Privacy Policy

Aberdeen Sports Village Privacy Notice

Who we are

Aberdeen Sports Village (ASV) is the data controller (responsible for the processing of personal data) and is registered with the Information Commissioner’s Office. We have an appointed Data Protection Officer (DPO), who can be contacted by emailing dpo@aberdeensportsvillage.com.

Aberdeen Sports Village (ASV) is committed to complying with the Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR) and other legislation associated with protecting personal data. This Privacy Policy informs customers and users about the collection, use and sharing of personal information we collect on our website aberdeensportsvillage.com, our app, within the facility and through various services that we offer.

Type of information we collect and how

We collect personal data from both members and non-members and is usually restricted to just your name, address, date of birth, email address and telephone number. We collect personal data from you when you book a place with us and attend a class, seminar, event, training course, etc., we need to collect your personal information so that we can honour your booking and to enable you to participate in your chosen service.

Sensitive health data

We collect any personal health data you provide to us when registering and signing up for our 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 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.

Data relating to children

Our services are used by people of all ages. ASV may accept website registrations and collect personal information from individuals under the age of 13. Children aged under 13 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.

Banking data

We will store your bank account number and sort code data where you have a Direct Debit (DD) mandate in place. When the DD mandate finishes, we will update our operational systems to ensure that no further DD’s are collected from your account as per our T&C’s. We process bank card information at the time we take payment. This data is not stored on our systems and is processed on Payment Card Industry Data Security Standard compliant banking systems.

Our lawful basis for processing your personal data

Contract

We need to collect our members’ personal information so that we can manage your membership. We will use your information to:

• provide you with core member services.
• set up your membership account and
• send you membership communications by post or email in relation to essential membership services, including but not limited to membership renewals, membership fees and information on membership benefits.

If you do not provide us with all the personal information that we need to collect, then this may affect our ability to book your place or offer the above membership services and benefits.

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. We may do this by tracking age groups, gender, post code locations, type of service purchased (e.g. Personal Training or class bookings). We can track how our customers accessed the website – through social media, another website, advertisements, email link or direct communication link. Please note that we never store your payment details on our website.

Legal Obligation

We are under a legal obligation to process certain personal information relating to our members, for the purposes of complying with our obligations under:

• The Charities and Trustee Investment (Scotland) Act 2005 to maintain a register of our members, which includes our members’ name, address, the date they were admitted to membership and the date on which they ceased to be our member.
• The Equality Act 2010, which requires us to process personal information to make reasonable adjustments where necessary.

Consent

We may ask you if we can process your personal information for additional purposes. For example, we may ask permission to use your personal information as a case study or testimonial. Where we do so, we will provide you with a consent form with information on how we will use your data for these additional purposes and how such consent can be withdrawn.

Legitimate Interest

We also process our members’ personal information in pursuit of our legitimate interests to:

• Promote and encourage participation in sport and exercise by sending members’ communications and booking information for upcoming competitions and events. Our competitions and events may be filmed or photographed, and your personal information may also be used in images captured from our competitions and events, which we use for promotional, education and development purposes.
• Monitor and develop participation in ASV’s services by monitoring members’ engagement and participation through, but not limited to sport, group exercise, swimming and gym visits. On occasions, we may invite our members to participate in surveys for researching and development purposes.
• Respond to and communicate with members regarding customer questions, comments, support needs or complaints, concerns or allegations in relation to activities undertaken at ASV. For example, we will use your personal information to investigate your complaint, to suspend membership, take disciplinary action, etc.
• We will also store your data in the form of a unique ID number; storing this data saves you from re-entering your details again when you return to the website. ASV can recognise you by your photograph as well, which also allows us to ensure that your card is not misused if lost or stolen and helps us identify you to ensure we support you on your activity journey.
• ASV health and fitness services - as a member or non-member, you may choose to participate in various health and fitness schemes that ASV operates, such as training programme reviews, general inductions, personal training, health and fitness assessments or through ASV’s fitness tracking system. If you decide to leave any of these schemes you have the right to request that we erase your data from those systems.
• We may also process your data based on our legitimate business interests for example in order to operate and improve our business.

