Our Privacy Policy PRIVACY NOTICE Introduction You have a legal right to be informed about how Greenhouse Sports uses any personal information that we hold about you. To comply with this, we provide a ‘privacy notice’ to inform you where we are processing your personal information. This privacy notice explains how we collect, store and use your personal information and what kind of information we hold. We, Greenhouse Sports, 35 Cosway Street London NW1 5NS, are the ‘data controller’ for the purposes of data protection law. Our Data Protection Officer is Rishi Varsani. Contact information is available below. Who we are Greenhouse Sports is a registered charity (Charity No. 1098744), founded in 2002, that delivers intensive sports coaching and mentoring sessions to help develop the Social, Thinking, Emotional and Physical (STEP) abilities of young people from disadvantaged communities. We work in almost 40 schools across London and manage a community sports centre in Marylebone. Information we collect and how we use it We may collect personal information such as your name, date of birth, email address, postal address, telephone number and, if you are making a purchase or donation, credit/ debit card details. Read more on the user type relevant to you below. Our Participants/ Members of the Greenhouse Centre Participants on our programmes: We collect your contact details and some statistical information to ensure we are fulfilling our charitable purpose, e.g. gender and ethnic background. Your safety is of paramount importance to us and therefore we collect details of any medical condition and emergency contacts. For more details, please see section 4 ‘Sensitive Personal Information’. Centre members: We collect your contact details when you create an account with us, allowing you to book classes and sessions online, and allowing us to program your electronic membership card to grant access to the facilities. We collect statistical information to ensure we are fulfilling our charitable purpose, e.g. gender, ethnic background, activity levels. We monitor your activity and usage of the facilities and use your contact details for marketing purposes to help improve our facilities, and offer classes appropriate to you. Your safety is of paramount importance to us and therefore we collect details of any medical condition and emergency contacts. For further details, please see section 4 ‘Sensitive Personal Information’. If you opt in to accept notices, you may receive email announcements, news updates or other specifically requested information. You may opt out at any time to stop receiving notices. Our donors We collect your personal information so we can: Process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions. Update you with important administrative messages about your donation, an event or services or goods you have requested. Send you relevant communications that you have opted to receive and are of interest to you, e.g. newsletters, information about campaigns or appeals. Invite you to participate in surveys. Comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, who requires us to identify and verify the identity of supporters who make major gifts so that we can assess any risks associated with accepting their donations. We will sometimes analyse the information we hold to build a picture of the kind of people who are supporting us. We may use external sources to help us keep your data up to date such as newspaper articles, Companies house, Linkedin and Debretts. Doing this ensures that we make the most efficient use of our resources, and enables us to invite you to our events and inform you of relevant fundraising campaigns. We also use publicly available information to find new potential supporters and invite them to be involved in supporting our cause through tailored communications. Analysis and segmentation of our database enables us to have a better understanding of our supporters. If you would prefer us not to use your data in this way, please let us know by emailing info@greenhousesports.org or calling 020 8600 9991. Our staff, volunteers and trustees We collect personal information concerning our own staff, volunteers and trustees as part of the administration, management and promotion of our charitable activities. Visitors to our Greenhouse Centre We require visitors to sign in at reception in order to control the building, particularly in the event of evacuation. We keep a record of visitors for a short period of time and our visitor records are securely stored, only accessible to Centre staff, for example, in the event of an incident. We have security measures in place at the Centre, including CCTV and Centre access controls. There are signs showing that CCTV is in operation. The images captured are securely stored and only accessed by a small number of approved staff (e.g. to review an incident). CCTV recordings are automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft or other incident). Visitors to our website We collect information through our website at several points. We may collect and process the following information: Information submitted through registration forms, newsletter subscription options and information that you provide when filling in any other forms on our site Details of your visit to our website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources you access Personal information provided by you about other people, for example, when applying for a membership or subscription on their behalf We use cookies for website statistical analysis. A cookie is a small text file that our web server places on your computer hard drive. Our cookies do not collect personally identifiable information. Some expire when you close your browser, and others do not expire. You can delete cookies anytime by consulting your browser help guide and searching for how to delete cookies. Suppliers We collect and process personal data about our suppliers (including sub-contractors and individuals associated with our suppliers and subcontractors) in order to receive goods or services for the benefit of our participants and staff and to complete our contractual