Privacy Policy

Introduction

Sport is registered as a ‘data controller’ under the Data Protection (Jersey) Law 2018 (ref Number 15801) as we collect and process personal information about you. We are part of Growth, Housing and Environment.

We process and hold your information in order to provide you with public services. This notice explains how we use and share your information. Information may be collected on a paper or online form, by telephone, email, or by a member of our staff, or in some cases, by another Government department.

We will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with changes in the law.

What information we collect about you

We collect a variety of information about you, including:

  • your name
  • date of birth
  • ethnicity
  • photograph of you
  • email address
  • postal address
  • telephone number
  • your signature
  • financial information
  • information relating to your full time education
  • pension information
  • information about you having lived in care or being on probation
  • medical information
  • CCTV recordings
  • pool view recordings
  • information about your disability or learning difficulty 
  • your coaching qualifications
  • disclosure and barring service checks

If you wish to terminate your Active Card mid contract we may also collect:

  • medical information
  • information about your loss of employment
  • information about your move off the island

We need to collect and hold information about you, in order to:

  • to confirm your identity
  • process your application for an Active Card or for Active Swim School attendance
  • verify that you are eligible for a complimentary Active Membership (this only applies
  • to those individuals that have previously lived in care or have been referred from probation services)
  • verify that you are eligible for a Student/Youth pass or a Senior Citizen Membership
  • verify that you are eligible for a discounted membership as part of the exercise
  • referral programme
  • process bookings for parties, swim schools, etc
  • to satisfy our terms and conditions when hiring our premises
  • process your application for a sports related professional qualification
  • answer your query and/or investigate complaints relating to our service provision and standards
  • process financial transactions (where charges apply)
  • terminate your Active Card mid-contract

How we will use the information we hold about you

We will use the information you provide in a manner that conforms to the Data Protection (Jersey) Law 2018 and endeavour to keep your information accurate and up to date. We will process your information for the following purposes:

  • provide you with the service you have requested
  • to monitor and improve our performance in responding to your service request
  • to allow the statistical analysis of data so we can plan the provision of our services
  • to notify you about membership renewals and to confirm freeze requests (if applicable)
  • to notify you of price increases and products or services

We may not be able to provide you with the service you have requested unless we have enough information or your permission to use your information.

We will not pass any personal data on to anyone outside of the Government of Jersey, other than to those who either process information on our behalf, or because there is legal requirement for us to do so.  We will only do this, where possible, after we have ensured that sufficient steps have been taken by the recipient to protect your personal data and where necessary we will ensure that the recipient has signed a data sharing agreement.  A data sharing agreement sets out the purpose of the sharing and the rules that must be followed when processing your data.

We will not disclose any information that you provide ‘in confidence’, to anyone else without your permission, except in the few situations where disclosure is required by law, or where we have good reason to believe that failing to share the information would put someone else at risk. You will be told about this.

Data processing

We use the following organisations to process information on our behalf.

 

​Organisation ​Reason for processing
​Gladstone / Jonas Group ​Provision of Plus2 Active Card system software
​Innovatise UG

​Maintenance and servicing of Active App functionality hosted on Government’s Active Jersey website

​Ports of Jersey ​Provision and maintenance of CCTV recording equipment
Poolview ​Provision and maintenance of underwater camera operation for lifeguard monitoring
​The Idea works ​For provision of news updates to our customers
​Eventbrite ​For sale of tickets and promotion of events

Information processed outside of the European Economic Area ('EEA')

Our software provider is Gladstone, who operate within the Jonas Group.  The Jonas Group use servers hosted outside the European Economic Area (EEA) in Canada the USA, Australia and New Zealand.

Canada and New Zealand have been deemed by the EU as having an adequate level of protection for personal data.

Whenever your personal data is transferred outside the EEA to the countries identified above which have not been deemed by the EU to have an adequate level of protection for personal data, and specifically to the US, Jonas ensure a similar degree of protection is afforded to it by using standard data protection clauses approved by the European Commission (as permitted under Article 46(2)(c) GDPR), that are designed to help safeguard your privacy rights.

Data sharing

We may need to pass your information to other Government of Jersey (GOJ) departments or organisations to fulfil your request for a service. These departments and organisations are obliged to keep your details securely, and only use your information for the purposes of processing your service request. 