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit as a member.

Who we share your personal information with

We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include the Health & Safety Executive, Disclosure Scotland, and Police Scotland for the purposes of safeguarding children and vulnerable adults.

We may also share personal information with our professional and legal advisers for the purposes of taking advice.

Aberdeen Sports Village employs third party suppliers to provide services, including IT, cascading member communication, member management system, member/booking analysis. These suppliers may process personal information on our behalf as “processors” and are subject to written contractual conditions to only process that personal information under our instructions and protect it.

In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

How long we keep your personal information

We will only keep your personal information for as long as necessary to provide you with membership services. Unless you ask us not to, we will review and possibly delete your personal information where you have not renewed your membership with us for 4 years.

We will keep certain personal information of members for longer in order to confirm your identity, when you were a member of ASV and for how long. We may need to do this in the event of a claim against ASV.

How we store and protect your personal information

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and organisational procedures to safeguard and secure the information we collect.

Your personal information is stored on our electronic filing system and our servers based in the UK is accessed by our staff for the purposes set out above.

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.

Links to other websites

Our website may contain links to and from external websites, advertisers and affiliates. If you follow a link to another site, please note that these will be governed by their own privacy policies. We cannot accept liability for data use on those websites.

Your rights

You have legal rights about the way we manage and use your personal data:

• The right to be informed.
• The right of access (subject access)
• The right to rectification
• The right to erasure
• The right to restriction
• The right to object
• The right to data portability
• Rights in relation to automated decision making and profiling.

Some of these rights only apply in certain circumstances, depending upon the lawful basis for processing. Full information about your rights can be found on our guide to your rights section below the 'Contact Us' notice.

Complaints about how we manage your data

If you are not happy about how we manage your data, please contact us as quickly as possible by contacting your centre or usual contacts for providing our service. You may also contact the Data Protection Officer – who will investigate your complaint and get back to you as soon as possible.

Any requests received by ASV will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner’s Office Website: ico.org.uk/global/contact-us
Helpline: 0303 123 1113

Changes to this privacy policy

This policy may be updated from time to time on this page. If you have any questions or comments about our Privacy Policy or how we use your personal information, please contact us at dpo@aberdeensportsvillage.com.

Contacting us

In most instances it is best to contact us in person at ASV. We can usually deal with most of your queries here.

You can also contact us on our website at www.aberdeensportsvillage.com/contact or telephone 01224 438900

Alternatively, you can email our Data Protection Officer at dpo@aberdeensportsvillage.com or write to us at:

Data Protection
Aberdeen Sports Village
Sports Centre
Linksfield Road
Aberdeen
AB24 5RU

Our Guide to Your Data Rights

The Data Protection Act 2018 and the UK General Data Protection Regulation (UKGDPR) give individuals a range of rights in relation to personal data. This guide aims to explain those rights to you and let you know how you can make use of them if Aberdeen Sports Village processes your personal data.

Your personal data

This is any information about you that means you can be identified. As an organisation we gather lots of personal data — about staff, members and non-members (the general public) — so we can deliver our services.

One of the main aims of GDPR is to empower individuals by giving more control over their personal data and to help you understand if we are meeting the principles of the data protection legislation.

To do this, GDPR gives you the following rights:

• The right to be informed
• The right of access
• The right to rectification
• The right to erase
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling

Right to be informed

You have the right to know how we are processing your personal data, including:

• why we are processing your personal data
• what categories of personal data we are processing
• who we are sharing your personal data with
• how long we will retain your personal data

We publish this information in our privacy notices, which we make available at the time of collecting information from you and on our website.

Right of access

You have the right to ask for a copy of the personal data we hold about you, along with information on why and how it is processed. This will help you understand what data is being used for and to verify the lawfulness of that use.

This is generally known as making a 'subject access request'. A subject access request is free of charge, unless it is excessive or repetitive. If this is the case, we may charge a reasonable fee to cover the costs of providing the information.

We will require verification of your identity before responding to the request, to make sure we have the right person and the right information.

