Purpose of policy
All Your Trust employees have responsibilities under the Data Protection Regulations and are trained appropriately for their specific roles on complying with the provisions of the regulations. Managers are trained to ensure that within their areas their staff are aware of their responsibilities and adhere to the relevant requirements and processes.
The details of the Trust’s ICO’s registration (Ref No. Z9765258) can be accessed on the Information Commissioner’s Office website.
We are committed to protecting your personal information and being transparent about what information we hold about you.
Using personal information allows us to develop a better understanding of our customers and in turn to provide you with relevant and timely information about the work that we do and services that we provide – across all areas of our business. As a charity, it also helps us to engage with potential donors, funders and supporters.
The purpose of this policy is to give you a clear explanation about how we [and all of our subsidiaries] collect and use the information we collect from you directly and from third parties.
We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:
- What information we may collect about you
- How we may use that information
- In what situations we may disclose your details to third parties
- Information about how we keep your personal information secure, how we maintain it for and your rights to be able to access it
If you have any queries about this policy, please contact the Data Lead at Your Trust by emailing: email@example.com.
Who we are
Your Trust is a charity that works in the heart of the Rochdale Borough community, inspiring people to live more active, creative and healthy lifestyles. We connect people with their cultural heritage, encourage creativity and foster wellbeing for each and every member of our diverse community.
Our vision is for communities that are active, creative and healthy and we work towards this through delivery of three complimentary areas of work:
- Active: Management of high quality sport and leisure facilities including fitness, swimming, team sports, outdoor and adventure activities
- Culture: Curating an ambitious arts, heritage and entertainment offer including exhibitions, outdoor events, live shows, education and projects
- Wellbeing: Delivering targeted community programmes which aim to improve people’s health, enjoyment and wellbeing.
Your Trust is a registered charity in England and Wales (Charity number: 1118610) and public limited company (no 6052980).
We collect various types of information and in a number of ways:
Information you give us
For example when you register on our website, enrol to a newsletter, take out an activity membership, buy tickets or make a donation, we’ll store personal information you give us such as your name, email address, postal address, telephone number and bank details. We will also store a record of your purchases, memberships, bookings, visits and donations.
A number of our services enable users to create accounts or profiles. In connection with these services, we may ask you to provide certain information about yourself to set up the account or profile. For example, you can submit certain information about yourself, such as your name and email address, when you create an online bookings account.
If you order/book a paid service from us, we may ask for your name, contact information, billing address and credit/debit card information in order to process your order.
Information about your interactions with us
For example, when you visit our website, we collect information about how you interact with our content and ads. When we send you a mailing we store a record of this, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on.
Information from third parties
We occasionally receive information about you from third parties. For example, we may use third party companies to provide general information about you, compiled using publicly available data.
Sensitive personal data
Data Protection law recognises that certain categories of personal information are more sensitive such as health information, race, religious beliefs and political opinions. We do not usually collect this type of information about our service users unless there is a clear reason for doing so. As an example, we collect health information about participants in our exercise referral programme.
How do we use your information?
We may use information we collect for the following purposes:
- To register you for a Service;
- To provide a Service you request, including to enable us to fulfil our obligations under any contract with you;
- For assessment and analysis of our market, customers, products, and services (including asking you for your opinions on our products and services and carrying out customer surveys);
- To understand the way people use our Services so that we can improve them and adjust our programmes and services to match customers’ demands;
- For the prevention or detection of fraud or crime;
- To comply with our legal obligations;
- Management of our memberships and prospects;
- For bookings and club administration;
- For administration of operation issues (lost property, refunds, customer comments, accident reporting);
- Management of funded community outreach programmes;
- Management of volunteers across our services;
- Management and administration of our Arts and Heritage collection;
- Administration of visitors and contractors to our facilities;
- Otherwise with your consent.
There are three bases under which we may process your data:
When you make a purchase from us such as a fitness membership or ticket for an event or when you make a donation to us, you are entering into a contract with us. In order to perform this contract we need to process and store your data. For example we may need to contact you by email or telephone in the case of cancellation of a booking or session, or in the case of problems with your payment.
Legitimate business interests
In certain situations we collect and process your personal information for purposes that are in our legitimate organisational interests. However we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
With your consent
For any situations where the two bases above are not appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.
We aim to communicate with you about the work that we do and services we provide in ways that you find relevant, timely and respectful. To do this we use data that we have stored about you, such as what sessions or events you have booked for in the past, as well as any preferences you may have told us about.
