Privacy Policy
Ashmole Phoenix Gymnastics Club (APGC) privacy notice – members and volunteers
APGC is the data controller and is committed to complying with our legal responsibilities under data protection law. We take your privacy seriously and will ensure your personal information is kept secure.
When we collect, use, share, retain or do anything else with your personal information (known collectively as ‘processing’) we are regulated under the General Data Protection Regulation (GDPR) and are responsible as ‘controller’ of your information.
This notice applies to you if you are:
We have a separate notice which provides privacy information relating to employees.
It is important that you read this carefully as it contains key information about how we use your personal data and your associated rights.
About us
APGC is a ‘not for profit’ membership organisation. Our members are gymnasts or the parents (if the gymnast is a child). We provide the opportunity for our members to participate in our activities, which include recreational classes, training, competitions, and other similar gymnastics activities.
We register with British Gymnastics who governs the sport, provides insurance for clubs and individual members and offers competitions and events. It is a condition of British Gymnastics club registration that all our club members also register as individual members of British Gymnastics.
We also affiliate to London Gymnastics who runs competitions and events in which we may participate.
Information we collect about you
The categories of personal information we process includes:
British Gymnastics collects the above information on our behalf when you join or renew your British Gymnastics membership.
The information marked with an * above is essential for us to provide your membership. It is your choice whether you provide all the information we have requested but not providing information may affect our ability to meet you or your child’s needs and to protect their well-being.
Our purposes for processing information about you
We use the information we hold about you for a variety of purposes which are outlined below. Data protection law requires us to tell you what our legal reason is for each purpose.
Contractual purposes
When you ask us to provide you a service, such as club membership or registration, gymnastics classes, competitions, or other activities or you buy a product from us we usually need to use information about you to provide this product or service, for example:
We do so because it is necessary for the performance of a contract.
Legal obligations
We have a duty of care to ensure it is safe for you or your child to take part in gymnastics activity and to keep you/them safe while participating. Some individuals may be at risk of harm from participating in gymnastics activity as a result of a pre-existing condition. It is vital that you let us know if there is any reason why taking part in gymnastic activity may be unsafe prior to participation. With your agreement, we will review any information you provide and undertake risk assessments in consultation with yourself and any appropriate trained professionals e.g. medical consultants. When we ask participants to provide relevant health information such as details of medical conditions, medication needs, allergies or injuries, this is because we have a legal obligation.
If you are selected for a role at the club, we will usually obtain a reference from any appropriate organisation or individual you have nominated.
When you tell us about any special needs such as disabilities or other support information we may use relevant information to comply with our legal obligations under the Equality Act 2010. We will review any information you have provided to help us identify any actions we can take to support inclusion. We may need to ask you for more information to help us to best meet your or your child’s needs. We will keep a record of any steps we take to support inclusion.
If you are wishing to volunteer or work for us, we may need to ask you to complete a criminal record check as we have a legal obligation to do so. We jointly control the checking process with British Gymnastics who is responsible for the assessment of any content on the check and will only share information with us where it is appropriate. For example, if you are considered by British Gymnastics to be unsuitable to take on the role, we may share relevant and proportionate information about criminal offences where it is deemed that while you are not considered unsuitable to take on the role, if it is considered necessary for safeguarding purposes.
When we retain information about you, even after you are no longer taking part in gymnastics activity, this is often because we are required to do so by law such as records we are required to keep for business and accounting purposes. Sometimes we are also legally obliged to share information about you with third parties. More information it provided below.
Legitimate interests
We rely on legitimate interests for the following purposes:
We keep records of progress against our award scheme
If there are no places in the club, we can place you on our waiting list and will contact you using the details you provide to inform you when a place is available.
If you wish to enter a competition organised by another gymnastics body, including British Gymnastics, and Regional Gymnastics Association, we will provide your information to the organiser to enable you to take part in the competition or event that they are organising.
Let us know if you do not wish to be filmed or photographed or do not want your image to be published. While we can usually take steps to prevent you from being photographed or filmed at small club events, please bear in mind that at our large public events, it may be difficult to avoid capturing you in footage. However, we always review all photographs prior to publication and we will ensure any images of you are deleted.
If we are filming or taking photos for any other purpose, we will ask for your consent.
