North Ayrshire Leisure Limited (“K:A Leisure”) takes your privacy very seriously.
- What personal data we collect about you;
- How we collect your personal data;
- How we use your personal data;
- The basis on which we use your personal data;
- Who we share your information with;
- How long your personal data will be kept;
- Transferring your personal data outside of the European Union;
- The steps we take to protect your personal data;
- The rights you have in relation to your personal data; and
- How to contact us about this policy.
Our use of your personal data is subject to your instructions, the EU General Data Protection Regulation (GDPR), the Data Protection Act 2018, other relevant UK and EU legislation and our professional duties to clients.
North Ayrshire Leisure Limited registered in Scotland under the Companies Acts, registered number SC202978 and having its registered office at 22 Quarry Road, Irvine, Scotland, KA12 0TH.
Our Data Protection Officer oversees compliance with data protection laws and this policy and provides guidance and advice to K:A Leisure as required.
Contact information for our Data Protection Officer is provided below under the heading “How to contact us about this policy”.
What personal data we collect about you
We may collect information from you in the course of our business, including when you visit our premises or use our services, when you contact or request information from us, when you use our website, when you apply for a job with us or as a result of your relationship with one or more of our staff and clients.
The personal information we may collect about you includes:
- Contact information such as your name, title, address, telephone number, mobile phone number, job title, name of employer, fax number and email address;
- Information about your use of our IT, communication and other systems including your password(s), and other monitoring information or information relating to materials and communications we send to you electronically;
- Information to enable us to check and verify your identity, e.g. your date of birth or passport details;
- Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, bank and building society details including security code numbers and other related billing information, as well as, where applicable, information relating to the source of funds;
- Information collected from publicly available resources and credit agencies;
- Details of your visits to our premises, including the capture of CCTV footage; and/or
- Membership of a professional or trade association or union.
In general, you will be able to choose whether or not to provide us with your personal data. If you do not provide the personal data that we need to collect then this may affect our ability to act on your behalf or to provide services to you, for example because this personal data is required to process your membership application. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How we collect your personal data
We collect most of this information from you:
- When you contact us to provide services;
- When you browse, provide information or use our website;
- When you make an enquiry for our services;
- Where you sign up to receive information from us;
- Where you or your organisation provide services to us.
We may also collect information from third party sources including:
- Credit reference agencies or government agencies;
- Third party organisations that you have or have had dealings with.
We may also collect information via our website or via our information technology (IT) and other systems.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so.
This will be for one of the following reasons:
- For the performance of our contract with you;
- To comply with our legal and regulatory obligations;
- For our legitimate interests or those of a third party;
- For the establishment, exercise or defence of legal claims or proceedings; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We may process special category personal data for the following reasons:
- Where you have given your explicit consent;
- For compliance with a legal obligation;
- For the purposes of establishing, exercising or defending legal claims;
- Where it is in your vital interests;
- Where you have made the personal data public; and/or
- For compliance with an employment law obligation.
There may be additional reasons which will be notified to you where they apply.
When we refer to special category data we mean information such as about race or ethnicity, religious beliefs, sexual orientation, marital status and health. Information about criminal convictions is also included within this type of data.
Managing our business
In relation to a number of uses of personal data we refer to above we are using such personal data on the basis that it is in our legitimate interests or those of a third party for us to do so. These interests cover a number of aspects of our business operations, namely:
- Ensuring that we are as efficient as we can be so we can deliver the best service for you at the best price;
- Preventing and detecting fraud and/or criminal activity that could be damaging for us and for you;
- For credit control purposes and to make sure our customers and members can pay for the services we provide;
- For the purposes of risk management so we can demonstrate we operate to the highest standards.
We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with respect.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at email@example.com;
- Using the ‘unsubscribe’ link in emails.
If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
You can also update your marketing preferences and give us more detail of the type of information you would like to receive from us by contacting us on our preference centre.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Use of website
At a number of points on our website you are asked to provide information, for example. our contact page and our Careers page. At the point at which information is requested it is clear what the purpose of providing the information is and we will only use the personal data you provide to us for that purpose.
