Regis Gymnastics

1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website or electronic/paper forms (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to us when registering with our website or electronic/paper forms (including your email address);
(c) information that you provide when completing your profile on our website or electronic/paper forms (including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details);
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(e) information that you provide to us when using the services on our website or place of business, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
(f) information relating to any purchases you make of goods and/or services or any other transactions that you enter into through our website or place of business (including your name, address, telephone number, email address and card details);
(g) information that you post to our website or social media for publication on the internet (including your user name, your profile pictures and the content of your posts);
(h) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and
(i) any other personal information that you choose to send to us.
2.2 Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

3. Using personal information
3.1 Personal information submitted to us through our website, social media or other means will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available;
(d) send you goods purchased;
(e) supply to you services purchased;
(f) send statements, invoices and payment reminders to you, and collect payments from you;
(g) send you non-marketing commercial communication;
(h) send you notifications that you have specifically requested;
(i) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(j) send you marketing communications relating to Regis Gymnastics which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(k) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(l) deal with enquiries and complaints made by or about you relating to our website;
(m) keep our website secure and prevent fraud; and
(n) verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).
3.3 If you submit personal information for publication on our website and social media, we will publish and otherwise use that information in accordance with the license you grant to us.
3.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.4 Except as provided in this policy, we will not provide your personal information to third parties.

5. Retaining personal information
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
5.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

6. Security of personal information
6.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
6.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers or in locked physical cabinets.
6.3 All electronic financial transactions entered into through our website will be protected by encryption technology.
6.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy [by email or through the private messaging system on our website].

8. Your rights
8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
8.2 We may withhold personal information that you request to the extent permitted by law.
8.3 You may instruct us at any time not to process your personal information for marketing purposes.
8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. Cookies
11.1 Our website uses cookies.
11.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.3 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11.5 We use both session and persistent cookies on our website.
11.7 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
(b) in Firefox (version 47) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
(c) in Chrome (version 52), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.
11.8 Blocking all cookies will have a negative impact upon the usability of many websites.
11.9 If you block cookies, you will not be able to use all the features on our website.
11.10 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 47), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and
(c) in Chrome (version 52), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".
11.11 eleting cookies will have a negative impact on the usability of many websites.

12. Our details
12.1 This website is owned and operated by Regis Gymnastics CIC.
12.2 Regis Gymnastics CIC is a company limited by guarantee and registered in England and Wales under registration number 08430864 and our registered office is at 15 Hatherleigh Garden, Bognor Regis PO21 5HZ.
12.3 Our principal place of business is at Regis Gymnastics, 16A Durban Road, Bognor Regis PO22 9QT.
12.4 You can contact us:
(a) by post, using the postal address given above;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.

Closed Circuit Television (CCTV) Policy
1. Introduction
1.1 REGIS GYMNASTICS believes that CCTV and other surveillance systems have a legitimate role to play in helping to maintain a safe and secure environment for all of its staff and visitors. However, REGIS GYMNASTICS recognises that this may raise concerns about the effect on individuals and their privacy. This CCTV Policy is intended to address such concerns. Images recorded by surveillance systems are Personal Data which must be processed in accordance with data protection laws. REGIS GYMNASTICS is committed to complying with its legal obligations and ensuring that the legal rights of staff, relating to their Personal Data, are recognised and respected.

1.2 This policy is intended to assist REGIS GYMNASTICS staff in complying with their own legal obligations when working with Personal Data. In certain circumstances, misuse of information generated by CCTV or other surveillance systems could constitute a criminal offence.

2. Definitions
For the purposes of this CCTV Policy, the following terms have the following meanings:

CCTV: means cameras designed to capture and record images of individuals and property.

Data: means information which is stored electronically, or in certain paper-based filing systems. In respect of CCTV, this generally means video images. It may also include static pictures such as printed screen shots.

Data Controllers: means those people who, or organisations which, determine the manner in which any Personal Data is processed. They are responsible for establishing practices and policies to ensure compliance with the applicable law. REGIS GYMNASTICS is the Data Controller of all Personal Data used in REGIS GYMNASTICS’s business for REGIS GYMNASTICS’s own commercial purposes.

Data Processors: means any person or organisation that is not a Data User (or other employee of a Data Controller) that Processes Personal Data on REGIS GYMNASTICS’s behalf and in accordance with REGIS GYMNASTICS’s instructions (for example, a supplier which handles Personal Data on REGIS GYMNASTICS’s behalf).

