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British Gymnastics Foundation Privacy Notice

Your privacy is extremely important to British Gymnastics Foundation (the Foundation) and we are fully committed to providing you with clear and transparent information about how we use your personal data. We value the trust you give us when sharing your personal information. We will ensure robust measures are in place to keep your information secure and will only use it for the purposes outlined in this notice.

You can contact our Data Protection Officer (DPO) at [email protected] or at British Gymnastics Foundation, Lilleshall National Sports Centre, Newport, Shropshire, TF10 9AT if you have any questions.

This notice applies to individuals who engage with the Foundation’s work; including supporters, donors, grant beneficiaries, participants, volunteers, and any other individuals who contact us.

 

About us

British Gymnastics Foundation is a registered charity, founded by British Gymnastics, for the purpose of transforming lives through gymnastics. The Foundation is a Private Limited Company, registered in England and Wales.

Some of the services we provide are aimed specifically at British Gymnastics Members. In such instances, we work closely with British Gymnastics to ensure the people who have applied for our support meet any required criteria. We have a data sharing agreement with British Gymnastics that protects the rights and privacy of individuals and ensures that information shared with British Gymnastics is limited to what is necessary.

 

Our privacy notice explains:

  • When we process information about you and how we obtain it
  • Our legal reason for processing your personal information
  • How we use your information for contractual purposes
  • How we use information about you for legitimate purposes
  • Marketing
  • Other lawful reasons for using information about you
  • Why we share information about you
  • How long we keep information about you
  • Transfers of data out of the European Economic Area (EEA)
  • Your rights in respect of your personal information
  • Changes to our privacy notice
  • How to contact us

Our legal reason for processing your personal information

 

We will only use information about you when we have a lawful reason to do so. When we process your information, we rely upon one of the following lawful reasons:

  • To comply with a legal obligation;
  • To perform a contract with you or to take steps at your request before entering into a contract with you;
  • When it is in our legitimate interests or those of another third party, providing that these interests are not overridden by your own interests and rights; and
  • With your consent.

Special categories of personal data and criminal convictions/offences data

An additional condition is required to process special categories of personal data as it is more sensitive and requires greater protection. This includes information that reveals or concerns your health such as details of medical needs and disabilities and information about your race/ethnicity.

When we invite you to provide information about relevant disabilities and medical conditions, we do so because we have a legal obligation under the Equality Act 2010 to make reasonable adjustment for individuals with disabilities to support access to the requested service and, where you are taking part in a physical activity programme; a general duty of care to ensure you are fit to participate. As this information is special category personal data, we will usually only process it if we have your explicit consent.

We will also process special categories of personal data and criminal offences data:

  • For scientific research and statistical purposes;
  • If it is in your vital interests and you are unable to provide consent;
  • If we are required to do so to establish, exercise or defend a legal claim;
  • If there is a substantial public interest to do so; as set out Schedule 1 (Part 2) of the Data Protection Act 2018 including:
    • Equality of opportunity or treatment;
    • Providing support for an individual with a particular disability or medical condition
    • Safeguarding of children and individuals at risk

 

How we obtain information about you

Most of the personal information we use comes directly from you when you:

  • Register for or participate in a Foundation programme, course or event.
  • Contact us or subscribe to receive communications from us
  • Apply for a grant or inspirational experience
  • Register interest to become one of our programme deliverers
  • Volunteer for us or take part in fundraising
  • Donate to us to support our activities
  • Use our website or interact with us on social media

We receive personal information from other sources when it is provided:

  • In a grant application or correspondence.
  • By a relative or carer who registers you on one of our programmes.
  • By a participant or volunteer who gives your details as an emergency contact.
  • By a grant applicant, deliverer, contractor or volunteer who applies for a grant on your behalf (if you are a child) or provides your details as a referee.
  • In a compliment, complaint or allegation or in a subsequent enquiry.
  • [In a publicly accessible source e.g. an organisation website, social media and media publications]

If we obtain information about you from a source other than you, we will ensure you are provided with our privacy notice, when it is appropriate and proportionate to do so.

Additional information about specific purposes for using your information is provided below.

