Wakefield Council Privacy Policy

Aspire Leisure Centres and Facilities Privacy Notice

Here at Wakefield Council, we take your privacy seriously and will only use your personal information for the purposes listed below. Our Aspire membership is a leisure membership scheme for Wakefield residents. The scheme gives the cardholder access gym, swimming and classes at our six leisure sites across the district. This notice provides details of how the Council collects and uses information about you in relation to your use of our Aspire Leisure Centres and Facilities.  
 

  1. Who we are:

The Data Controller for the information we hold is Wakefield Council. The Council’s Data Protection Officer is the Corporate Information Governance Team Manager. They can be contacted on:

Telephone:  01924 306112
Email: dataprotection@wakefield.gov.uk
 
 
  1. What personal information do we collect?
In order to manage your Aspire Membership or ‘Pay and Play’ Aspire account the Council’s Sport and Health Improvement Service may process the following categories of personal data in relation to your membership and subsequent access/usage of our facilities:
  • Name
  • Age
  • Date of Birth (D.O.B)
  • Gender
  • Address
  • Contact details (email address and telephone number)  
  • Financial Information to facilitate payment of membership or ‘Pay and Play’ sessions
  • Photos

We may also process the following types of personal category information:
  • Health and/or medical information  

  1. Why do we collect your personal information?
We will process your personal information for the following purposes:
  • To facilitate service delivery and improvement across the Council’s health and fitness facilities offer
  • To manage your Aspire membership or ‘Pay and Play’ access including the collection of payments
  • To manage access to our leisure facilities including class bookings
  • To communicate with you regarding your membership and any resolve customer enquiries or respond to feedback etc.
  • To add your image to your account so that you can be identified as a member and therefore granted access to our facilities
  • To ensure the health, safety and security of our visitors via the use of CCTV and our recording of incidents and accidents etc.
  • To capture images of your participation in leisure and fitness activity and use this in our marketing/promotional material (upon receipt of your consent)
  • To send you marketing and other communications that may be of interest to you, including information about our leisure services, new events and programmes (depending on your communication preferences)
  • To invite you to share your opinions, experiences and feedback through electronic surveys.
 
  1. Who do we share this information with?
To enable us to provide the above service to you, we may need to share your information with other third-party organisations. We will share your information with the following:
 
  • Public Health team within the Council in order to report on positive health outcomes
  • Health and Fitness Apps including Aspire Health and Technogym – individual consent is sought on registration to these apps.

Health & Fitness Data:
  • The apps collect and processes limited health and fitness data only as necessary to provide core fitness and activity-tracking functionality.
  • Subject to user consent, this may include workout and activity information such as activity type, duration, distance, time, calories burned, step counts, and activity statu obtained from system health platforms, including Google Health Connect on Android and Apple Health on iOS.
  • The data is used solely for displaying activityhistory, generating fitness insights, enabling in-app challenges and supporting app functionality
  • Health and Fitness data is not used for advertising, marketing or profiling, is not sold or shared with third parties, and access permissions may be reviewed or revoked at any time through device settings
  • The app does not collect or process sensitive health or medical information

We will only share the minimum information necessary for the purpose and subject to the appropriate safeguards.
 
  1. What authority does the Council have to collect and use this information?

Wakefield Council relies on the following lawful bases to process your personal data:

UK GDPR Article 6 (1)(a) – the data subject has given consent to the processing of their personal data for one or more specific purposes

UK GDPR Article 6(1)(b) - processing is necessary for the performance of a contract  

Where we process information, which is ‘special category’ data, we will also rely upon the following lawful basis:

UK GDPR Article 9(2)(g) - processing is necessary for reasons of substantial public interest with processing meeting Schedule 1, Part 2 of the Data Protection Act 2018 as below:
 
  • (16) Support for individuals with a particular disability or medical condition

  1. How long will we keep your data?
We will hold your information according to the following retention periods:

DataRetention period
Membership details12 months after end of membership
Pay and Play account12 months after last visit
Usage information i.e., booking and attendance records12 months after the last booking
CCTV28 days
Health and Safety records (accident book)3 years
 
  1. Your rights and your personal data

Under the UK GDPR you have the following rights:

Right of Access
You have a right of access to the personal information that the Council holds about you, and/or the right to be given a copy of the data undergoing processing.

Right to Rectification
You have the right to request that the Council corrects any personal data if it is found to be inaccurate, incomplete or out of date.

Right to Erasure
Where we have relied on your consent for processing your data, you have the right to request your personal data is erased.

Right to Restriction of Processing
You have the right, where there is a dispute in relation to accuracy or lawfulness of processing of your personal data, to request that a restriction is placed on further processing.

Right to Portability
Where we have relied on your consent for processing your data, you have the right to request the Council transmit that data directly to another data controller, where possible.  However, this only applies to data that you have provided to us and not to all the information that the Council holds about you.

Right to Object to Processing
Where we have relied on the public interest basis for processing your data, you have a right to object to the processing.

Right of Complaint
You have a right to lodge a complaint with the Information Commissioner. The contact details are as follows:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number

To exercise any of your rights, you should contact the Data Controller’s representative as provided at the beginning of this notice.



 
  1. Transfer of data outside the UK

Generally the personal data that the Sport and Health Improvement Service processes is all held within the United Kingdom. However, some information may be held on computer servers which are located within other European Union countries.

The council uses the online platforms of Survey Monkey and Campaign Monitor for their electronic marketing and survey activities.  Both of these systems may transfer and store your data on servers located outside of both the UK and European Union. This will be made clear to you whenever we seek your consent to collect your personal data using this platform.  The council will ensure that there are appropriate safeguards in place to protect your data prior to sharing any details with platforms.
 
  1. Automated decision making
We do not use any of the personal information we collect to make automatic decisions which affect you.
 
  1. Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new Privacy Notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

For more information about how the Council uses your data, including your privacy rights and the complaints process, please see our Corporate Privacy Notice.