We have carried out a legitimate interest assessment (LIA) to ensure that the above processing is necessary and is carried out in a way that ensures a balance between the club’s interests and your individual interests, rights and freedoms with appropriate safeguards, especially to protect the interest of data subjects who are children. We can provide details of these assessments on request.
You have a right to object to the use of your information for any purposes we undertake based on legitimate interests. Further information is provided in the section below on individual rights.
Consent
We rely on consent in the following circumstances:
With your consent, we may take photos during training or at small club events to promote the club on our website and in communications. All film and photos of children will be published in line with our safeguarding policy.
When you have given us your consent for your personal information to be used for a particular purpose, you have the right to withdraw this consent at any time, which you may do by contacting us using the contact details below. If you provided (any) consent(s) for a specific purpose as part of the information you provided on our behalf through the British Gymnastics membership platform, this (these) consents can be withdrawn at any time by logging into your British Gymnastics account. Your withdrawal of consent will not affect any use of the data that was made before you withdrew your consent.
Special categories of personal data
Special categories of personal data are a category of information that is more sensitive and requires greater protection. Some of the information we process falls into this category (e.g. health/medical data or any information you provide to us about a disability or your religion, race or gender identity). It is unlawful for organisations to process this type of information unless an additional legal condition applies. We will only process this type of information if one of the following applies:
Marketing
We will not use or share your data for marketing purposes.
Why we share information about you
We have a legitimate interest in sharing your personal information with British Gymnastics to ensure the sport is safe and well-governed and where relevant to access support and advice.
We may also be required to share your personal information in the following reasons:
Except for the above, will only share your information with any other third parties with your prior agreement.
Transfers of data out of the EEA
We will not transfer or store your personal data outside the UK or the European Economic Area (EEA).
Individual rights
You have important rights under data protection law. In summary these include:
Video footage that has only been taken for coaching purposes will be retained only for as long as it is required for that purpose and in most cases, will be deleted within one month.
Photographs and other video footage captured for promotional purposes will be retained for up to 4 years. After this time, they will be deleted unless we consider them to be of public interest and should consequently be archived for historical purposes. Where images have been published on social media, these platform providers may continue to process your data after the retention period has lapsed.
You have a right to request the deletion of your information in advance of the above retention periods. We will delete this information unless there is a lawful reason for the information to be retained.
The right to object extends to any automated decision making including profiling, which we do not undertake
Click here to learn more about your rights.
To exercise any of your rights or if you have any questions about our privacy notice please contact:
Julia; Gina; Fiona or Louise via [email protected]
While we hope to be able to resolve any concerns you have about the way that we are processing your personal data, you have the right to lodge a complaint with the Information Commissioners Office (ICO) if you believe your data has been processed in a way that does not comply with the GDPR or have any wider concerns about our compliance with data protection law. You can do so by calling the ICO helpline on 0303 123 1113 or via their website.
Keeping your personal information secure [optional]
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 reason to need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will
contact you and the ICO of any personal data breaches in line with our legal obligations.
Changes to the privacy notice
We keep our privacy notices under regular review. This privacy notice was published on 11th September 2018 and last updated on 11th September 2018.
We may change this privacy notice from time to time, when we do we will inform you via email.
APGC is the data controller and is committed to complying with our legal responsibilities under data protection law. We take your privacy seriously and will ensure your personal information is kept secure.
When we collect, use, share, retain or do anything else with your personal information (known collectively as ‘processing’) we are regulated under the General Data Protection Regulation (GDPR) and are responsible as ‘controller’ of your information.
This notice applies to you if you are:
- An existing or prospective member of our club;
- A person with parental responsibility for a member;
- An existing or prospective club volunteer or official;
We have a separate notice which provides privacy information relating to employees.
It is important that you read this carefully as it contains key information about how we use your personal data and your associated rights.
About us
APGC is a ‘not for profit’ membership organisation. Our members are gymnasts or the parents (if the gymnast is a child). We provide the opportunity for our members to participate in our activities, which include recreational classes, training, competitions, and other similar gymnastics activities.
We register with British Gymnastics who governs the sport, provides insurance for clubs and individual members and offers competitions and events. It is a condition of British Gymnastics club registration that all our club members also register as individual members of British Gymnastics.
We also affiliate to London Gymnastics who runs competitions and events in which we may participate.
