Virtue privacy notice – members and volunteers
Virtue is the data controller and is committed to complying with our legal responsibilities under data protection law. We take your privacy seriously and will ensure your personal information is kept secure.
When we collect, use, share, retain or do anything else with your personal information (known collectively as ‘processing’) we are regulated under the General Data Protection Regulation (GDPR) and are responsible as ‘controller’ of your information.
This notice applies to you if you are:
- An existing or prospective member of our club
- A person with parental responsibility for a member named on our system
- An existing or prospective club coach, volunteer or official
It is important that you read this carefully as it contains key information about how we use your personal data and your associated rights.
Virtue is a Limited company. We provide the opportunity for our members to participate in our activities, which include recreational classes, training, camps, competitions, squads and other similar gymnastics activities.
We register with British Gymnastics (BG) who governs the sport, provides insurance for clubs and individual members and offers competitions and events. It is a condition of BG and club registration that all our club members also register as individual members of British Gymnastics.
We also affiliate to Southern Region who runs competitions and events in which we may participate.
Information we collect about you
The categories of personal information we process for members includes:
- Contact name and contact details (gymnast or parent details and emergency contacts)
- Gymnast date of birth
- Gymnast gender
- Any relevant medical conditions and/or disabilities and additional related information
- Other relevant individual needs for example, information about learning, religious or other support needs.
- BG collects the above information also when you join or renew your BG membership
- Any individual risk assessments (gymnasts and others if applicable)
- Details of any reasonable adjustments or steps taken to support your individual needs
- British Gymnastics membership details (which are confirmed by British Gymnastics when you join or renew)
- Gymnast attendance and achievement records
- Any communications from, to or relating to you
- Details relating to standards of conduct
- Any accident or incident reports including details of injuries
- IP address, browser identifier and the time of access (if you use our website)
- Bank details
- Experience, qualifications, training and confirmation that you have completed a criminal record check
Our purposes for processing information about you
We use the information we hold about you for a variety of purposes which are outlined below. Data protection law requires us to tell you what our legal reason is for each purpose.
When you ask us to provide you a service, gymnastics classes, competitions, trips or other activities we usually need to use information about you to provide this service, for example:
- To contact you to confirm arrangements
- To notify you about changes to terms and conditions
- To tell you when it is time to renew membership or re-register for activities
- To process payments or send you receipts required
We do so because it is necessary for the performance of a contract.
We have a duty of care to ensure it is safe for you or your child to take part in gymnastics activity and to keep you/them safe while participating. Some individuals may be at risk of harm from participating in gymnastics activity as a result of a pre-existing condition. It is vital that you let us know if there is any reason why taking part in gymnastic activity may be unsafe prior to participation. With your agreement, we will review any information you provide and undertake risk assessments in consultation with yourself and any appropriate trained professionals e.g. medical consultants. When we ask participants to provide relevant health information such as details of medical conditions, medication needs, allergies or injuries, this is because we have a legal obligation.
If you are selected for a role at the club, we will usually obtain a reference from any appropriate organisation or individual you have nominated.
When you tell us about any special needs such as disabilities or other support information we may use relevant information to comply with our legal obligations under the Equality Act 2010. We will review any information you have provided to help us identify any actions we can take to support inclusion. We may need to ask you for more information to help us to best meet your or your child’s needs. We will keep a record of any steps we take to support inclusion.
If you are wishing to volunteer or work for us, we may need to ask you to complete a criminal record check as we have a legal obligation to do so. We jointly control the checking process with British Gymnastics who is responsible for the assessment of any content on the check and will only share information with us where it is appropriate. For example, if you are considered by British Gymnastics to be unsuitable to take on the role, we may share relevant and proportionate information about criminal offences where it is deemed that while you are not considered unsuitable to take on the role, if it is considered necessary for safeguarding purposes.
When we retain information about you, even after you are no longer taking part in gymnastics activity, this is often because we are required to do so by law such as records we are required to keep for business and accounting purposes. Sometimes we are also legally obliged to share information about you with third parties. More information it provided below.
Covid 19 test and trace
As per government guidelines we may have to share your data with test and trace in the event of a positive covid result. The NHS Test and Trace Service is set up to track down potential infected people and inform them to self-isolate for 14 days. If a person tests positive for Covid-19 then they will be contacted, and all their contacts will be traced. Anybody who has been in contact with an infected person will then be told to self-isolate for 14 days and will be required to get a test immediately. If they test negative, they are then not required to self-isolate.
The club has a responsibility to maintain registers of staff and members who are in the facility and a note of the date and time they have been in the facility. If somebody who has been in our facility tests positive for Covid-19, the NHS test and trace may ask the infected person or their carer to provide details of anyone they have been in contact with (Name and contact number). These registers will assist in this process.
It is now a legal requirement for all our venues in England to display the official NHS QR code poster.
We rely on legitimate interests for the following purposes:
- Responding to communications, concerns or complaints and seeking feedback from you about our services.
We will use the information you provide to respond to any comments or questions you raise and where appropriate to undertake investigations into any complaints or concerns. On occasion, we may contact you to seek your views on the services we provide.
- Holding emergency contact information
When you join the club, we collect contact details. We also ask you to provide an emergency contact which we will only use in exceptional circumstances if we are unable to contact your primary contact e.g. a parent.
