hosts limited information about you comprised of your name, contact details, photograph and the type of membership you have.
• Brief Your Market provide us with software which we use to get in touch with you to send you personalised mailings, promotions and services tailored to your individual interests. The software has access to your name, contact details and the type of membership you have.

There are also other specific situations where we may be required to disclose information about you, such as:

• Where the Council is required to provide the information by law
• Where disclosing the information is required to prevent or detect a crime

Where disclosure is in the vital interests of the person concerned

6. How long we will keep your information

We will keep your information for as long as you remain a member. If you cancel your membership, your personal data will be deleted from our computer systems after 25 months.  Your data is kept as part of a research project.

Copies of paper membership forms are kept for 3 months.

7. Your Data Protection rights

You have the right to:

• Obtain access to the personal data that Carmarthenshire Council is processing about you
• Have any inaccurate or incomplete information rectified (corrected)
• Withdraw your consent to processing, where this is the only basis for the processing
• Make a complaint to the Information Commissioner’s Office (ICO), the independent body in the UK which protects information rights

In some circumstances, you may have the right to:

• Object to the processing of your personal information
• The erasure of your personal data
• Restrict the processing of your personal information
• Data portability

8. Contact details

For more information regarding this privacy notice and your rights, please contact:

Data Protection Officer

Carmarthenshire County Council

County Hall

Carmarthen

SA31 1JP

Email: dataprotection@carmarthenshire.gov.uk

Tel: 01267 224127

Contact details for the Information Commissioner’s Office along with further guidance on Data Protection legislation can be found on the ICO website:

www.ico.org.uk