Information we collect about you
The categories of personal information we process includes:
- Contact details* (gymnast or parent and emergency contacts)
- Gymnast date of birth*
- Gymnast gender
- Any relevant medical conditions and/or disabilities and additional related information
- Other relevant individual needs for example, information about learning, religious or other support needs.
British Gymnastics collects the above information on our behalf when you join or renew your British Gymnastics membership.
- Any individual risk assessments (gymnasts and others if applicable)
- Details of any reasonable adjustments or steps taken to support your individual needs
- British Gymnastics membership details* (which are confirmed by British Gymnastics when you join or renew)
- Gymnast attendance and achievement records
- Any communications from, to or relating to you
- Details relating to standards of conduct
- Any accident or incident reports including details of injuries
- Bank details (If you are making regular payments to us or we are making payments to you e.g. for volunteer expenses)
- Experience, qualifications, training and confirmation that you have completed a criminal record check (prospective or existing volunteers).
The information marked with an * above is essential for us to provide your membership. It is your choice whether you provide all the information we have requested but not providing information may affect our ability to meet you or your child’s needs and to protect their well-being.
Our purposes for processing information about you
We use the information we hold about you for a variety of purposes which are outlined below. Data protection law requires us to tell you what our legal reason is for each purpose.
Contractual purposes
When you ask us to provide you a service, such as club membership or registration, gymnastics classes, competitions, or other activities or you buy a product from us we usually need to use information about you to provide this product or service, for example:
- To contact you to confirm arrangements;
- To notify you about changes to terms and conditions;
- To tell you when it is time to renew membership or re-register for activities
- To process payments or send you receipts required.
We do so because it is necessary for the performance of a contract.
Legal obligations
We have a duty of care to ensure it is safe for you or your child to take part in gymnastics activity and to keep you/them safe while participating. Some individuals may be at risk of harm from participating in gymnastics activity as a result of a pre-existing condition. It is vital that you let us know if there is any reason why taking part in gymnastic activity may be unsafe prior to participation. With your agreement, we will review any information you provide and undertake risk assessments in consultation with yourself and any appropriate trained professionals e.g. medical consultants. When we ask participants to provide relevant health information such as details of medical conditions, medication needs, allergies or injuries, this is because we have a legal obligation.
If you are selected for a role at the club, we will usually obtain a reference from any appropriate organisation or individual you have nominated.
When you tell us about any special needs such as disabilities or other support information we may use relevant information to comply with our legal obligations under the Equality Act 2010. We will review any information you have provided to help us identify any actions we can take to support inclusion. We may need to ask you for more information to help us to best meet your or your child’s needs. We will keep a record of any steps we take to support inclusion.
If you are wishing to volunteer or work for us, we may need to ask you to complete a criminal record check as we have a legal obligation to do so. We jointly control the checking process with British Gymnastics who is responsible for the assessment of any content on the check and will only share information with us where it is appropriate. For example, if you are considered by British Gymnastics to be unsuitable to take on the role, we may share relevant and proportionate information about criminal offences where it is deemed that while you are not considered unsuitable to take on the role, if it is considered necessary for safeguarding purposes.
When we retain information about you, even after you are no longer taking part in gymnastics activity, this is often because we are required to do so by law such as records we are required to keep for business and accounting purposes. Sometimes we are also legally obliged to share information about you with third parties. More information it provided below.
Legitimate interests
We rely on legitimate interests for the following purposes:
- Responding to communications, concerns or complaints and seeking feedback from you about our services.
- Holding emergency contact information
- Maintaining attendance registers, achievement records and waiting lists
We keep records of progress against our award scheme
If there are no places in the club, we can place you on our waiting list and will contact you using the details you provide to inform you when a place is available.
- Entering you into a competition and providing results
If you wish to enter a competition organised by another gymnastics body, including British Gymnastics, and Regional Gymnastics Association, we will provide your information to the organiser to enable you to take part in the competition or event that they are organising.
- To monitor that you have completed any required safeguarding training and criminal record checks
- Filming for coaching purposes
- Photography and filming [at large club events] to promote the club
Let us know if you do not wish to be filmed or photographed or do not want your image to be published. While we can usually take steps to prevent you from being photographed or filmed at small club events, please bear in mind that at our large public events, it may be difficult to avoid capturing you in footage. However, we always review all photographs prior to publication and we will ensure any images of you are deleted.
