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Privacy Policy

Culture and Leisure NL Ltd

Privacy Notice – COVID 19 Coronavirus Test and Protect Strategy

  • Who we are

CultureNL and NL Leisure are trading names of Culture and Leisure NL Ltd. Culture and Leisure NL Ltd is a registered Scottish charity, charity number SCO 43891. We are an Arms Length External Organisation (ALEO) of North Lanarkshire Council. Our head office is at Summerlee Museum Of Scottish Industrial Life, Heritage Way, Coatbridge, Lanarkshire, ML5 1QD. Culture and Leisure NL Ltd is the data controller and responsible for your personal information.

  • Information we are collecting about you

For the health and safety of the customers and staff in these premises, we are recording the name and contact details of everyone who enters to support NHS Scotland’s Test and Protect Strategy. This information will be used to enable NHS Scotland to contact you should you have been in these premises around the same time as someone who has tested positive for coronavirus. Contacting people who might have been exposed to the virus is an important step in stopping the spread.

  • Commitment to Privacy

We are committed to protecting the privacy and confidentiality of any personal information that we hold.  This privacy notice will tell you how we look after this information and tell you about your rights.

We will ensure that your personal information is kept secure, in line with the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. We will only collect the minimum information necessary to fulfil this purpose; when we don't have a need to keep this information about you, it will be disposed of in a secure manner.

Information Commissioner’s Office

You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK data protection regulator who can be contacted via the contact details below, however, we would welcome the opportunity to discuss your concerns with you before you do so:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Phone: 0303 123 1113 (local rate) or 01625 545 745 or visit their website at

  • Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, you can contact the DPO via the contact details below:

Data Protection OfficerEmail: informationrequests@culturenl.co.uk
Culture and Leisure NL LtdTelephone: 01698 274589

North Lanarkshire Heritage Centre

High Road

Motherwell

ML1 3HU

  • The personal information we are asking you to provide

Along with the date and time of your arrival and departure we will ask for your name and contact telephone number. If you do not have a telephone number, you have the option to provide a postal address or an email address. Customer health information will not be requested or stored.

  • How your personal information is collected?

We will ask you for this information when you attend these premises.

  • Purposes for which we will use your personal data

As described above, the purpose for which we are processing your personal data is to assist with NHS Scotland’s Test and Protect strategy in relation to the coronavirus public health epidemic. This will involve the gathering and, when necessary, the sharing of information with NHS Scotland as the responsible body for Test and Protect. We will only share this information with NHS Scotland in relation to the coronavirus public health epidemic. This data will not be used for any other purpose including any marketing purposes.

  • Lawful Basis for Collection and Sharing of this Information

We will use your personal information on the following basis:

Under data protection law, GDPR Article 6(1) (e ) we are allowed to collect and process personal information where necessary to perform a task carried out in the public interest or in the exercise of official authority vested in us. Collection of this information will assist us in providing services and carrying out official functions safely. It will help us to assist with NHS Scotland’s Test and Protect Strategy in relation to the coronavirus public health epidemic.

  • Sharing your personal information

We will share the personal information you provide only with NHS Scotland and only for the purposes described in this notice. In order to assist in the containment of the virus, we will only share your data when it is requested directly by NHS Scotland. This will only be in the unlikely event there is a cluster of coronavirus cases linked to the venue. Information will be transferred securely to NHS National Services Scotland who will use the data to contact trace those who were in the establishment at the same time as the positive case, and will provide guidance and support to those who may be advised to self-isolate. Read further information on the NHS Scotland Test and Protect strategy on the NHS website at: www.informationgovernance.scot.nhs.uk/use-of-your-data-for-track-trace-isolate-tti/

  • How long will we hold your information

Your personal data will be retained only for the purposes stated in this privacy notice and will be held by us for no more than 3 weeks (21 days). All personal data will be held and disposed of in a safe and secure manner.

  • Your Legal Rights

You have rights under data protection laws in relation to your personal information. You have the right to

  • Request access to your personal information (known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Not be subject to a decision based on solely automated processing if that produces a legal effect concerning you or similarly significantly affects you. Note that this right does not apply if the decision is (i) necessary for entering into, or performance of, a contract between us and you; (ii) authorised by law; or (ii) based on your explicit consent
  • If at any point within the 21 days after your visit you decide you’d like us to delete the personal data you provided, please advise us and we will delete the information which you have provided.

If you wish to exercise any of the rights set out above, please contact us on 01698 274589.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

For information about how Culture and Leisure NL Ltd process wider personal information for other purposes please see our privacy notice at: https://culturenl.co.uk/privacy-statement/

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Privacy Notice for services provided by Active and Creative Communities

 

Who are we?

Active and Creative Communities are a team within North Lanarkshire Council who provide culture and leisure services for North Lanarkshire’s residents and visitors. 

 

Why do we have a Privacy Notice?

North Lanarkshire Council has a legal requirement to let you know how we will manage your personal information. We are aware of the importance of handling your information appropriately and securely. Having this statement helps us to comply with the requirements of the UK GDPR and the Data Protection Act 2018. This statement supplements the council’s privacy notice and should be read in conjunction with it.

 

What is personal information?

Personal information is any information which identifies someone as a living, private individual or could do so if combined with other information held electronically, e.g. on a computer database or CCTV images.

 

Why do we need your information and what do we do with it?