duties, e.g. make payments. Others who get in touch with us We collect personal information when an individual gets in touch with us with a question, complaint, comment or feedback, such as name, contact details and subject. In these cases, we will only use the data for responding. Job applicants When you apply for a role at Greenhouse Sports, the information made available to you has details about why and how personal data is collected and processed. Sensitive Personal Information Data Protection Law recognises that some categories of personal information are more sensitive than others. The sensitive personal information we collect includes ethnicity, date of birth, health conditions, required medication, whether a child has Pupil premium or Free School Meal status and details of any safeguarding concerns that are reported to us. We collect certain sensitive data to: Ensure that all our participants are safe and protected whilst on our programme, including health conditions and medication; Enable us to understand who we are working with and ensure we are working with our target demographic. If you provide us with any sensitive personal information by telephone, email or by other means, we will treat that information with extra care and confidentiality and always in accordance with this Privacy Notice. We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation. Keeping your information safe We take the security of your information very seriously. We have implemented appropriate physical, technical and organisational measures to protect the on-line and off-line personal information under our control from improper access, use, alteration, destruction and loss. Under 18 To run our activities safely, we collect person information on our participants, many of whom are under the age of 18 years. Whenever we collect this data we will always gain parental or legal guardian consent. When and how we share personal data We will not sell or rent your information to third parties; and We will not share your information with third parties for marketing purposes. We may share your information with third parties who help manage our facilities, for example, a local authority or a sub-contractor. The information will be disclosed to provide the services you have requested, or to contact you about your membership or billing. We share anonymised data about facility usage and participant demographics with our funders and partner sponsors. The data does not contain any personal information that can identify you or your address. We will only disclose your personal information to third parties, the court service and/ or regulators or law enforcement agencies in connection with proceedings or investigations. How long we hold your information for We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example the collection of Gift Aid). We will hold your personal information on our systems for as long as is necessary for the relevant activity, or to the date specified in any contract you hold with us. Changes to this privacy notice We will keep this privacy notice under regular review and may make changes from time to time. It was last updated on 23 April 2018. Please check back from time to time to take notice of any changes we have made, as they are binding on you. Our legal basis for using your information In some cases, we will only use your personal information where we have your consent. However, there are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for Greenhouse Sports to process your information to help us to achieve our vision. Whenever we process your personal information under the ‘legitimate interest’ lawful basis we make sure that we consider your rights and interests and will not process your personal information if we feel that there is an imbalance. We may use publicly available information, for example, to find new potential supporters and to invite them to be involved in supporting our cause through tailored communications. This processing of publicly available personal information ensures that approaches are only made to people that may be interested in our cause. Your rights and how to exercise them You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights, please email us at dataprotection@greenhousesports.org. Access to your personal information: You have a right of access to personal data held by us. This right may be exercised by clicking here to find out how, using an online form if you prefer. You will need to provide us with evidence of your identity. Individuals will not be charged, unless the request is unreasonable, persistent or time consuming; in such circumstances a charge of £10 per subject access request will be levied. The data controller will aim to provide the relevant data within 14 days. Right to object: You can object to our processing of your personal information where we are relying on a legitimate interest and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time. Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you. Deletion: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it. Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in an electronic form, so it can be easily transferred. Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it. No automated-decision making: You can object to decisions being taken by automated means (by a computer or machine, rather than by a person). We do not currently carry out any automated decision-making. Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request. Complaints We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to dataprotection@greenhousesports.org. We will consider and respond to any complaints we receive. You also have the right to make a complaint to the Information Commissioner’s Office (“ICO”), the UK data protection regulator. For further information on your rights and how to complain to the ICO, please refer to the ICO website. Contact us If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Data Protection Officer at dataprotection@greenhousesports.org. BE A #GAMECHANGER Learn how sports is changing young people´s lives! 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