 

When we use your information for contractual purposes

When you apply to be a Love to Move Deliverer, enter a prize draw or competition, register for one of our courses or events, or if you are entering into a contract to provide services to the Foundation; we need to process your information because it is necessary for the performance of the contract with you or to take steps prior to entering into a contract with you. The purposes include:

  • To confirm you meet our terms and conditions, including complying with any registration and suitability requirements;
  • To confirm the agreed service and inform you of arrangements for the service;
  • To take payments or process invoices and sending you receipts/remittances as required;
  • To informing you of decisions or results, where applicable.

 

Love to Move Deliverers

When you register an interest to be a Love to Mover Deliverer, we collect information about you for recruitment, training, assessment & licencing purposes.

On receipt of your registration of interest, we will use your contact information to identify a suitable training course, register you and process any necessary payments. Once registered, we will create you an individual record, which you can access at any time and use to upload any necessary information via a secure portal.

On completion of your training and assessment, to meet our licencing criteria, we will ask you to provide information to confirm that you do not have a criminal record that we could consider makes you unsuitable to work with adults at risk; and that you are covered by public liability insurance. We will also maintain records of the training and CPD you have completed to maintain your licence.

We will retain your information for three years from the point that you cease to be a licenced deliver, unless we have another legal reason to continue to process your information for longer. We will retain any payment records for six years from the end of the tax year that the payment was made.

Safeguarding checks

Our Love to Move Programme is aimed primarily at people with people living with dementia and other degenerative, cognitive diseases; and we also provide activities that are aimed at children. If you will be working with children and/or adults at risk as either a licenced Love to Move Deliver or as a contractor on our behalf, we will need to ensure you are suitable to undertake this role.

We do this by requesting details of any criminal offences. In most circumstances, we will accept a recently completed enhanced criminal record check carried out by the Disclosure and Barring Service, or Access NI. If your criminal records check is not clear, we will ask you to provide more information and, with your consent will contact your existing or previous employer and any other relevant parties.

Any criminal offences information or information relating to these offences will be deleted within six months of the date it was provided, unless the assessment and decision has not been concluded in this time period.

 

Promotions, prize draws or competition

If you enter one of our prize competitions, we will process your entry in accordance with the terms and conditions and contact you if you are a prize winner. We will only publish identifiable information about you with your consent.

When we use your information for our legitimate interests or those of a third party

Love to Move Participants

The Love to Move programme is aimed primarily at people living with dementia and other degenerative, cognitive diseases, but carers and family members and other interested people are welcome to take part.

The Love to Move programme is part-funded by Sport England and delivered by the Foundation or by one of our Licensed deliverers.

When you attend a Love to Move session you will be asked to provide your name and any relevant information about your health and any additional needs. This information is required by the deliverer to ensure you are safe to participate and are provided with the appropriate support during the session.

As a condition of this funding, we also need to undertake research to monitor the impact and accessibility of the programme. To do this, we ask you to complete a separate questionnaire about your health (condition/disability type and impact on you), current activity levels, your postcode, age range and ethnic origin/race. We will also need information about when you have attended sessions. If your session is delivered by a licensed deliverer, they will collect this information on our behalf.

We aggregate and anonymise this information before providing it to CFE Research, who has been contracted by Sport England and our other research partners [ http://cfe.org.uk/app/uploads/Tackling-Inactivity-Evaluation_Privacy-Notice_Survey-Feb-2019.pdf ] to undertake an evaluation of the extent that Love to Move has a positive impact on activity levels of this age group. Before this information is shared with CFE Research, it is given a unique identifier and the postcode is assigned a score that measures the relative deprivation in that postcode area. This enables CFE and other researchers to measure the impact on individuals without needing access to any information that would identify the individual.

We will ask you for your explicit consent to use your information for these purposes except where a participant is considered (in accordance with the Mental Capacity Act 2005) unable to understand sufficiently to make decisions about how their information will be used. In such instances, their information can be used to provide support to them and for research purposes as there is a substantial public interest to do so.

The information you have provided to support your participation in the programme will only be retained while you continue to participate. The information provided for research purposes will be retained until the end of the funding period in October 2022, so that we can evidence the proper use of government funding.

Volunteering including fundraising

If you contact us to express interest in volunteering for us, we will also collect information about your background and experience, your interests, availability, access to transport and IT equipment and any special requirements.