​Organisation ​Reason for sharing ​Legal Basis
​Customer and Local Services ​Processing of customer complaints through GOJ systems

Schedule 2, Part 1, Paragraph (4) of the Data Protection (Jersey) Law 2018

Loi (1934) sur la Sante Publique 

​States Treasury and Exchequer ​Processing membership payments, monthly invoices and debt management ​Public Finances (Jersey) Law 2019
​Health and Social Services

​Where necessary for notification of Incidents

Where necessary for provision of services to customers with special needs

​Health and Safety at work (Jersey) Law 1989

Schedule 2, Part 1, Paragraph (4) of the Data Protection (Jersey) Law 2018

Loi (1934) sur la Sante Publique 

​Education ​Completion of incident reports ​Health and Safety at work (Jersey) Law 1989

​Multi-Agency Safeguarding Hub

Safeguarding Partnership Board

​Where necessary for the safeguarding of vulnerable children and adults

​Loi (1934) sur la Sante Publique 

Schedule 2, Part 1, Paragraph (4) of the Data Protection (Jersey) Law 2018

​States of Jersey Police ​For the detection and prevention of crime

​States of Jersey Police Force Law 2012

Police procedures and Criminal Evidence (Jersey) Law 2003

Other forms of sharing

If we need to disclose any sensitive or confidential information about you, we will only do so if absolutely necessary and once we have obtained your consent, or where we are legally required to do so.  An example of this is where the disclosure is necessary for the purposes of the prevention and / or detection of crime.

At no time will your information be passed to organisations for marketing or sales purposes or for any commercial use without your prior express consent.

Data security

We have put appropriate security measures in place to prevent your personal data from being used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legal or legitimate business need to know.

All of our staff have received training on data protection awareness and security. We have procedures in place to deal with any suspected personal data breach and will notify you and the Office of the Information Commissioner of any breach where we are legally required to do so.

CCTV

We use CCTV in and around our premises for the purpose of security, public safety and good management. When visiting our premises or using the pool it is possible that you have been recorded on our CCTV or by our pool view camera. 

CCTV recordings are kept for a maximum of 31 days and Pool view recordings are kept for a maximum of 21 days before being deleted.

Recordings can only be accessed by authorised personnel.

Publication of your information

We may need to publish your information on our website where we are required to provide statistical information or where you have responded to a public consultation; although your data will be anonymised to protect your identity.

How long we keep information about you

We will not keep your information for longer than is necessary. Personal and financial details provided by you will be securely disposed of within 6 months of expiry of your membership.

If you are concerned about us continuing to hold your personal information you can contact us to ask that we remove the data immediately. We will always seek to comply with your request but we may require further information from you to be able to locate your data or we may still be required to continue to hold or process your information in order to supply you with a service you have requested or comply with a legal requirement.

Telephone calls

We do not record or monitor any telephone calls you make to us using recording equipment, although if you leave a message on our voicemail systems your message will be kept until we are able to return your call or make a note of your message. File notes of when and why you called may be taken for record keeping purposes. We will not pass on the content of your telephone calls, unless is it necessary for us to do so; either to fulfil your request for a service or to comply with a legal obligation. 

Emails

If you email us we may keep a record of your email address and a copy of the email for record keeping purposes. For security reasons we will not include any confidential information about you in any email we send to you. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum or use our secure online services where possible or correspond with us by post. We will not share your email address or your email contents unless is it necessary for us to do so; either to fulfil your request for a service or to comply with a legal obligation.

Your rights

You can ask us to stop processing your information

You have the right to request that we stop processing your personal data.  However, this may prevent us from delivering a service to you. Where possible we will seek to comply with your request but we may be required to hold or process your information to comply with a legal requirement.

You can withdraw your consent to the processing of your information

You have the right to withdraw your consent to the further processing of your personal data.  However, this may prevent us from delivering a service to you. We will always seek to comply with your request but we may be required to hold or process your information in order to comply with a legal requirement.

You can request that the processing of your personal data is restricted

You have the right to request that we restrict the processing of your personal information.  You can exercise this right in instances where you believe the information being processed in inaccurate, out of date, or there are no legitimate grounds for the processing. We will always seek to comply with your request but we may be required to continue to process your information in order to comply with a legal requirement.

You can ask us to correct or amend your information

You have the right to challenge the accuracy of the information we hold about you and request that it is corrected where necessary.  We will seek to ensure that corrections are made not only to the data that we hold but also any data held by other parties that process your data on our behalf.

You can ask us for a copy of the information we hold about you

You are legally entitled to request a list of, or a copy of any information that we hold about you. You can submit a subject access request (SAR) using our online form.

Retention schedule

The retention schedule for Sport is currently being reviewed. If you require information regarding the length of time a particular document or data set is retained for please contact us at active@gov.je

Complaints

If you have an enquiry or concern regarding the Government of Jersey processing your personal data you can contact the Central Data Protection Unit.

You can also complain to the Jersey Office of the Information Commissioner about the way your information is being used.