- Maintaining attendance registers, award records and waiting lists
For health and safety purposes and club records, we need to maintain a register of those in attendance at training or other club activities.
If there are no places in the club, we can place you on our waiting list and will contact you using the details you provide to inform you when a place is available.
- Entering you into a competition and providing results
If you wish to take part in a competition, your information (usually your name, date of birth and gender) will be used to enter you into the appropriate category and your score will be recorded. Results of competitions are normally published on our social media pages.
If you wish to enter a competition organised by another gymnastics body, including British Gymnastics, Regional and County Gymnastics Association we will provide your information to the organiser to enable you to take part in the competition or event that they are organising.
- Monitoring performance and undertaking fitness assessments
If you or your child is a squad gymnast, we will need to collect additional information about you/them. We track and monitor gymnast’s performance in training, trials and competition and undertake regular fitness assessments. We may require additional information about lifestyle and education if you or your child are/is training at an elite level and requires time out of school or lifestyle.
- To monitor that you have completed any required safeguarding training and criminal record checks
If you undertake a role where a criminal record check and safeguarding training are required, we will receive confirmation from British Gymnastics if your check is approved and that you have completed the required safeguarding training.
- Filming for coaching purposes
On occasion, we may film gymnasts e.g. during a gymnastics session for coaching purposes. Videos taken at training sessions for individual coaching purposes will not be used for any other purpose without prior consent.
- Photography and filming at large club events to promote the club
At our large club events such as our annual club competitions and club display, we take photos to promote club activities and may film the event to create a DVD. We publish images on our website, social media account and in our communications. Any images of children will be published in line with BG safeguarding policy.
Upon club registration you will let us know if you do not wish to be filmed or photographed or do not want your image to be published. While we can usually take steps to prevent you from being photographed or filmed at training and small club events, please bear in mind that at our large public events, it may be difficult to avoid capturing you in footage. However, we always review all photographs prior to publication and we will ensure any images of you are deleted.
If we are filming or taking photos for any other purpose we will only do so if you have given your consent.
Special categories of personal data
Special categories of personal data are a category of information that is more sensitive and requires greater protection. Some of the information we process falls into this category (e.g. health/medical data or any information you provide to us about a disability or your religion, race or gender identity). It is unlawful for organisations to process this type of information unless an additional legal condition applies. We will only process this type of information if one of the following applies:
- You have given your explicit consent or have made this information public;
- We are required to do so to establish, exercise or defend a legal claim;
- We are required to do so to comply with employment or social security or social protection law;
- There is a substantial public interest in doing so; or
- It is in your vital interests and you are unable to provide consent e.g. if you are unconscious or do not have sufficient mental capacity.
With your consent, we will send you our newsletter and other information about our additional activities: half term workshops, holiday camps and competitions. We will send you this information by email.
You can ask us to stop sending you this information at any point by clicking unsubscribe. It may take up to 21 days for this to take place.
Why we share information about you
We have a legitimate interest in sharing your personal information with British Gymnastics to ensure the sport is safe and well-governed and where relevant to access support and advice.
We may also be required to share your personal information in the following reasons:
- Complying with legal and/or regulatory responsibilities
We may be required to share information with bodies such as Her Majesty’s Revenue & Customs (HMRC), Health & Safety Executive (HSE), Police and Information Commissioner’s Office (ICO). 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 are protected from harm and will be carried out in accordance with the law and relevant government guidance.
- Obtaining legal or professional advice
- Obtaining a service from a third party
All service providers are contractually required to ensure your information is secure and cannot use this information for their own purposes. Where we are required to share information with them to provide the service, we only disclose information that is strictly necessary to deliver the service.
Except for the above, will only share your information with any other third parties with your prior agreement.
You have important rights under data protection law. In summary these include:
- To be informed about how your information is processed
- To access any personal data held about you
- To have your data rectified if it is inaccurate
If you think that any of the information we hold is inaccurate, you can ask that corrections are made. 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)
If you do not renew your membership or cease to have a relationship with the club, we will delete any information you provided within [two years] except for any financial/accounting records which need to be retained for six years in line with UK tax law. Additional information that has been provided solely for the purpose of participating in a specific activity will be deleted after the event
Video footage that has only been taken for coaching purposes will be retained only for as long as it is required for that purpose and in most cases, will be deleted within [one month].
Photographs and other video footage captured for promotional purposes will be retained for up to [4 years old]. After this time, they will be deleted unless we consider them to be of public interest and should consequently be archived for historical purposes. Where images have been published on social media, these platform providers may continue to process your data after the retention period has lapsed.
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.
- 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 portability
If you wish to move to another club, you can transfer your information to another club registration by logging into ‘My Account’ on the British Gymnastics system. Alternatively, if you wish to leave the club, the information you provided on behalf of our club will be archived on the British Gymnastics system for 60 days and will be deleted after this has lapsed. During this period, you can transfer your information to another club. This may be limited to your club membership
- To object to:
- Any processing based on legitimate interests
The right to object is specific to the data subject’s particular situation. 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.
- Your personal information being used for direct marketing activities
You can object to our direct marketing activities by unsubscribing from the relevant communication as described above in the marketing section of this notice.
To exercise any of your rights or if you have any questions about our privacy notice please contact:
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 the privacy notice
We keep our privacy notices under regular review.
We may change this privacy notice from time to time, the most recent copy will always appear on our website.