We collect this information to enable us to find you an appropriate role and to provide you with support.

Donating to the Foundation

To process your donation, we will usually collect your name, email address, postal address, telephone number and payment details to enable us to process your donations.

If you have indicated that you are happy for us to reclaim the basic rate tax back from HM Revenues and Customs on your donations through the Gift Aid scheme, we will need to confirm that you have paid sufficient tax in the relevant financial year.

Hardship Grants

If you apply for a grant, we will use the information provided to assess your eligibility, and if successful, to make payment of the funds and monitor that you comply with the terms and conditions of the grant.

British Gymnastics members are eligible to apply to the Foundation for a hardship grant if they find themselves in a position where they may be struggling to continue with gymnastics. This may be due to significant financial hardship, ill health, disability, bereavement, poverty, trauma or another form of hardship.

To confirm eligibility for a grant, you are required to complete a detailed application form setting out the circumstances of your hardship. This usually includes information about your gymnastics participation and inspirational gymnastics wish, family life, roles and responsibilities, employment history and/or information about education, financial position including breakdown of gymnastics-related costs and grant requested. It also often includes information that is a special category of personal data such as information about health, including disabilities and medical conditions.

If the information includes any special category of personal data, we will also need your explicit consent, which you can withdraw at any time.

Except for the individual named as your endorser, it is generally not proportionate for us to contact anyone whose information you have provided in your application. If you consider it necessary to provide information about an individual other than the grant recipient or the British Gymnastics members who will directly benefit, we would suggest that you check that those individual whose information you are providing have no objections.

The Foundation’s Board are responsible for deciding whether you meet the criteria for a grant and will seek confirmation from British Gymnastics that you hold current membership and to verify any other gymnastics specific information that you have provided in your application e.g. qualifications, performance level.

 

Other Grant Giving

From time to time, British Gymnastics Foundation distributes Exchequer funding allocated to us by Sport England, for purposes such as financially supporting the establishment of new Love to Move Community structures/sessions. If your organisation applies for such a grant, we will use the information provided to assess your eligibility, and if successful, to make payment of the funds and monitor that you comply with the terms and conditions of the grant. The specific terms and conditions of individual grant programmes are shared with applicant organisations.

 

Inspirational Experiences

On occasion, we may contact you if you have received a hardship grant or have approached us for support to offer you an inspirational experience. If you accept the offer, we will need additional information about you to arrange the experience and cater for your needs. With your consent, we will take photographs and/or video footage and use your personal story and testimonials to promote the Foundation.

 

Photography and film

We use images to promote the Foundation on our website, on social media, in our publications and promotional material and in general media (e.g. newspapers, magazines, outlets) and awareness films or by our corporate partners who help us raise money to support the Foundation.

At large public events organised by the Foundation, we take photographs and often video footage. If you are attending one of these events, we will ensure you are informed in advance and will provide appropriate notices to ensure those present on the day are aware that photographers are present. If you do not want your photograph taken, please let us know so that we can take steps to accommodate this request or ensure that any images of you are not published.

At small events, such as our courses or inspirational experiences or where we wish to create a case study, we will ask for your consent. We will also ask for your consent to use an image where you are the focus, taken at an event, for a purpose that you may not reasonably expect. If you change your mind, you can withdraw your consent at any time.

Unless we have informed you in advance or we re-permission images, we will retain photographs and images for a maximum of five years, after such time they will be deleted or retained in our archives for historical purposes.

 

Responding to your questions, requests and support needs you raise in person or by telephone, email or letter or via our website.

When you make an enquiry to us via our website, phone, email or through social media, we may require the following information from you in order to make contact with you and provide you with the information or service which you require. If you don’t provide this information, it may affect our ability to provide you with what you require.

We may compile anonymous statistical reports showing information like the number and type of query and how they have been resolved. Occasionally we will use information provided to develop case studies for learning and development purposes. We will be very careful to ensure that any information that could identify a person will be removed or changed to preserve anonymity.

We will maintain a log of any important calls, emails and correspondence requesting support on our CRM system.

If you contact us requesting specific information, we will respond to you using the contact information we hold.

 

Monitoring the use and effectiveness of our website, communications and IT systems.

