Privacy Policy

Privacy Notice – How we use your information

1 Introduction

This notice is to help you understand how and why we collect personal information about you and
what we do with that information. It also explains the decisions that you can make about your own

Sylvestrian Leisure Centre (Sylvestrian Enterprises Limited) is a wholly owned subsidiary of Forest
School, Essex. We are committed to comply with the Data Protection Act 1998 and the General Data
Protection Regulation (GDPR) from 25th May 2018.

2 What is “personal information”?
Personal information is information that identifies you as an individual and relates to you. This
includes your contact details and financial information. We may also hold information
such as health information if these are shared by you in relation to some of our services.

3 Why may we collect personal data about you?

Mostly, we collect and process your data on the following lawful bases:

3.1 Contractual reasons, like processing a monthly direct debit payment or access to our
building and facilities

3.2 Legal Obligations, for example, if you should have an accident, we may need to provide
personal details to relevant health and safety authorities

3.3 Legitimate interests, such as ensuring your safety, the safety of others, and particularly
the safety of children.

3.4 Consent, for example, when you are asked whether you want to provide health information
that may assist, or be relevant to your training programme or when you indicate that you want to
receive news or information from us

We may, at times rely on other lawful bases to use your personal data, such as

3.5 Vital interest, in a life-threatening situation to you or another individual, where this
information could be potentially life-saving

4 What personal data we may gather about you

We may gather the following kinds of information about you


4.1 Information that you give us when you enquire, become a customer of ours or apply for a job
with us including name, address, contact details (including email address and phone number)

4.2 the name and contact details (including phone number) of your next of kin

4.3 recordings of calls we receive or make

4.4 information about complaints and incidents

4.5 information you give us when you make a payment to us, such as financial or credit card

4.6 other information received from other sources, including from your use of our website,
e-mail messages and correspondence, access records and CCTV footage on the premises

Where you have named someone as your next of kin and provided us with personal data about that
person, you are responsible to ensure that that individual is aware of, and accepts the terms of
this Privacy Policy.

5 How we use your data

We use your data to keep you informed of the services that you use, to keep in contact with you and
to manage your account with us. If you contact us by e-mail, in person, by phone or via our
website, we may keep a record of your contact information and enquiry, and use these to respond to

5.1 Booking information

We record the services and activities that you book from us, including the time, type of service
and other information to make sure that you get the service requested when you need it.

5.2 Banking and Financial Data

5.2.1 When you sign up for one of our memberships, we will store your bank account number and
sort code data where you select to have a Direct Debit mandate in place. When the Direct Debit
mandate finishes, we will remove this data from our operational systems within 30 working days.
5.2.2 We may share your information with debt recovery suppliers if you do not pay any fees owed
5.3 Service Feedback

We will record your feedback about our services.

5.4 Communications preferences

We will keep a record of your communication preferences and permissions regarding what kinds of
communication you want to receive from us.


5.5 CCTV footage and access control data

5.6 We use CCTV footage of the surrounding school premises and our facility to ensure the
safety of members, visitors and and users of the centre, and staff, pupils and parents of Forest
School, who share the premises, and use of the facility, with us. We also use it to secure our

5.7 We use access control data to ensure that only authorised members have access to the
facilities and services in the building, and to ensure their safety.

6 Personal data relating to children

Some of our services are used by children, including our Swim School, Holiday Activities and
Birthday Parties. Sylvestrian Leisure Centre may accept website registrations and collect personal
information about individuals under the age of 13. Children under the age of 13 must have a parent
or guardian’s consent before providing personal information to us. We do not wish to collect any
personal information without this consent.

7 How we store and protect your data

These are the basic guidelines we use to look after your personal data.

• We maintain secure systems to protect your personal information

• We respect your wishes about how we contact you

• We will update your information or preferences promptly when you ask us to

• We will respond fully to requests from you to see the information that we hold on you.

• We will not hold your personal information for longer than is necessary for our
legitimate business purposes.

• We follow strict procedures when storing or handling information that you have given

• We will never sell your personal information to a third party.

8 For how long do we keep your data?

We retain personal information as long as we consider it useful to contact you, or as needed to
comply with legal obligations. Where data is not needed for legal or statutory purposes, we will
delete this information at your request or at the latest, 7 years after you end your contract with
us. See the contacts section to request your data to be deleted.


9 What data about you do we share with others?

9.1 We jointly control your information together with our parent organisation, Forest
School, who also process information on our behalf, including:

9.1.1 Your account with us including monthly debit orders
9.1.2 Access control and CCTV records
9.1.3 Email communications
9.1.4 Legal communications

9.2 We make use of cloud-based email services (Microsoft) to communicate with you.

9.3 Our booking system is operated by who process the following information
about you:

9.3.1 Your membership details
9.3.2 Your booking information
9.3.3 Visits and access to our website and the booking system

Our information security is governed by the policies and procedures of Forest School, to ensure
that your data is managed securely, and that our other processors manage your data securely and in
accordance with Data Protection regulations.

We will only share data about you with any other organisations if it there is statutory or legal
requirement to do so.

10 Marketing Partners

Sylvestrian Leisure Centre will never sell your personal information to any third party for
marketing or other purposes.

In some cases, for example, when we run a Lifeguard Course or Swimming Teacher Course, we work in
partnership with another organisation to provide that service to you. In these cases, the partner
may contact you for marketing purposes if you have given the partner organisation your permission
to do so. The Course providers who fall into this category are:

• The Royal Lifesaving Society (RLSS)

• The Swimming Teachers Association (STA).

11 Keeping you updated

There are certain communications we need to send to you so we can provide an efficient level of
service to you. Sometimes these are important customer notices, which could include details of any
School events that may affect your journey to the centre, cancellation of a booking or class, or
closure of the centre for example. We will only send you these updates if you have given us your
permission to do so.


From time to time, we may contact you by email about promotions, new products or services that we
think you might find interesting. We will only send you these updates if you have given us your
permission to do so.

If you want to change your email preferences concerning the information you receive from us, you
can do so by sending an email to or by logging into your
account through Go to ‘Settings’ and then tick the relevant
boxes under the ‘Communications’ heading.

12 What decisions can you make about your information?

We respect you right to manage your data. Your rights are explained below.

11.1 Accuracy of data and rectification

We will always try to ensure the data we hold about you is accurate and relevant. If you believe
the information we hold about you is out of date or incorrect, please tell a member of staff or
send an email to .

12.1 Access to your information and subject action requests

You can also ask what information we hold about you and be provided with a copy. This is known as
making a Subject Access Request. We will also give you extra information, such as why we use this
information about you, where it came from and what types of people we have sent it to. This is
called a Subject Access Request. If you would like to make a request, please send an email to

12.2 Removing your data

If you are no longer a customer of Sylvestrian Leisure Centre and you wish for us to delete your
personal data, we will do this if there are no legal or statutory regulations requiring us to keep
this information. If you would like us to delete your personal data, please send an email to

12.3 Restricting the use of your data

You may restrict the use of your data in some cases. For example, if you tell us that the
information is inaccurate we can only use it for limited purposes while we check its accuracy.

12.4 Complaints about how we manage your data

If you are not happy about the way we manage your data, please contact us by email to . Your complaint will be investigated and we will get back to you as soon as

13 Information Commissioner’s Office (ICO)

The ICO is the UK’s independent authority set up to uphold information rights. You have the right
to contact them should you wish. Details can be found on their website:

14 Changes to this privacy policy

This policy may be updated from time to time on this page. If you have any questions or comments
about our Privacy Policy or how we use your personal information, please email .

Document last updated: 15th May 2018

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