What this policy covers?
Keighley Healthy Living is committed to protecting your personal information. We aim to be transparent on what we hold whether you are a client, employee, volunteer, website user or a potential candidate for employment. Our purpose with this policy is to provide a clear explanation of how we collect and process your personal information. KHL will not sell or rent your information. We will only share your information in the ways outlined in this policy.

This policy is split into sections so you can navigate to the section that is relevant to you.

Keighley Healthy Living may periodically make changes to this policy due to changes in the law or our procedures. Please ensure you check this policy to keep up to date.

If you have any queries about our privacy or cookie policy please email our data protection officer at admin@khl.org.uk or write to us at Keighley Healthy Living, 13 Scott Street, BD21 2JH.

Who we are
Keighley Healthy Living is a charity in England. We are registered as Keighley Healthy Living Network and our registered charity number is: 1090543 and our registered Company number is: 04190566

How we collect Information

• Information you give to us when making enquiries. e.g. when you call us, message us on social media, email us.
• Information you give to us when you register for one of our courses or activities, by filling out one of our forms.
• We use cookies on our website to see how you use our website so we can monitor traffic and improve. See our cookie policy.
• Information from third parties that you may interact with us through. For example, if you are referred to us from your GP or when applying for a Job you may apply through indeed.com, or you may make a donation through JustGiving.com. These services and websites may pass needed information on to us.

Personal Information processed by KHL

• Your name and contact details, including postal address, telephone number and email address.
• Your date of birth.
• Gender.
• Health and dietary requirements.
• Disabilities.
• Ethnicity.
• Your attendance in our groups and building.
• Photos taken by KHL. E.g. in a KHL group.
• CCTV footage on KHL premises.
• Information about your computer/mobile device and your visits to and use of this website, including for example your IP address and geographical location. We will not use this data to personally identify you and only use it for trends. An example use of this could be: “this many people visited the activity list page on our website on mobile phones but nobody uses that page on desktop PC, perhaps there is something displaying wrong for Desktop PCs”.
• Education (Job candidates and employees only).
• Job History (Job candidates and employees only).
• Any other personal information you share with us as described above.

Do we process Special Category Data?

Yes. We collect the following special category data:

• Data concerning Health and Disabilities.
• Data revealing Ethnicity.

When we collect this data we will explicitly ask for your consent to process and store it.

We collect Health data for a number of reasons including:

• Monitoring how well we are achieving our mission to improve Health in the local area.
• For a participant to access a cookery class we need to be made aware of any allergies.
• For a participant to access exercise classes we need to know you have no existing conditions which could be antagonised by vigorous exercise or we may need to know you have permission from your doctor.
• So we can be made aware of any additional accessibility requirements you may have.
• So we can demonstrate we are non-discriminatory and open to all.

We collect Ethnicity data so we can demonstrate we are reaching all audiences in our area and are being non-discriminatory.

How we use your data:

• To provide you with our services.
• To provide information about our services (with your consent, which can be revoked at any time)
• To process donations
• For administration purposes such as recording registers, attendance etc.
• To contact you if a group you are booked on is cancelled.
• Where collecting your data is required by law, for example your details are recorded in our accident book if you have an accident on our premises.
• Photos may be used for marketing purposes or shared with funders for evidence purposes with your permission.
• CCTV data for security and safety reasons.
• To aggregate the data and demonstrate to funders that we are reaching all audiences.
• Other specific reasons which you may agree to from time to time.

Who we share data with:

• We share your information with our funders and in most cases this will be entirely anonymous and not connected to you. However, in some cases funders ask us for names, postcodes and date of birth, we will only share this if you have given us explicit consent on the registration form to do so. Funders request this information to check we are meeting our targets and make sure we are reaching the demographics they require.

Website Users

• We use IP addresses to analyse trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
• This website may contain links to other sites. Please be aware that Keighley Healthy Living are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.
• Please see our separate cookie policy for in-depth information on how we use cookies for the functionality of our website.

Job Applicants

If you apply for a job at KHL, we will only use the information you give us to process your application or to monitor recruitment statistics on an anonymous basis. We will not disclose your information to anyone outside the organisation except for gathering employment references, which we will ask for your permission first.

We keep statistical information about all applicants to develop our recruitment processes however no individual applicant would be identifiable from this information.

Volunteers

If you apply for a volunteer role at KHL, we will only use the information you give us to process your application or to monitor recruitment statistics on an anonymous basis. We will not disclose your information to anyone outside the organisation except for gathering references, which we will ask for your permission first.

Once you are a volunteer for KHL we will store your contact details on our volunteer database along with emergency contact details, accessibility requirements etc.

Employees

Employee records are taken via paper format on induction and locked away. Most of these paper files are input to our online database which employees are given access to. We gather information required and store on a contractual legal basis. Such as payroll information which is shared with an external payroll service who provide employees with a payroll service. We also store employee contracts, induction records and training records.

CCTV

The CCTV system is installed and used for the following purposes:

• Security and Crime Prevention: To deter, detect, and record unauthorized access, vandalism, theft, or any criminal activities affecting the centre.
• Employee Conduct Monitoring: To help ensure that employees adhere to the centre’s code of conduct and to provide evidence in the event of breaches, thereby supporting a safe and professional working environment.

See our CCTV policy for further detail.

Legal basis for processing your data:

We process your data on the following legal grounds:

• Legitimate interests. For instance, processing your contact details when you book onto an exercise class.
• In many instances we will ask for your consent, for example to store ethnicity and health data, or photo and marketing permissions.
• If you are an employee, freelancer or volunteer we will process a lot of your data on a contractual basis.
• Legal obligation. For instance, we are required by law to record accidents that happen on our premises or in our groups.

Your rights:

Right to be Informed: You have the right to know how your personal data is being collected, processed, and used.

Right of Access: You have the right to ask us for copies of the data we hold on you.  To do this we require a written request and proof of your identity and to be satisfied that you are entitled to see the data.

Right to Rectification: You have the right to correct any data that we may have that is wrong. This can be done by emailing admin@khl.org.uk or writing to us at Keighley Healthy Living, 13 Scott Street, BD21 2JH.

Right to Erasure (Right to be Forgotten): You have the right to request we delete your data. We will not do this if we are legally obliged to keep it.

Right to Restrict Processing: Individuals can request a temporary halt to further processing of their personal data.

Right to Data Portability: You have the right to obtain and reuse your personal data for your own purposes across different services. This right applies where the processing is based on consent or a contract and is carried out by automated means.

Right to Object: You have the right to object to KHL processing your data. If an objection is raised KHL will review and where appropriate cease processing the data in question. , KHL will review and, where appropriate, cease processing the data in question.

Right to Withdraw Consent: Consent for data that is processed based on consent, for example marketing and  photo permissions, can be withdrawn at any time. Email admin@khl.org.uk

Right Regarding Automated Decision-Making: We do not use any automated decision making systems.

How to Exercise These Rights & Complaints: Please contact our data protection officer via admin@khl.org.uk  

For more information about your rights or if you are not happy with our response to your request, you can contact the Information Commissioner’s Office (ICO) – for more details, see https://ico.org.uk

How do we store your information

How long do we store your information?

• Registered clients details are stored for up to 3 years after your last attendance at KHL activity or if you registered and never attended, 3 years after you registered.
• Employee and Freelancer records are kept for 6 years after you leave.
• Volunteer and Trustee records are kept for 3 years after you leave.
• CCTV records are kept up to a year unless they are saved due to a crime or misconduct. They will be then kept for the length of the investigation.
• Job Applicants are kept on record for up to 3 months.
• Accident records are kept for 3 years after the accident.