Data Subjects: means all living individuals about whom REGIS GYMNASTICS holds Personal Data as a result of the operation of its CCTV.

Data Users: means those REGIS GYMNASTICS employees whose work involves the Processing of Personal Data. This will include those whose duties are to operate CCTV cameras and other surveillance systems to record, monitor, store, retrieve and delete images. Data Users must protect the Personal Data they handle in accordance with this CCTV Policy and REGIS GYMNASTICS’s Privacy Standard.

Personal Data: means data relating to a living individual who can be identified from that data (or other data in REGIS GYMNASTICS’s possession). This will include video images of identifiable individuals.

Processing: is any activity which involves the use of Personal Data, including obtaining, recording or holding data, or carrying out any operation on the Personal Data including organising, amending, retrieving, using, disclosing or destroying it. Processing also includes transferring Personal Data to third parties.

Surveillance Systems: means any devices or systems designed to monitor or record images of individuals or information relating to individuals. The term includes CCTV systems as well as any technology that may be introduced in the future such as automatic number plate recognition (ANPR), body worn cameras, unmanned aerial systems and any other systems that capture information of identifiable individuals or information relating to identifiable individuals.

3. About This Policy
3.1 REGIS GYMNASTICS currently uses CCTV cameras to view and record individuals on REGIS GYMNASTICS premises. This CCTV Policy outlines why REGIS GYMNASTICS uses CCTV, how REGIS GYMNASTICS will use CCTV and how REGIS GYMNASTICS will process Personal Data recorded by CCTV cameras to ensure that REGIS GYMNASTICS is compliant with data protection law and best practice. This CCTV Policy also explains how to make a subject access request in respect of Personal Data created by CCTV.

3.2 REGIS GYMNASTICS recognises that Personal Data that REGIS GYMNASTICS holds about individuals is subject to data protection legislation. The images of individuals recorded by CCTV cameras in the workplace are Personal Data and therefore subject to the legislation governing data protection, including the General Data Protection Regulation (GDPR).

3.3 This CCTV Policy covers all employees, directors, officers, consultants, contractors, freelancers, volunteers, interns, casual workers, zero hours workers and agency workers and may also be relevant to visiting members of the public.

3.4 This policy is non-contractual and does not form part of the terms and conditions of any employment or other contract. REGIS GYMNASTICS may amend this policy at any time. The policy will be regularly reviewed by REGIS GYMNASTICS to ensure that it meets legal requirements.

4. Personnel Responsible
4.1 The board of directors has overall responsibility for ensuring compliance with relevant legislation and the effective operation of this policy. Day-to-day management responsibility for deciding what information is recorded, how it will be used and to whom it may be disclosed has been delegated to the head of IT/IT director in the country. Day-to-day operational responsibility for CCTV cameras and the storage of data recorded is the responsibility of the IT department.

4.2 Responsibility for keeping this policy up to date has been delegated to the HR department, supported by the IT department and the legal department.

5. Reasons for the Use of CCTV
5.1 REGIS GYMNASTICS currently uses CCTV as outlined below. REGIS GYMNASTICS believes that such use is necessary for legitimate business purposes, including:

(a) to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;

(b) for the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime;

(d) to assist in day-to-day management, including ensuring the health and safety of staff and others; and

(e) to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings.

This list is not exhaustive and other purposes may be or become relevant.

6. Monitoring
6.1 CCTV monitoring varies from site to site, however, it is usually the communal areas of the building, and both the main entrance and secondary exits. This data is continuously recorded 24 hours a day.

6.2 Camera locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV cameras will not focus on private homes, gardens or other areas of private property.

6.3 Surveillance systems will not be used to record sound.

6.4 Images are monitored by authorised personnel. This monitoring is undertaken when required, not as a standard daily function.

6.5 Staff using surveillance systems will be given appropriate training to ensure they understand and observe the legal requirements related to the processing of relevant data.

7. How REGIS GYMNASTICS Will Operate Any CCTV
7.1 REGIS GYMNASTICS will ensure that signs are displayed at the entrance of the building to alert individuals that their image may be recorded.

7.2 REGIS GYMNASTICS will ensure that live feeds from cameras and recorded images are only viewed by approved members of staff whose role requires them to have access to such data. This may include HR staff involved with disciplinary or grievance matters.

