Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual. The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.
Who are we?
This Privacy Notice is provided to you by G.R.A.B which is the data controller for your data.
G.R.A.B will process some or all of the following personal data where necessary to perform its tasks:
· Names, contact details such as telephone numbers, addresses, and email addresses, facebook profile;
In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations.
G.R.A.B will comply with data protection law. This says that the personal data we hold about you must be:
· Used lawfully, fairly and in a transparent way.
· Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
· Relevant to the purposes we have told you about and limited only to those purposes.
· Accurate and kept up to date.
· Kept only as long as necessary for the purposes we have told you about.
· Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
We use your personal data for some or all of the following purposes:
· To deliver our services to you including to understand your needs to provide the services that you request and to understand what we can do for you and to inform you of other relevant services;
· To confirm your identity to provide some services;
· To contact you by post, email or telephone
· To enable us to meet our insurance and legal obligations.
· To promote the interests of G.R.A.B;
· To maintain our own accounts and records;
· To seek your views, opinions or comments;
· To notify you of changes to our facilities, services, events and staff,
· To send you communications which you have requested and that may be of interest to you. These may include information about new events, offers and other new projects or initiatives;
· To allow the statistical analysis of data so we can plan the provision of services.
What is the legal basis for processing your personal data?
Your personal data is processed for the provision and performance of our contract with you, or to take steps to enter into a contract.
Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use.
We will always take into account your interest and rights. This Privacy Notice sets out your rights and our obligations to you.
Sharing your personal data
We at G.R.A.B never share your personal data
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support HMRC audits or provide tax information. We may retain data in order to defend or pursue claims. In some cases the law imposes a time limit for such claims (for example 3 years for personal injury claims or 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
1) The right to access personal data we hold on you
· At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within one month.
· There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee.
2) The right to correct and update the personal data we hold on you
· If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
3) The right to have your personal data erased
· If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.
When we receive your request we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it to comply with a legal or insurance obligation).
4) The right to object to processing of your personal data or to restrict it to certain purposes only
· You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.
5) The right to data portability
· You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
6) The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
You can withdraw your consent easily by telephone, or email
7) The right to lodge a complaint with the Information Commissioner’s Office.
· You can contact the Information Commissioners Office on 0303 123 1113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
ALL requests must be made in writing and marked “for the attention of Annie Edmunds GDPR Officer” or via email to G.firstname.lastname@example.org
If you request to have all your data erased or object to processing you will no longer be able to participate in fitness classes.
Transfer of Data Abroad
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website and facebook page is also accessible from overseas so on occasion some personal data (for example your photograph) may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Use of pictures
We obtain subjects verbal consent at time of taking, for use of images in maarketing and promotion, including use on our website and facebook instagram and twitter feeds.
All pictures remain the property of G.r.a.b, however subjects rights are not effect.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on our website This Notice was last updated in May 2018.
Please contact us if you have any questions about this Privacy Notice or the personal data we hold about you or to exercise all relevant rights, queries or complaints to:
Annie Edmunds GDPR officer G.R.A.B