We will use your personal information to allow us to carry out the leisure and culture functions that we carry out:

 

  • Sports and leisure activities including gym, swimming and leisure classes and memberships
  • Library services including library membership, newsletters, online services and in-person activities
  • Macmillan Cancer Support community support services
  • Museum and Archives services including activities, workshops, exhibitions and donations 
  • Venues and events including ticket bookings   
  • Community Arts classes
  • Marketing of any of the above services where we have consent or another legal basis

 

We will also use your information to comply with our legal obligations, verify your identity where required, contact you by post, email or telephone and to maintain our records.  

 

What types of personal information do we hold?

In order to carry out our business, we collect and use data about our employees, suppliers, service users and customers. We may hold personal information such as a name, address and date of birth and it could be in different formats e.g. photos or video. We could also have sensitive information such as information about health, racial or ethnic origin, or criminal offences. 

 

Legal basis for holding your information:

We will use your personal information using a legal basis from this list: 

  • Where necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us 
  • Where necessary for the performance of a contract with you (or to take steps to enter into a contract with you)
  • Where we need to comply with a legal or regulatory obligation
  • On the basis of your consent  
  • Where necessary to protect the vital interests of you or another person.
  • Where necessary for our legitimate interests (but not when we are performing our public tasks) or those of a third party and your interests and fundamental rights do not override those interests 

 

We may also need to process more sensitive personal information about you. This would include information about race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation. We will process these special categories of sensitive information using a basis from this list:

 

  • Where necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
  • Where necessary for reasons of substantial public interest
  • Where necessary to establish, exercise or defend legal claims
  • Where necessary to protect the vital interests of you or another person where you or that other person is physically or legally incapable of giving consent
  • Where you have given us explicit permission to do so

 

We may process your personal information using more than one legal basis depending on the specific purpose for which we are using your data

 

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with services). In this case we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

 

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

How long do we keep this information for?

We only keep your personal information for the minimum amount of time necessary.  Sometimes this time period is set out in the law, but in most cases it is based on the business need.  We maintain a records retention and disposal schedule which sets out how long we hold different types of information for.   You can view this on our website at Data protection | North Lanarkshire Council.

 

How do we collect personal information?

In most cases, the information that we have will come from you directly, e.g. when applying for a library card or buying tickets for an event. However, the information could come from another source such as your legal representative, partner, relatives or other agencies such as North Lanarkshire Council. When we receive personal information about you from another source, we are required to inform you of this within one month of receiving the information.

 

Who do we share your personal information with?

We are legally obliged to safeguard public funds so we may be required to verify and check your details internally for fraud prevention. We may share this information with other public bodies (and also receive information from these other bodies) for fraud checking purposes.  We are also legally obliged to share certain data with other public bodies, such as HMRC and will do so where the law requires this.  We will also generally comply with requests for specific information from other regulatory and law enforcement bodies where this is necessary and appropriate.  Your information is also analysed internally to help us improve our services. 

 

How do we manage our responsibilities regarding data protection?

Before we start to manage personal information for a new purpose or make significant changes to the way we handle information, we will carry out a Data Protection Impact Assessment at the earliest possible stage in the planning process.

 

We will ensure that any contractors, who are providing services on our behalf, comply with data protection legislation by asking them to sign a Data processing Agreement. 

 

We will provide you with a Privacy Notice when we collect your information and communicate with you if we are changing our Privacy Statement.

 

We will ensure that all staff are required to undertake data protection training on a regular basis.

 

Your rights under data protection law

Please contact us if you wish to exercise any of these rights.

  • Access to your information – you have the right to request a copy of the personal information that we hold about you. 
  • Correcting your information – you may ask us to correct any personal information about you that you believe is not accurate, complete and up to date.
  • Deletion of your information – you have the right to ask us to delete personal information about you where:
  • you think that we no longer need to hold the information for the purposes for which it was originally obtained
  • we are using that information with your consent and you have withdrawn your consent 
  • you have a genuine objection to our use of your personal information – see Objecting to how we may use your information below
  • our use of your personal information is contrary to law or our other legal obligations.
  • Objecting to how we may use your information – You have the right at any time to tell us to stop using your personal information for direct marketing purposes.  
  • Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information.  This right might apply, for example, where we are checking the accuracy of personal information that we hold about you or we are assessing the objection you have made to our use of your information.  This right might also apply if we no longer have a basis for using your personal information but you don't want us to delete the data.  Where this right is realistically applied it will mean that we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
  • Withdrawing consent to use your information – Where we are using your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given. 

 

Information you have given us about other people

If you have provided us with anyone else’s details, please make sure that you have told them that you have given their information to us and how they may contact us for further information.

 

This may be the case for emergency contact information or contact details to take up references in the event of a successful job application. We will only use this information for the purposes for which it has been provided.

  

How will we tell you if we change our Privacy Notice?

We will change our Data Protection Statement in line with changes to data protection law and will publish any new or amended statement on our websites and through other appropriate channels.

 

How can you contact our Data Protection Officer?

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please email dataprotection@northlan.gov.uk

 

Complaints

We aim to directly resolve all complaints about how we handle personal information. However, you also have the right to lodge a complaint with the Information Commissioner's Office, who can be contacted by post at:  Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Visit their website for more information at- https://ico.org.uk/concerns