We will provide you with the information you have requested within 1 month. Although if the request is complex, we may extend the deadline by a further 2 months. If this is the case, we will discuss it with you.

There are some exemptions which may apply and might mean not all the information you request will be available, for example if providing the information would also disclose the personal data of another person. In such circumstances we will redact (withhold) some or all the information. We will explain our reasons for doing this when we provide the response.

If you would like to make a request, please use the Contact Us section.

Right to rectification

You have the right to have your personal data rectified if it is inaccurate or incomplete.

If we are unable to correct your data and have a legitimate reason for this, we will keep your statement requesting rectification on your record(s). We will also explain our reasons for this to you.

If we have passed your personal data on to any other organisations (in accordance with lawful processing and as described in our privacy notices) we will ask them to update the personal data they hold.

If the personal data held by us is correct, we will not make any changes and will advise you of this.

Right to erasure (the right to be forgotten)

You have the right to ask us to delete or remove personal data we process when there is no compelling reason for us to process it. For example:

• where it is no longer necessary for the purpose for which it was originally collected/processed
• when you withdraw consent
• if you object to the processing and there is no overriding legitimate interest for continuing the processing
• the use of the data is unlawful.
• the data must be erased to comply with a legal obligation.

This is not an absolute right, which means we can refuse a request for erasure if the processing of personal data is:

• used to exercise the right of freedom of expression and information.
• needed to comply with a legal obligation or the performance of a public interest task.
• needed for public health purposes in the public interest.
• for archiving in the public interest, for scientific or historical research, or for statistical purposes
• needed for making or defending legal claims.

When this right is exercised, we will stop any further processing, delete all your personal data and advise any other organisations we may have passed your data to (in accordance with lawful processing and as described in our privacy notices) to do the same.

Right to restrict processing

You have the right to ask us to stop processing your personal data if:

• You believe the personal data we are processing is inaccurate or incorrect.
• You believe our processing is unlawful and you would like us to stop (but not have your information deleted)
• We no longer need to process your personal data, but it needs to be kept making or defend a legal claim.

We will retain enough personal data to meet the needs for keeping it and will make sure it is not processed for any of the purposes for which you have asked us to stop.

You can contact us using the Contact Us details to ask for the restriction of the processing of your data including some processing we do under legitimate business interests.

Right to portability

You have the right to ask for a digital copy of personal data held about you. This allows you to move, copy or transfer your data from one IT system to another in a safe and secure manner.

This right only applies to personal data:

• that you have provided to us
• that is processed based on your consent or because it is necessary as part of a contract.
• that is processed by automated means.

We will provide the information requested in a machine-readable format so that it can be reused by any other organisation you choose to pass it to.

Right to object

You have the right to object to our processing of your personal information when ASV is processing your personal data:

• In the legitimate interests of the organisation. We must show compelling legitimate grounds to be able to continue to process your data.
• For direct marketing, including profiling.
• For scientific or historical research or for statistical purposes, unless the processing is necessary to carry out a public task in the public interest.

We will stop processing your personal data unless there is a compelling reason that is greater than your individual rights.

Rights relating to automated decision making and profiling

Automated decision making is where a decision is made solely by automated means, without any human intervention e.g. by a computer algorithm. Profiling is the automated process of using personal data to evaluate certain things about an individual.

You have the right to:

• Know whether an organisation is using automated decision making and processing.
• Request human intervention and to challenge a decision.

ASV does not currently use any automated processes or profiling activities without human intervention.

Right to withdraw consent

In addition, if you have given your consent for us to process your personal data and we are using this as the lawful basis for processing you can withdraw your consent at any time. This means we will stop processing your data for the specified purpose(s); you can also exercise your rights to erasure and portability.

How to exercise your rights

If you would like to exercise any of these rights, or ask for more information or explanation, please contact us by emailing dpo@aberdeensportsvillage.com

If, having contacted us, you are still unhappy you right to complain to the Information Commissioner who is the regulator for data protection in the UK:

Website: ico.org.uk/global/contact-us
Helpline: 0303 123 1113