This policy should be read alongside Gym Juniors policies and procedures on child protection and safeguarding. The policy statement applies to all Gym Juniors staff, volunteers, children, parents, young people involved in Gym Juniors activities.
The controller of the images and personal information captured using the CCTV covered by this notice is Gym Juniors Limited. The images and personal information are captured using our CCTV system for the purpose of security, crime detection, public safety and any other legitimate reasons.
The purpose of this policy statement
This policy sets out how Gym Juniors uses your personal information which may be recorded on our CCTV system. This notice explains how we comply with the law on data protection and what your rights are and for the purposes of data protection laws we will be the controller of any of your personal information recorded on our CCTV system.
What information may we hold / process that will relate to you?
We may collect from you video recordings and still pictures which feature you and your child if in the field of vision of our CCTV system. This personal information may include your activities, your face, car registration details and other visual information about you which is recorded on our CCTV system.
What do we do with your personal information?
- We will collect personal information on our CCTV system and use it for the following purposes:
- For the prevention and detection of crime
- For evidence in any civil or criminal legal proceedings
- To assist in investigations
- For safety and security
- Dealing with any queries, complaints or enquiries
As well as being the purposes for which we use your personal information, all of the above are also legitimate reasons for us to use and store personal information relating to you which is captured on our CCTV system and legitimate interests is our legal basis for processing your personal information.
We may anonymise any of the personal information we hold on our CCTV system (so that it does not directly identify you, for example by obscuring your face) and it therefore ceases to be your personal information. We may use this anonymised information for any other purposes.
Who we share your personal information with
We share your personal information with the following parties:
- Suppliers and service providers: to manage and operate the CCTV system as our data processor.
- The police and other law enforcement agencies: to carry out policing, assist investigations, trace missing people and investigate alleged criminal activities.
The security services: where relevant for matters of national security.
- People who have been injured, attacked or had property damaged or stolen and their insurance providers: to assist them with any criminal or civil investigations or legal proceedings.
- People who have been involved in road traffic accidents and their insurance providers: to assist with insurance claims, legal claims and investigations.
- Any relevant regulators: where we are required to do so by law or to assist with their investigations or initiatives, and this includes but is not limited to the Information Commissioner’s Office.
We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell your data.
Transferring your personal information internationally
The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.
Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.
In limited circumstances the people to whom we may disclose personal information from our CCTV system as mentioned in the section above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.
How long do we keep your personal information for
We will keep your personal information for up to approximately 28 days after the recording was made. After this time the recording stored on the hard drive of our CCTV system will usually be overwritten.
However, if we receive an enquiry about a particular recording on our CCTV we will generally then retain that part of the recording until it is no longer required. This period can vary as it will depend upon the circumstances of the particular case, but for criminal or civil legal proceedings this could mean that the personal information is retained until after the legal case and any appeals have been concluded, which may be many years.
As soon as it is no longer required we will then delete the personal information.
Your rights in relation to your personal information
You have the following rights in relation to your personal information:
- the right to be informed about how your personal information will be used.
- the right to access the personal information we hold about you;
- the right to request the removal of inaccurate personal information about you
- the right to request the erasure of personal information in specific circumstances
- the right to restrict processing of your personal information where certain requirements are met;
- the right to object to the processing of personal information about you
- the right to request that we transfer elements of your data either to you or another service provider; and
- the right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights may not always apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored in our CCTV system and also other of these rights will not be relevant to personal information stored in a CCTV system.
There is no legal, contractual or other requirement or obligation for you to provide our CCTV system with your personal information.
More information about your legal rights can be found on this website https://ico.org.uk/for-the-public/.
Changes to this notice
We may update this privacy notice from time to time. You are encouraged to regularly check for any updated version of this privacy notice.
This policy can be found online at www.gymjuniors.co.uk or copies are available upon request. If you have any queries about this statement please contact us at Gym Juniors, Unit 2, 454 Gorgie Road, EDINBURGH EH11 2RN or by email Edinburgh@gymjuniors.co.uk