We monitor whether our electronic communications are received and opened. We also use your IP address to analyse the number of users who are accessing the IT systems at any one time and the types of device being used. This information helps us to make improvements to our systems and communications. We would not normally use IP addresses to identify individuals except if this is deemed to be necessary to investigate problems or potential misuse of the system.

In using our website, we also use cookies which are small text files that are stored on your PC, phone or other web-enabled device when you visit the site. Cookies are an essential part of how our website works – they are needed to help provide you with a quick, responsive and personalised web experience; and also help us to understand how you use our website, so that we may analyse this to make improvements to our website.

Based on how you use our website, some of our cookies will be used to send you marketing information on Facebook which is relevant to the areas you have visited on our website and the interactions you have had on our website. You will only receive our marketing on Facebook if you have set your Facebook ad preferences to allow this. For example, if you have visited our Love to Move page and downloaded our Love to Move booklet, are a Facebook user and have set your ad preferences to receive our marketing, you are likely to see advertising on Facebook which invites you to participate in a survey to tell us about how the booklet has benefitted you, to help us understand the impact of our charitable work.

See our Cookies Policy here:

[ https://britishgymnasticsfoundation.org/cookie-policy/ ]

 

Seeking feedback from you about our services

If you participate in one of our charitable programmes or events, we may ask you to provide your views on this experience which we will use to improve this service. You can provide this information to us anonymously but if you would like us to contact you about your feedback, you can provide your name and contact details.

We have carried out legitimate interest assessments (LIA) to ensure that the above processing activities are necessary and are carried out in a way that ensures a balance of our interests and those of any other relevant third parties in processing information about you and your own individual interests, rights and freedoms in respect of this information. As part of these assessments, we have identified appropriate safeguards, especially to protect the interest of data subjects who are children or are vulnerable for another reason. We can provide details of these assessments on request.

You have the right to object to any of the processing we undertake based on legitimate interests based on your own individual circumstances. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing, which override your individual interests, rights and freedoms or we need to continue to process your information in connection with a legal claim. If you wish to object to any of the processing activities we undertake based on legitimate interests, you can contact our Data Protection Officer (DPO). Please bear in mind that in some cases, if you object, this may affect our ability to carry out the tasks above for your benefit.

 

Marketing

With your consent, we will contact you by email or in line with your communication preferences where applicable to send you the latest news and information about our charity that we believe may be of interest to you. We use Mailchimp, a third-party provider to manage our marketing communications.

We do not intentionally seek to direct our marketing to children but will confirm that anyone subscribing is over the age of 13, which is the minimum age in the UK that children are able to provide their own consent to online services.

It is our legitimate interest to ensure that we only send you information that we believe will be of interest to you. By looking at your role as well as any other relevant personal information you have provided, we can identify news, offers and services that are most likely to be most relevant and will meet your needs.

When we send you marketing communications, we monitor whether you have opened the communication and clicked on any included links. This will enable us to track and analyse your level of engagement/interest in the communication we are sending you and will provide us with further insight on what type of communications are of most of interest to you.

If you agree to marketing, and later change your mind, you can opt out at any point, by using the ‘unsubscribe’ link at the end of the electronic communication. Please note that you may still receive communications for a short period after changing your preferences but this will stop as soon as our systems are updated.

Other lawful reasons for using information about you

We may need to process information about you to comply with a legal or statutory obligation. This includes but is not limited to:

  • Accounting, auditing, compliance and administration practices.
  • To maintain records of amendments to consents and to create suppression lists, to ensure people who object to processing are excluded from the relevant processing activity.

 

Why we share information about you

We may need to share limited personal information with the following organisations:

Statutory/regulatory authorities and other organisations

On occasion, it may be necessary to share information with bodies such as the Health & Safety Executive (HSE), Information Commissioner’s Office (ICO), Disclosure and Barring Service (DBS) or Access NI and the NSPCC, Police or Children’s/Adult’s services. We may also share information with other organisations to safeguard children. Any information that is shared will be strictly limited to what is required to ensure children or vulnerable adults are protected from harm; and will be carried out in accordance with the law and relevant government guidance.