We use our legitimate organisational interest as the legal basis for communications by post, email and SMS. In the case of postal mailings, you may object to receiving these at any time using the contact details at the end of this policy. In the case of email, we will give you an opportunity to opt out of receiving them during your first contact with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the end of this policy. This does not apply where we are contacting you in regards to communications that we are contractually required to send you, for example price changes for memberships you have.
You have the option to inform us what your preferred mailing method is. However, this is dependent on the nature and file size of the communication, but wherever possible we will endeavour to send this to your desired preference. This also requires us to have each contact method available to use.
We may also contact you about our services by telephone however we will always get explicit consent from you before doing this. Please bear in mind that this does not apply to telephone calls that we may need to make to you related to your purchases, memberships and services you receive.
We may use information about you which we hold in order to provide you with information about products or services, promotions, special offers and other information which relates to our products or services or which we believe may be of interest to you.
When you provide us with information about yourself, you will usually be given the option to let us know that you do not want that information to be used for direct marketing purposes whether by ourselves or by any third party. We will only use that information for the purpose of direct marketing in accordance with your preferences (or where we are otherwise permitted to do so by law).
Where your consent is required, we will usually ask for it by asking to you tick an “opt-in” box on the pages of our website or paper forms where we ask for information about you.
We may send you such information by:
- SMS text message and/or any other form of electronic messages (including MMS; picture messages; video messages; instant messages; and next generation messages);
- social networking websites;
- or any other method which becomes relevant from time to time.
You can change your mind about your preferences (as defined above) in respect of direct marketing by contacting our Data Protection Officer at Your Trust, c/o Middleton Arena, Lance Corporal Joel Halliwell VC Way, Middleton, M24 1AG or by emailing firstname.lastname@example.org. You can do this at any time.
In addition, if you receive direct marketing from us by email or by SMS message, you will be reminded in the email or SMS message that you are free to request a change to your preferences. If you do change your mind about your preferences, we would not remove your Personal Data from our data base(s) but we would note your changed preferences and would cease using your information for the purpose of direct marketing as soon as reasonably possible.
We will not disclose your information to third parties for their own independent marketing or business purposes without your consent. However, there are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
- To our own partners and service providers who process data and provide services on our behalf and on our instructions (for example our ticketing and booking system software provider). In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data. These entities are limited in their ability to use your information for purposes other than providing services for us.
- Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices, and/or browsing sessions. Cookies serve many useful purposes.
We use the following types of cookies on our website:
These enable you to order products and receive services from our website and make bookings;
These enable Your Trust and our third party providers to analyse the performance and design of our website and detect errors. For example, this type of cookie allows us to recognise that you have visited our website before, and show which sections of our website are most popular by allowing us to see which pages visitors access most frequently and how much time visitors spend on each page. We may use Google Analytics or similar analytics cookies to achieve this;
These allow us to deliver a better user experience. For example, this type of cookie ensures that the information displayed on your next visit to our website will match up with your user preferences, or tells us the domain name of another website from which you linked to our website; and
Our website may also display content from a third party website or service, which may result in cookies from third parties being stored on your hard drive or browser. We do not control the storage of these cookies and you should refer to the privacy policies of the relevant third party for more information.
When you use a web browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent.
Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. The operating system of your device may contain additional controls for cookies.
Please note, however, that some Services may be designed to work using cookies and that disabling cookies may affect your ability to use those Services, or certain parts of them.
Accessing your information
Under UK data protection law you have the right to request details of Personal Data which we hold about you. We will comply with your request promptly and by no later than 30 days from receipt of any such request. We may charge a reasonable fee for dealing with your request which we will notify to you. If you would like to make any such request please write to Data Privacy at Middleton Arena, Lance Corporal Joel Halliwell VC Way, Middleton, Manchester M24 1AG.
Please help us to ensure that the information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please write to Your Trust in the manner set out above. We will correct or update any information about you as soon as reasonably possible.
Requests for Erasure
Individuals have the right to have personal data erased. This is also known as ‘the right to be forgotten’. The right only applies to data held at the time the request is received. It does not apply to data that may be created in the future.
If you would like to make any such request, please contact email@example.com To ensure that we can identify you correctly, please include your full name, your date of birth and your membership number (if known).
When all relevant details have been received, we will comply with your request promptly and by no later than 30 days from receipt of any such request.
We will contact the individual when the request has been completed.