Our website makes use of Google Analytics to look at how our website is used. This is done by placing small text files, known as session cookies, on your device to collect information about how visitors use our website. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This information is transmitted to and stored by Google on servers in the US.
Who we share your personal data with
We share personal data and financial information with North Ayrshire Council on a confidential basis where required for the purposes of providing services (e.g. facility management services).
We also routinely share personal data with:
- Companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared;
- Our insurers and brokers, external auditors, banks and other third parties which provide services to us to allow us to fulfil our regulatory obligations and for risk management purposes;
- Courts, law enforcement authorities, regulators or lawyers or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process or to comply with our legal and regulatory obligations;
- Third parties for the purposes of collecting your feedback our service provision, to help us measure our performance and to improve and promote our services;
- External service suppliers, representatives and agents that we use to make our business more efficient, e.g. technology service suppliers, marketing agencies, document collation, translators or analysis suppliers;
We will only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you and to ensure compliance with data protection laws.
We may also, should the need arise, need to share some personal data with other parties, such as during a re-structuring. Usually, information will be anonymised but this may not always be possible.
The recipient of the information will be bound by confidentiality obligations.
We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.
Other than as set out above, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
Personal data about other people which you provide to us
How long your personal data will be kept
- Legal and regulatory requirements and guidance;
- Limitation periods that apply in respect of taking legal action;
- Our ability to defend ourselves against legal claims and complaints;
- Good practice; and
- The operational requirements of our business.
When it is no longer necessary to retain your personal data, we will delete or anonymise it. If you would like more information about how long we hold particular types of personal information then please contact us on firstname.lastname@example.org.
Updating personal data about you
We also need to know that your information is accurate and up to date so please advise of any changes on email@example.com. You should also use this email address if you want to cancel any request you have made to us or you become aware of any inaccuracy in the data we hold about you.
Transferring your personal data out of the European Union
To deliver services to our clients, it is sometimes necessary for us to share your personal data outside the European Union (EU), e.g.:
- Where our service providers are located outside the EU;
- If you are based outside the EU.
These transfers are subject to special rules under European and UK data protection law.
We will, however, implement appropriate safeguards to ensure the transfer complies with European and UK data protection law and all personal data will be secure. If you would like further information on these safeguards please contact our Data Protection Officer (see How to contact us about this policy below).
The steps we take to protect your personal data
We will take appropriate technical and organisational measures to keep your personal data confidential and secure. We have appropriate security measures in place which take account, in particular, of the risks arising from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
The rights you have in relation to your personal data
You have the following rights, which you can exercise free of charge:
You can ask us to:
- Provide a copy of your personal data;
- Correct any mistakes in your personal data;
- Delete your personal data – in certain situations;
- Restrict processing of your personal data – in certain circumstances, e.g. if you contest the accuracy of the data; and
- Provide you with a copy of the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.
You can object:
- At any time to your personal data being processed for direct marketing (including profiling);
- In certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
If you would like to exercise any of those rights, please email us on firstname.lastname@example.org.
Your objection (or withdrawal of consent) may mean we cannot perform the services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.
You also have the right to complain to the supervisory authority in the part of the European Union where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner so we would ask that you contact us in the first instance.
Our contact details can be found in the section below How to contact us about this policy.
How to contact us about this policy
Our contact details are shown below:
Data Protection Officer, North Ayrshire Leisure Limited, 22 Quarry Road, Irvine, Scotland, KA12 0TH
v.1.2 24 October 2019 Edited & customised by: KA Leisure. Registered Office: 22 Quarry Road, Irvine KA12 0TH; Tel: 01294 315120; Fax: 01294 315140; email: email@example.com North Ayrshire Leisure Limited is a Company Limited by Guarantee No. 202978 and a recognised Scottish Charity No. SCO29780.