How we use your information

This privacy policy explains what information the Department of Education, Sport and Culture collects and what that information is used for.
We aim to be fair and honest in managing your personal information. As part of this process we would like to explain how we use your personal information and inform you of the steps we take to protect that information.

What information do we collect?

• name and gender
• date of birth – to allocate a price level on our system based on age according to MSR’s Strategy for Sport.
• contact information including email address
• demographic information such as postcode, preferences and interests
• other information relevant to customer surveys and/or offers with consent
• photo ID for those signing up for memberships
• health information – for gym use and where relevant for the vital interests of customers.
• emergency contact details – for children involved in MSR activities.
• CCTV – for the vital interest of our customers.
• Membership ID and card ID – to assist in the delivery of our services
• Bank details – only where customers have chosen to pay for their membership or swim lessons by direct debit.

If you have given your consent but then change your mind you have the right to withdraw this consent at any time by contacting us at National Sports Centre, Groves Rd, Douglas, IM2 1RB Tel: 688550 / Email: [email protected] You also have the right to ask us to stop processing your information; however this may result in us being unable to offer you services. You also have the right to request your details to be erased from our system; however this may result in us being unable to offer you services.

Why do you need my personal information?

Depending on the activity you are taking part in or service you are using we may need to collect some of your information in order to provide these services or ensure your safety. Generally this information is collected at the time you begin to use the services (for example through discussions with our staff) or if you complete an application form.
When you agree to give us your information we may use it for the following purposes:

• We sometimes collect health related information from you in order to make sure you will be safe taking part in physical activities.
• To manage your membership subscription(s).
• For audit and debt collection.
• To provide you with discounts on activities and services.
• For statistical reporting.
• For internal monitoring of our own performance and services.

We will seek your consent to inform you about new activities which you or members of your family may be interested in and to also update you with information about the development of our facilities. If you have given your consent but then change your mind you have the right to withdraw this consent at any time by contacting us at National Sports Centre, Groves Rd, Douglas, IM2 1RB Tel: 688550 / Email: [email protected]

Who do you share my personal information with?

We may share your personal information with some agencies including:

• Swimming teachers – for your health and safety and to deliver a more personal service
• Staff taking sessions – for your health and safety and to deliver a more personal service
• IOM Government Treasury Department - debt recovery services
• Isle of Man Constabulary - where IOM Police requests assistance from us and we have a legal duty to assist, or where we choose to assist in order to protect our business, staff or customers, we will pass on only the personal information that is necessary for their procedures.
• Health professionals - with consent from participants
• Gladstone Software – as part of a legitimate interest for Manx Sport and Recreation (http://www.gladstonesoftware.co.uk/privacy-policy)

We occasionally share your information with partner organisations. We do this for the following reasons:

• We provide statistical reports so that our partners can monitor us to make sure we are achieving the objectives set by the Department of Education, Sport and Culture.
• We also provide statistical reports to some of our partners as part of funding bids to improve our services and facilities.
• Where we share statistical reports we remove information that identifies you as an individual. Some examples of statistical information we might provide to a partner:
• The age ranges of our customers. We use this information to demonstrate that we provide services and activities for all ages, from children through to adults.

We do not pass your information to any other company for their own marketing purposes.

Who are your partner organisations?

In order to deliver our services to local communities and meet our social objectives we work with partner organisations. An example of some of our current partners:

• Department of Education, Sport and Culture, Manx Sport and Recreation
  • Sports Development Unit
  • National Sports Centre
• Department of Health and Social Services
• Regional swimming pools

How do you protect the information you hold about me?

We store information about you in both electronic and written formats. Where we store written information it is stored in locked cabinets within our offices. Office access is restricted to employees and authorised partners only.
Your electronic information is stored on our secured network. Only authorised members of our staff are given login credentials to our network and they are only granted the access they require to fulfil their role within the company. Our computer applications are further secured by separate passwords and access to these is restricted to an even smaller number of employees. We regularly review who has access to these systems and remove access where an employee no longer requires it.

Can I access the information you hold on me, if so how?

Yes, you are entitled to know whether we hold or process any information about you. If we do hold or process any such information you are entitled to a copy of that information. You are further entitled to know the source of that information and who we share it with.
You can access the information through a process called a Subject Access Request. Subject Access Requests must be made in writing.
If you make a request we would encourage you to be as specific as possible about the information you would like us to search for. Doing so helps us speed the process up of looking for that information.
At present we may charge the statutory fee of £10 for each Subject Access Request made, which is payable before we commence a search. If a fee is due you will be notified when we acknowledge your request. The fee is not refundable in the event that no information is found, or you are otherwise dissatisfied with the information provided.
Before we provide a response to a Subject Access Request we may ask for proof of identity and/or entitlement to access that personal information.
You also have a right to request that we correct any inaccuracies in the information which we hold on you. You should make such requests to us in writing, and may do so by using the addresses in the section headed "To find out more information" below.
You may also ask us to restrict processing but this may mean that you are no longer able to access our services and make use of our facilities.
You also have the right to be forgotten, however this will mean that you will need to reapply for any of our services as information about you will have been deleted and no longer be accessible.

Is all information always released?

The law allows us to refuse your request for information in certain circumstances. For example, if you have previously made a similar request and there has been little or no change in the data since we complied with the original request.
The law also allows us to withhold information where, for example, release would likely to

• prejudice the prevention or detection of a crime
• prejudice the apprehension (arrest) or prosecution of offenders
• prejudice the assessment or collection of any tax or duty
• reveal the identity of another person, or information about them

We will do our best to apply these conditions carefully, without damaging the effectiveness of our work, so that we can meet your requests as often as possible.

To find out more information

If you would like to know more about how your information is used, how we maintain the security of your information and your rights to access information we hold on you, please contact:

The Data Controller
National Sports Centre,
Groves Rd,
Douglas,
IM2 1RB Tel: 688550 / Email: [email protected]

Alternatively, you may wish to speak to:

The Data Protection Officer, Department of Education, Sport & Culture. Hamilton House, Douglas. Isle of Man IM1 5EZ. Email: [email protected]

If you wish to complain about any aspect of our privacy policy or our use of your data you have the right to complain to the Information Commissioner at P.O. Box 69, Douglas, Isle of Man, IM99 1EQ Telephone: +44 1624 693260 Email: [email protected]

Changes

We keep our privacy notice and data protection procedures under regular review. This privacy notice was last updated on 28/12/2017.