8. Use of Data Gathered by CCTV
8.1 In order to ensure that the rights of individuals recorded by the CCTV system are protected, REGIS GYMNASTICS will ensure that Personal Data gathered from CCTV cameras is stored in a way that maintains its integrity and security. This may include encrypting the Personal Data, where it is possible to do so.

8.2 Given the large amount of Personal Data generated by surveillance systems, REGIS GYMNASTICS may store video footage using a cloud computing system. REGIS GYMNASTICS will take all reasonable steps to ensure that any cloud service provider maintains the security of our information, in accordance with industry standards.

8.3 REGIS GYMNASTICS may engage Data Processors to process Personal Data on our behalf. REGIS GYMNASTICS will ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.

9. Retention and Erasure of Data Gathered by CCTV
9.1 Personal Data recorded by the CCTV system will be stored digitally using a cloud computing system. Personal Data from CCTV cameras will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes, data will be kept long enough only for incidents to come to light. In all other cases, recorded images will be kept for no longer than 90 days.

9.2 At the end of their useful life, all images stored in whatever format will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.

10. Use of Additional Surveillance Systems
10.1 Prior to introducing any new surveillance system, including placing a new CCTV camera in any workplace location, REGIS GYMNASTICS will carefully consider if they are appropriate by carrying out a privacy impact assessment (PIA).

10.2 A PIA is intended to assist REGIS GYMNASTICS in deciding whether new surveillance cameras are necessary and proportionate in the circumstances and whether they should be used at all or whether any limitations should be placed on their use.

10.3 Any PIA will consider the nature of the problem that REGIS GYMNASTICS is seeking to address at that time and whether the surveillance camera is likely to be an effective solution, or whether a better solution exists. In particular, REGIS GYMNASTICS will consider the effect a surveillance camera will have on individuals and therefore whether its use is a proportionate response to the problem identified.

10.4 No surveillance cameras will be placed in areas where there is an expectation of privacy (for example, in changing rooms or toilets) unless, in very exceptional circumstances, it is judged by REGIS GYMNASTICS to be necessary to deal with very serious concerns.

11. Covert Monitoring
11.1 REGIS GYMNASTICS will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue.

11.2 In the unlikely event that covert monitoring is considered to be justified, it will only be carried out with the express authorisation of the Group General Counsel. The decision to carry out covert monitoring will be fully documented and will set out how the decision to use covert means was reached and by whom. The risk of intrusion on innocent workers will always be a primary consideration in reaching any such decision.

11.3 Only limited numbers of people will be involved in any covert monitoring.

11.4 Covert monitoring will only be carried out for a limited and reasonable period of time consistent with the objectives of making the recording and will only relate to the specific suspected illegal or unauthorised activity.

12. Ongoing Review of CCTV Use
12.1 REGIS GYMNASTICS will ensure that the ongoing use of existing CCTV cameras in the workplace is reviewed periodically to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.

13. Requests for Disclouse
13.1 No images from REGIS GYMNASTICS’s CCTV cameras will be disclosed to any third party, without express permission being given by the Group General Counsel. Personal Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced.

13.2 In accordance with applicable laws, REGIS GYMNASTICS will allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.

13.3 REGIS GYMNASTICS will maintain a record of all disclosures of CCTV footage.

13.4 No images from CCTV will ever be posted online or disclosed to the media.

14. Subject Access Requests
14.1 Data Subjects may make a request for disclosure of their Personal Data and this may include CCTV images (data subject access request). A data subject access request is subject to the statutory conditions from time to time in place and should be made in writing, in accordance with the REGIS GYMNASTICS subject access policy.

14.2 In order for REGIS GYMNASTICS to locate relevant footage, any requests for copies of recorded CCTV images must include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual.

14.3 REGIS GYMNASTICS reserves the right to obscure images of third parties when disclosing CCTV data as part of a subject access request, where it considers it necessary to do so.

15. Complaints
15.1 If any member of staff has questions about this policy or any concerns about our use of CCTV, then they should speak to their manager in the first instance or contact Joel King.

15.2 Where this is not appropriate or matters cannot be resolved informally, employees should use our formal grievance procedure.

16. Requests to Prevent Processing
16.1 REGIS GYMNASTICS recognises that, in rare circumstances, individuals may have a legal right to object to processing and in certain circumstances to prevent automated decision making (see Articles 21 and 22 of the General Data Protection Regulation). For further information regarding this, please contact the REGIS GYMNASTICS Group Data Protection Officer (GDPO) Joel King.

CCTV POLICY