Professional and legal advisors

External service providers who are contracted to provide specific services on our behalf

We use the services of third-party providers to help us in areas such as:

  • Electronic marketing communications e.g. Mailchimp
  • IT services and cloud storage e.g. Microsoft 365 and Microsoft Dynamics 365
  • Providing learning and development activities
  • Photography and filming activities

In some cases, we may be required to share your personal information, such as your contact details with the external provider. We limit the personal data that we share to the minimum required to provide the service and the provider will only be able to use personal data for the specific purposes for which it was shared. If we stop using the service we ensure your data is deleted or securely returned to us.

How long we keep information about you

We will retain your personal data only as necessary to provide the services to which you have subscribed or where we have another legitimate and lawful reason to do so. At your request we will delete any information that we no longer have a reason to retain, unless you ask us not to.

We retain some information to comply with our legal obligations, such as financial/accounting records which need to be retained for six years in line with UK tax law.

We may need to retain other information to comply with legal or statutory requirements, some of which are highlighted in this notice.

As the reason for retaining certain types of information varies, the retention periods can vary significantly. Please contact our Data Protection Officer (DPO) if you require any further information on specific retention periods.

 

Transfers of data out of the EEA

We transfer your personal information to third-party data processors who are based in the countries outside the European Economic Area (EEA).

We use some US-based companies that provide services such as data analytics and marketing communication. We only use US-based organisations that are self-certified as adhering to the EU-US Privacy Shield.

We will not transfer your information to any processors based in other countries outside the EEA unless there is a European Commission adequacy decision for the specific country to which the data is transferred; or where we can be certain that there are adequate safeguards provided for your information and individual rights standards that meet the GDPR requirements.

Please contact our Data Protection Officer (DPO) if you require any further information relating to international transfers.

 

Your rights in respect of your personal information

You have important rights under data protection law. In summary these include:

To be informed about how your information is processed

We hope that the information in our privacy notice has achieved this, but please contact our DPO if there is any additional information you require.

 

To access any personal data held about you

  • You can request a copy of any personal information that we hold by writing to our DPO.
  • You have the right to see the personal information we hold about you. This is called a Data Subject Access Request (DSAR/SAR).

If we do hold information about you, we will:

  • Describe the information we hold and tell you why we are holding it;
  • Tell you who it could be shared with; and
  • Provide you with a copy of the requested information in an easy to understand format. Alternatively, if your request is straight forward, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone where appropriate.

To have your data rectified if it is inaccurate

If we do hold information about you, you can ask us to correct or amend any inaccurate or incomplete information by contacting us in writing at the address below. We will either make the requested amendments or provide an explanation as to why we are not making changes.

 

To have your data deleted (except if there is a valid lawful reason to retain it)

You have a right to request the deletion of your information in advance of the above retention periods. We will delete this information unless there is a lawful reason for the information to be retained.

Where you have given us your consent for your personal information to be used for a particular purpose, you have the right to withdraw this consent at any time. You may do so by contacting us using the contact details below. Your withdrawal of consent will not affect any use of the data that was made before you withdrew your consent.

 

To have your information restricted or blocked from processing

If you object to processing, we will restrict the processing of your information for the purpose to which you are objecting whilst we review your objection.

 

To object to:

  • Any processing based on legitimate interests
  • Any automated decision-making including profiling (which is only undertaken for marketing activities)
  • Your personal information being used for direct marketing activities

If you object to any direct marketing we undertake, including any profiling we undertake related to this activity (where we decide that a communication would be of interest based on your membership profile) we will no longer use your information for these purposes.

While we hope to be able to resolve any concerns you have about the way that we are processing your personal data, you have the right to lodge a complaint with the Information Commissioners Office (ICO) if you believe your data has been processed in a way that does not comply with the GDPR or have any wider concerns about our compliance with data protection law. You can do so by calling the ICO helpline on 0303 123 1113 or via their website.

Changes to our privacy notices

We keep our privacy notices under regular review. This notice was last updated on 15th November 2019.

How to contact us

We hope that you have found this information helpful, but if you have any questions or concerns, please contact our Data Protection Officer (DPO) who will be pleased to help you.

Data Protection Officer

British Gymnastics Foundation

Lilleshall National Sports Centre

Nr Newport

Shropshire

TF10 9AT

[email protected]