Privacy

RFC Recreation Club Limited (The Rec Club) is a stimulating and affordable gym providing a range of classes, a pool and room hire. It is one of many services provided to the local community, including staff and patients of the Royal Free London NHS Foundation Trust (RFL), enabling everyone to benefit from access to a pool, classes, and the fitness room at an affordable rate, including a discount for NHS staff.

RFC Recreation Club Limited is a company registered in England and Wales (07686541) and registered as a Data Controller with the ICO (ZA639731)

Royal Free Charity
Pond Street
London
NW3 2QG

The Data Protection Act 1998, the UK General Data Protection Regulation 2023 (UK GDPR) and the Privacy and Electronic Communications Regulations (PECR) 2003, protect individual data subject and give them certain rights in relation to their personal data. This notice is to provide you with details on how we process your personal data in line with the above legislations.

In accordance with the UK GDPR, personal data is any data from which a living individual can be identified – either from the information itself, or when combined with other separate pieces of information. This includes data held electronically and in manual records (e.g. paper files and other media).

There are other personal data which the ICO has defined as ‘Special Category Data’ (SCD), they are:

• racial or ethnic origin.
• political opinions or religious/philosophical beliefs.
• physical or mental health or condition.
• genetics or biometrics.
• sexual life.
• criminal convictions or the alleged commission of an offence; and
• trade union membership.

Explicit, informed consent will usually be required to process any of the above SCD, additional operational measures are in place to provide extra assurances around the confidentiality, integrity, and availability of these data types.

To perform our organisational function efficiently and effectively, we must handle many types of personal data, we may collect and process personal data of the following group:

• Members
• Staff
• Instructors
• General users
• Subscribers to our monthly newsletter
• Hirers of any part of The Rec Club

The personal data of which we may collect and process for membership management, facilities operations, and other general communications:

• full name
• employment status and job title
• contact information including email address and phone numbers
• demographic information such as postcode, preferences and interests
• information to confirm identity, specifically for membership purposes
• other information relevant to customer surveys and/or offers
• employment related details for job role applications.

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When joining as a member or booking one of our facilities, take up employment or provide a service as an instructor, you would enter into a contract of agreement (terms & conditions) where you provide your data in order for us to manage and maintain our contractual obligations (Article 6(1)(b)). Where you sign up for our newsletter or other communications, this would be within the scope of consent (Article 6(1)(a)). We may also process data in line with our legal obligations to comply with the Data Protection Act and other legal legislations.

Where you have provided explicit consent, you can request that this consent be withdrawn at any time, if you wish to do so, please inform us via contact details within the last section of this notice.

The UK General Data Protection Regulation sets out seven key principles which lie at the heart of the general data protection regime and should be followed in all handling of personal data, list below as defined by the ICO.

(a) processed lawfully, fairly and in a transparent manner in relation to individuals (‘lawfulness, fair-ness and transparency’)

(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’)

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)

(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)

(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the UK GDPR in order to safeguard the rights and freedoms of individuals (‘storage limitation’)

(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

It applies to all ‘processing’ of personal data, e.g., capturing, collecting, retaining, processing, disclosing, allowing access to, destroying and even simply holding, personal data.

We process all personal data in accordance with the above principles.

Personal Data will be kept in line with the UK GDPR principles, only while we have an appropriate legal basis and to comply with all relevant governing laws (Financial Act, Limitation Act etc).

Any account details associated with memberships will be retained on file until such a time when there are no outstanding balances and in line with the relevant legislations.

Our online membership management portal that also manages our hires and class bookings is run by Gladstone Ltd. Company Registration: 01548633. You can access their privacy policy here: https://www.gladstonesoftware.com/gladstoneresources#policies

The UK GDPR gives individuals eight data subject rights as listed below:

• Right to be informed: organisations must tell individuals what data is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties.
• Right of access: individuals have the right to request a copy of the information that an organisation holds on them.
• Right of rectification: individuals can correct inaccurate or incomplete data.
• Right to be forgotten: in certain circumstances, individuals can ask organisations to erase any personal data stored on them.
• Right of portability: in some circumstances, individuals can request that an organisation transfer any data that it holds on them to another company.
• Right to restrict processing: in some circumstances, individuals can request that an organisation limits its use of personal data.
• Right to object: individuals have the right to challenge certain types of processing, such as direct marketing.
• Rights related to automated decision making, including profiling: under most circumstances, individuals have the right to object to having decisions made about them by automated processes or profiling.

To exercise any of the above rights, please contact us in the first instance via the contact details in the last section of this notice.

If you have any queries or concerns about our use of your personal information, you should write to us at:

The Data Protection Lead, RFC Recreation Club, Fleet Road, London NW3 2QG

Phone: 020 7830 2848

Email: info-recreationclub@royalfreecharity.org

You can also complain to the ICO if you are unhappy with how we have used your data, their details:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Phone: 0303 123 1113

ICO website: https://www.ico.org.uk