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Sports Services Privacy Policy

Sports Services Privacy Notice

1. Introduction

Newcastle University Sports Services as the Data Controller collects and processes data to carry out its function as a Sports & Fitness provider. This privacy notice explains how Sports Services processes your personal data as well as your rights in relation to the personal data we hold about you. A separate privacy notice is available regarding the University’s processing of your personal data.
The contact details of the University’s Data Protection Officer are available via the following web‐ page: http://www.ncl.ac.uk/data.protection/.


2. How is your personal data collected?

Sports Services collects your personal data from a number of sources:
2.1. From you:
2.1.1. Interactions with the University, including but not limited to contact details from open day events and your application/enquiry to the Sport & Fitness Centre;
2.1.2. When you enrol with the University during the student/staff registration process;
2.1.3. When you complete surveys and feedback forms;
2.1.4. Communications with the University;

2.2. From third‐parties:
2.2.1 SAP Student/Staff registration/contract data
2.2.2. UCAS course applications;
2.2.3. Newcastle University Students Union.

2.2.4 NUIT Utils System data.


3. What personal data is collected?

Sports Services collects and processes the following personal data:
3.1 Identification and contact details: Your name, title, date of birth, age, gender, photographic images, correspondence address, email address, phone number, emergency contact details; where applicable
3.2 Attendance records;
3.3 Bank account details/transactions when Sports Services wishes to make a payment to you or you wish to make a payment to Sports Services;
3.4 Special Category Data: physical or mental health conditions where this data has been provided by you or the Newcastle University Health and Wellbeing Service and/or third parties.


4. Legal Basis of Processing

Sports Services will only process your personal information where it has a lawful basis for such processing.
4.1. Contract
As part of the contractual relationship between you and Sports Services, Sports Services will process your personal data for the following purposes:
4.1.1. Administration of your application to Sports Services

4.1.2. Access to Newcastle University owned and/or hired facilities

4.1.3. To maintain a suitable record of access to Sport and Fitness services facilities, activities and programmes

4.1.4. Administration of membership services with partner institutions and organisations, for example British Universities and Colleges Sport (BUCS);

4.1.5. Processing of fees and payments.


4.2. Legal Obligation
Where there is a legal obligation placed upon the University, the University will process your personal data for the following purposes:


4.2.1. Providing census or other information including the assessment of fees to government and regulatory authorities;
4.2.1. Local authority matters such as council tax, electoral registration or the investigation of benefit fraud;
4.2.3. Sharing personal information to HESA and the Office for Students and their nominated sub‐contractors, including but not limited to facilitating participation in the National Student Survey (noting your participation is voluntary);
4.2.4. Where there is a legal obligation, prevention and detection of crime in order to assist the police and other competent authorities with investigations;
4.2.5. Where there is a legal obligation to share your personal data with third parties such as the police and other law enforcement agencies; local authorities; the Home Office, British overseas missions; other government bodies; international governmental and regulatory bodies; HMRC; the University’s external auditors; the Office for Students; the Office of the Independent Adjudicator.

4.3. Legitimate Interests
Sports Services will process your personal information to meet legitimate interests in the following circumstances:


4.3.2. Sharing your data with Newcastle University Students’ Union (Students’ Union) for the administration and membership rights whilst you are studying at the University (e.g. to give you access to the Students’ Union services and facilities, sending updates about Students’ Union services and activities via email);
4.3.3. Presenting you, and appropriate colleagues, with your collated data showing your engagement with Sports Services systems in line with the Policy on the Ethical use of Student Data for Learning Analytics to provide you with a more personalised experience
4.3.4. Participation in surveys and benchmarking exercises to assist in designing the future shape of Sports Services
4.3.6. Service improvement and development through analysing the use of the University’s website and other online services that Sports Services provides;
4.3.7. Organising events that are likely to be of interest (e.g. Welcome Week, Freshers Fayre, Club trials, Programmes and activities);
4.3.8. Recording of video/audio/images on the Sports Services premises for use in promotional/information materials and video analysis (Sports programmes). Legitimate interests are used in this instance where it would not be necessary, appropriate or practicable to seek your specific consent;

4.3.9 Data is obtained from University central SAP software into Sports Services Leisure Management software for adminstrative purposes as well as sending promotional/ marketing materials to Staff/Student email addresses.


4.5. Consent
In the following circumstances, Sports Services will process your personal information based on consent:


4.5.1. Consent will be sought where specific services have been requested by you as an Associate contact of Newcastle University or where the law requires the University to obtain your consent for adminstrative purposes as well as sending promotional/ marketing materials.


4.6. Vital Interests

Where the University believes it is necessary to protect the life of you or another person, Sports Services will use the vital interest’s lawful basis to process your personal data, and this may include sharing with a third‐party. E.g. if you are admitted to a hospital A & E department after a serious accident and you are incapable of providing consent Sports Services may share relevant personal data with the NHS or emergency services.

5. Sharing Data with Third‐Parties
Sports Services will in some circumstances disclose your personal data to third‐parties. Examples of such processing are:
5.1. Partner organisations such as NUSU where you undertake closely related organised Sport & Fitness activity.
5.2. IT Service providers (e.g. Leisure management software system used within Sports Services);
5.3. Registration and initiatives with Sports National Governing Bodies
5.4. Where there is an obligation placed upon Sports Services detailed in section 4 above.


6. Data Leaving the EEA


Whilst Sports Services carries out the majority of its data processing activity within the EEA, Sports Services may process some of your personal data outside the EEA, but only within one of the following circumstances:
6.1. Where “appropriate safeguards” are put in place through contract;
6.2. Where the European Commission has agreed that the data protection provisions of the country/ territory offer an adequate level of protection; or
6.3. Where you have given your explicit consent.

7. How long is your data retained?


After you leave the University and in meeting the University’s Public Task and Legal Obligations your personal data will be retained for up to six years. Sports Services reviews data annually and 'purges' accounts/records of anyone identified as leaving the University and no longer can be identified as engaging in activities provided by Sports Services.

8. Your Rights:

Under legislation in force from 25th May 2018 you have a number of rights, although it should be noted that they are not absolute and requests may be refused where an exemption applies:

8.1. The right of access to your personal data held by Sports Services;
8.2. The right to have inaccurate or incomplete personal information held by Sports Services about you rectified;
8.3. The right to request that Sports Services restricts the data processing activities with respect to your personal data;
8.4. The right to request that we erase your personal data;
8.5. The right to complain about Sports Services processing of your personal data. Contact details for the UK supervisory authority are available: http://www.ncl.ac.uk/data.protection/;
8.6. The right to object to processing where Sports Services is relying upon on its legitimate interests or the performance of a task in the public interest; where it is used for direct marketing or for purposes of scientific/historical research and statistics;
8.7. The right to portability where you have provided us with your data and the legal basis of processing is consent or performance of a contract.