Privacy Notice

Who are we?

We are Edinburgh Leisure, a charity dedicated to improving the health and wellbeing of people in and around Edinburgh. Established in 1998 we manage and develop over 30 top-class sport and leisure facilities. We also run many programmes to support people affected by health conditions or inequalities to lead healthier lives.

Edinburgh Leisure is a company limited by guarantee (company number SC179259) and does not have share capital or shareholders. We are a charity registered in Scotland (no SC027450) and every penny our customers spend with us is invested back into our facilities and services to help local people lead more active, and healthier lives. Our registered office address is Meadowbank Sports Centre, London Road, Edinburgh EH7 6AE.

We are registered as a data controller with the Information Commissioner’s Office, with registration number Z469586X.

How your personal information is used and kept secure by Edinburgh Leisure

At Edinburgh Leisure we respect and protect your privacy. This privacy notice explains how we process your personal data.

The security of your personal information is of paramount importance to us, and we use appropriate technical and organisational measures to safeguard your personal information.

However, whilst we will use reasonable efforts to safeguard your personal information, the use of the Internet is not entirely secure and, for this reason, we cannot guarantee the security of any personal information that is transferred by or to you via the Internet.  If you have any concerns about the security of your personal information, please contact us for more information.

How do we collect personal information from you?

We may collect personal information either on paper forms or electronically:

  • When you buy or enquire about our products and services
  • When you talk to us on the phone or in our venues
  • When you join any of our Active Communities programmes   
  • From emails    
  • When you use our website or coaching portal, online booking services or mobile app    
  • In customer surveys  
  • When you use our venues 
  • If you take part in competitions or promotions
  • If you join Edinburgh Leisure as a Service Provider
  • If you provide donations or funding to us       
  • When you visit our website

What type of information is processed about you?

 Personal - Name, address, email, date of birth, telephone, membership number, signature

 Qualifications - For Service Providers we require copies of insurances and certificates. For extended lets we require evidence of insurances and may also require evidence of qualifications.

For customers taking part in externally validated qualifications, we will also hold records of this.

For IRATA qualifications, IRATA numbers, driving licence number, passport number and national insurance number

 

Product or service - Details about the products or services you have used or bought from us.

Financial - For example bank address, sort code and account number. If you buy something from us using a card, your card information is not held by us. It is collected by our third-party payment processors. They specialise in the secure online capture and processing of credit/debit card transactions.

Image - If you become a member or sign up to our programmes your photograph will be taken electronically to allow our staff to verify your membership. When utilising our self-entry system your image will be displayed on a screen when you are there to verify your identity. We also have a variety of CCTV systems across our facilities which may capture your image. Images may also be taken and used for marketing purposes, with your consent.

Sensitive data - This includes any medical or health information disclosed or discovered through our gym induction programme, by self or external company referrals into any of our health programmes, or by parents/guardians volunteering this information.

Usage - Information about how you use our products and services

Preferences and consents - This includes information such as how you would prefer us to contact you, what your fitness aims are, whether you wish to receive marketing information from us, use of your image for marketing purposes or confirmation that you understand risks associated with certain activities such as climbing

 

What are the legal bases for us processing your personal data

We will only process your personal data on one or more of the following legal bases:       

  • contract           
  • consent       
  • our legitimate interests, including CCTV recordings, the usage of display screens to confirm the identity of customers, inviting individuals to VIP events, live report on class attendees, undertaking surveys and sending operational emails            
  • vital interests and qualifications reminders         
  • the performance of a task carried out in the public interest / with official authority       
  • legal obligation

 

Where we are relying on the lawful basis of contract for the processing of personal data, we may not be able to enter into an agreement with you if you do not provide us with the relevant information.

Where we rely on the lawful basis of consent, you can withdraw consent at any time by contacting us using the information below.

The purpose of our processing of your personal data is primarily to provide goods and services to you, receive donations from you and / or to enter into an agreement with you.

How long we keep your personal data

We set retention periods for the retention of personal data based on legal requirements and best practice.

 

Who do we share your personal data with?

We may disclose your personal data to any of our employees, officers, contractors, insurers, professional advisors, agents, suppliers, subcontractors and external bodies insofar as reasonably necessary, and in accordance with data protection legislation. 

We may also disclose your personal data, as allowed by law, including:         

  • with your consent;     
  • to the extent that we are required to do so by law;     
  • to protect the rights, property and safety of us, our customers, users of our websites and other persons;
  • in connection with any ongoing or prospective legal?proceedings;
  • If we are investigating a complaint, information may be disclosed to solicitors, independent investigators such as auditors, regulatory body involved in any complaint, whether investigating the complaint or otherwise; 
  • to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; 
  • to another organisation if we enter into a joint venture or merge with another organisations.

 

How you can update your information

The accuracy of your information is important to us. If you change email address or if any of the other information we hold is out of date, please contact us via askus@edinburghleisure.co.uk.

16 or Under

We will always protect the privacy of children aged 16 or under. For our coaching programmes only a parent/guardian of children aged under 16 can provide us with personal information and will be or point of contact. Please do not provide us with phone numbers or email addresses of under 16’s. Our Active Communities programmes may work directly with young people and will utilise their contact information if required.

Any health data you supply for under 16’s in our coaching programmes will be held in our Learn2 system which can be accessed by coaches, service providers and volunteers working on our behalf. This is to ensure our staff have the relevant information to hand when providing a service to under 16’s. This information is supplied by parents/guardians of children, if they feel it is relevant. Health data supplied through our Active Communities programmes is retained on a central database with very limited and controlled access.

Transferring your personal data outside of the United Kingdom

Where Edinburgh Leisure processes your personal data outside of the United Kingdom we will ensure that lawful and appropriate safeguards are in place, in accordance with the UK General Data Protection Regulation.

 Marketing

When you contact us, you may be asked if you want to receive relevant information from us about the vital work we do to help keep Edinburgh active and the latest information on our products, services and offers. 

Updating your marketing preferences

 You can email askus@edinburghleisure.co.uk or call us on 0131 458 2100 to update your marketing preferences.

You can choose to stop receiving email marketing at any time by clicking the ‘unsubscribe’ link at the bottom of emails.

Whatever you choose, we will continue to send you important operational information such as class cancellations or venue closure notifications which may affect you.

What are your rights?

You have the right at any time to request us to comply with your request to exercise your data subjects’ rights, including: 

·        Access 

·        Rectification 

·        Erasure 

·        Restriction 

·        Portability 

·        Object 

Please contact us, using the contact details below, if you wish to make any of the above requests.  When you make a request, we are required to verify your identity and may ask you for specific information to fulfil this purpose.  Normally, you will not need to pay a fee when you make any of the above requests, but we may charge a reasonable fee or refuse to comply if your request for access is clearly unfounded or excessive. Alternatively, you can use our online form, which is available at Ask Us | Edinburgh Leisure | | Submit a Ticket

Queries and Complaints 

Any questions relating to this notice and our data protection compliance should be sent, in the first instance to askus@edinburghleisure.co.uk

Edinburgh Leisure has appointed a Data Protection Officer (DPO). Our DPO is provided by RGDP LLP, who can be contacted either via 07935 008316 or info@rgdp.co.uk  You can contact them directly regarding any queries or complaints.

We seek to directly resolve any queries or complaints about how we process personal information and would request you contact us in the first instance if you have any concerns. You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.  The Information Commissioner’s contact details are noted below: 

 

Telephone: 0303 123 1113

Online: Make a complaint | ICO

 

Reviewing this notice

We will review this notice as required. This notice was last updated January 2022.