If we are filming or taking photos for any other purpose, we will ask for your consent.
- Running and monitoring our club website
- Using CCTV for security and crime detection/prevention
We have carried out a legitimate interest assessment (LIA) to ensure that the above processing is necessary and is carried out in a way that ensures a balance between the club’s interests and your individual interests, rights and freedoms with appropriate safeguards, especially to protect the interest of data subjects who are children. We can provide details of these assessments on request.
You have a right to object to the use of your information for any purposes we undertake based on legitimate interests. Further information is provided in the section below on individual rights.
Consent
We rely on consent in the following circumstances:
With your consent, we may take photos during training or at small club events to promote the club on our website and in communications. All film and photos of children will be published in line with our safeguarding policy.
When you have given us your consent for your personal information to be used for a particular purpose, you have the right to withdraw this consent at any time, which you may do by contacting us using the contact details below. If you provided (any) consent(s) for a specific purpose as part of the information you provided on our behalf through the British Gymnastics membership platform, this (these) consents can be withdrawn at any time by logging into your British Gymnastics account. Your withdrawal of consent will not affect any use of the data that was made before you withdrew your consent.
Special categories of personal data
Special categories of personal data are a category of information that is more sensitive and requires greater protection. Some of the information we process falls into this category (e.g. health/medical data or any information you provide to us about a disability or your religion, race or gender identity). It is unlawful for organisations to process this type of information unless an additional legal condition applies. We will only process this type of information if one of the following applies:
- You have given your explicit consent or have made this information public;
- We are required to do so to establish, exercise or defend a legal claim;
- We are required to do so to comply with employment or social security or social protection law;
- Legitimate activities of a ‘not for profit’ organisation;
- There is a substantial public interest in doing so; or
- It is in your vital interests and you are unable to provide consent e.g. if you are unconscious or do not have sufficient mental capacity.
Marketing
We will not use or share your data for marketing purposes.
Why we share information about you
We have a legitimate interest in sharing your personal information with British Gymnastics to ensure the sport is safe and well-governed and where relevant to access support and advice.
We may also be required to share your personal information in the following reasons:
- Complying with legal and/or regulatory responsibilities
- Insurance
- Obtaining legal or professional advice
- Obtaining a service from a third party
Except for the above, will only share your information with any other third parties with your prior agreement.
Transfers of data out of the EEA
We will not transfer or store your personal data outside the UK or the European Economic Area (EEA).
Individual rights
You have important rights under data protection law. In summary these include:
- To be informed about how your information is processed (set out above)
- To access any personal data held about you
- To have your data rectified if it is inaccurate
- To have your data deleted (except if there is a valid lawful reason to retain it)
Video footage that has only been taken for coaching purposes will be retained only for as long as it is required for that purpose and in most cases, will be deleted within one month.
Photographs and other video footage captured for promotional purposes will be retained for up to 4 years. After this time, they will be deleted unless we consider them to be of public interest and should consequently be archived for historical purposes. Where images have been published on social media, these platform providers may continue to process your data after the retention period has lapsed.
You have a right to request the deletion of your information in advance of the above retention periods. We will delete this information unless there is a lawful reason for the information to be retained.
- To have your information restricted or blocked from processing
- To portability
- To object to:
- Any processing based on legitimate interests
The right to object extends to any automated decision making including profiling, which we do not undertake
Click here to learn more about your rights.
To exercise any of your rights or if you have any questions about our privacy notice please contact:
Julia; Gina; Fiona or Louise via [email protected]
While we hope to be able to resolve any concerns you have about the way that we are processing your personal data, you have the right to lodge a complaint with the Information Commissioners Office (ICO) if you believe your data has been processed in a way that does not comply with the GDPR or have any wider concerns about our compliance with data protection law. You can do so by calling the ICO helpline on 0303 123 1113 or via their website.
Keeping your personal information secure [optional]
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 reason to need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will
contact you and the ICO of any personal data breaches in line with our legal obligations.
Changes to the privacy notice
We keep our privacy notices under regular review. This privacy notice was published on 11th September 2018 and last updated on 11th September 2018.
We may change this privacy notice from time to time, when we do we will inform you via email.