Data Protection Policy
Introduction
This policy explains how Wimbledon Racquets and Fitness Club (the “club”) manages data related to employees, coaches, volunteers, members, and guests of the club to comply with the Data Protection Act 2018 and implement General Data Protection Regulation (GDPR).
The purpose of this policy is:
- to protect the rights of those mentioned – by safeguarding your personal data;
- to comply with the law and follow best practice;
- to protect the club from the risks of a data breach.
The policy applies to all those who handle data on behalf of the club. It explains how we collect data, how we use and store your information and what it means for you.
Roles and responsibilities
WR&FC is the Data Controller. The Data Protection Officer for WR&FC is Board Director Geoff Chapman. It is the responsibility of all those that work for (or on behalf of) the club to adhere to this policy.
Whilst your information will not be shared for any marketing purposes or with unauthorised third parties, we do utilise the expertise of external partners for human resources, information technology and our membership and booking system. Whilst none of these companies has the right to use your data or is legally permitted to do so, we are making you aware that on occasions content may be viewed but not used. The club is the guardian of all information it holds.
Please be aware that we may pass on information if required by law or by a regulatory body, e.g. the police.
Principles
The club complies with its obligations under GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access, and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We collect data where lawful and where necessary for the legitimate purposes of the club. These are:
- Your name, contact details and any relevant medical information will be collected when you join the club or become an employee and are held on our membership management system (MyCourts). You should update this as and when any changes occur.
- Your email address and other contact details may be used to inform you of essential information related to your membership and also for marketing communications. Members do have the right to request no marketing emails, c.f. “How we get consent”.
We do not collect more data than is necessary to achieve these legitimate purposes. Ultimately, we need the information to provide you with the best service.
We keep your data secure. All our data is stored in a cloud-based environment, protected by passwords and other access control methods.
How we get consent
Where your personal data is displayed, e.g. on court booking web pages, or for the issuing of marketing communications we require your consent. You can change these consents at any time by logging into MyCourts and selecting “Privacy Settings” (for web pages) or “Email settings” (for marketing communications).
Data collected will only ever be used in the way described and consented.
Data Retention
We will keep records for no longer than is necessary. We periodically purge membership records for ex-members who are inactive and have zero balance on their account with the club. Such records may be held for up to three years.
Employee records are kept for five years after leaving the company.
CCTV recordings are held for two months before being deleted, unless management explicitly retains a recording for some legitimate purpose.
Individual’s rights
Members can ask to see the data we hold on them and for confirmation of how it is being used. Such requests should be made via email to the club Manager: manager@wimbledonclub.co.uk. Please be aware that this process may take up to 21 days and we may need to make further checks to ensure we are communicating with the correct individual.
Individuals can withdraw consent at any time from receiving marketing communications as explained in “how we get consent” above.
What we do with your data
We may use the personal data we collect from you to:
- inform you of news, events, activities, and services running at Wimbledon Racquets & Fitness Club;
- manage court bookings;
- manage any credit you have on your account with the club;
- administer attendance/membership records;
- provide an interactive website where email is used to communicate with users;
- raise funds and promote the interests of the club;
- manage our employees and volunteers;
- maintain our own financial accounts and business records.
Applying for a job or volunteering with us
Where you provide personal data and sensitive personal data when applying for a job or volunteer role with us, such as the information on your CV, we will process, store and disclose the personal data we collect to:
- Support the recruitment process;
- Answer any questions you may have;
- Use third parties to provide services such as references, qualifications, criminal referencing, checking services, verification of information you have provided, health screening and psychometric evaluation or skills tests;
- Provide anonymised data to monitor compliance with our equal opportunities policy.
We may hold recruiter information for up to a year after recruitment closes but will delete it sooner if you request this in writing.
Security
We ensure that we have appropriate technical controls in place to protect any personal data you provide. We ensure that access to personal data is restricted only to those staff members or volunteers whose job roles require such access and that suitable training is provided for these staff members and volunteers.
Credit/Debit card and bank security
If you use your debit or credit card to purchase something or pay for an event online, we will process your information securely in accordance with the Payment Card Industry Data Standard. We do not store any card information. We may hold your bank account details if you have asked us to set up a direct debit or standing order for you. These are stored securely and retained in line with legal requirements.
Where we store your personal information
We adopt the Information Commissioner’s approved measures and therefore ensure that personal data is held in compliance with European data protection regulations. We take all reasonable steps to ensure that your data is stored and processed securely in accordance with this policy. By submitting your personal data, you agree to this transfer, storing and processing of your information.
Children
Families are required to provide personal data for their children. This data is provided with the consent of the parent or guardian and is securely held and stored as above. We require parental consent for any child under the age of 18.
Telling us when things change
You can change the data we hold on you, e.g. your phone number, by notifying us by email to reception@wimbledonclub.co.uk detailing your full name and the data you want to change. You may be contacted for verification of changes requested.
Changes to this data protection policy
We may amend this policy from time to time to take account of changes to our processes or changes to data protection or other legislation. If we make any significant changes to this policy, we will show this clearly on our website or in our communications. By continuing to use our website you will be deemed to have accepted these changes.
Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing as well as setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Governing law
This policy is subject to the law of England and Wales.