Privacy Policy

1. Introduction

The Pickaquoy Centre Trust (PCT) is committed to ensuring that your personal information is protected and that we are transparent about any information we hold about you.

Please read this Privacy Policy carefully as it contains important information regarding who we are and how and why we collect, store, use and sometimes share your personal information. It also explains your rights in relation to your personal information and how to contact us or The Information Commissioner’s Office in the event you have a complaint.

We have developed this Privacy Policy to ensure those who use our services and otherwise interact with PCT, including visitors to our website (www.pickaquoy.co.uk), are informed and confident about the security and privacy surrounding their personal information.

When we handle certain personal data about you, we do so subject to the General Data Protection Regulation ((EU) 2016/679) (GDPR) which applies across the European Union (including in the United Kingdom) and the Data Protection Act 2018. This Privacy Policy supplements our terms and conditions of use and is not intended to override them.

2. About us

PCT was established in 1999 with the primary purpose to provide or assist in the provision of facilities and services for recreational, sporting or other leisure time occupation for the public at large and in the interests of social welfare. PCT is registered with the Scottish Charity Commission with the registration number SCO28833.

Based at:
The Pickaquoy Centre Trust
Muddisdale Road
Kirkwall
Orkney
KW15 1LR
01856 879900
www.pickaquoy.co.uk

PCT is the data controller for the purposes of this Privacy Policy.

3. The Principles Of Data Protection

When using the term “personal data” or “personal information” in this Privacy Policy, we mean information (including opinions) that relates to you and from which you could be identified, either directly or in combination with other information which we may have in our possession.

To help you understand how we handle your personal information more clearly, below is a summary of the privacy principles which guide how we use your personal information. These principles provide that personal data should be:

  • used lawfully, fairly and in a transparent way;
  • collected for lawful reasons which have been clearly explained to you;
  • relevant to the purposes you have been told about and limited only to those purposes;
  • kept accurate and up to date;
  • shared only as has been explained to you, when you ask us to or when legally required to;
  • kept only as long as necessary for the purposes you have been told about; and
  • kept securely and protected.

Our website may provide links to third party websites. PCT is not responsible for the conduct of third party companies linked to our website and you should always refer to the privacy notices of these third parties as to how they may handle your personal information.

4. How Your Personal Data Is Collected

The circumstances in which we may collect personal data about you includes when:

  • the personal data is provided to us by you (e.g. when you agree to sign up to join our mailing list or enter a competition);
  • the personal data is collected in the normal course of our relationship with you (e.g. when you are booking a space with us, to attend a class or a cinema/live production ticket via telephone or on the website);
  • the personal data has been made public by you (e.g. contacting PCT via a social media platform) or obtained from a publicly accessible source (e.g. Companies House);
  • the personal data is received by us from third parties (e.g. third party booking websites, from your employer, external travel agents);
  • the personal data is collected via our IT systems, such as:
  • automated monitoring of our website, centre Wi-Fi services and other technical systems including our computer networks and connections;
  • CCTV which we operate within and around our facility;
  • E-mail and instant messaging systems; and
  • The personal data is created by us, such as records of your communications with PCT

5. Types of Personal Data Collected

The categories of personal information about you which we may collect and use includes:

  • Personal Details: title, full name, age range, gender, business or home address, telephone numbers, email address.
  • Family Information: children and dependents contact details.
  • Public Identifiers: signatures, passport details, driving licence details, social media handles, national concession , photographs, voice recordings, video recordings (identifying physical characteristics).
  • Internal Identifiers: discount codes and vouchers, prize letter details, sponsorship details.
  • Financial Details: purchase transaction history, card payment details in accordance with PCI DSS
  • Booking Information: Booking requirement information.
  • Correspondence: responses to competitions, promotions and surveys (some details of which may be anonymised), social media postings, general correspondence.
  • Preferences: consents, permissions, or preferences that you have specified, such as whether you wish to subscribe to our mailing list or agree to our terms and conditions.
  • Incident History: health and safety accidents, security incidents, accident information, complaints communications, insurance claims history.
  • Sensitive Personal Data: health and medical information, racial or ethnic origin, religion, philosophical beliefs.
  • Website Access Details: your computers unique identifier (e.g. IP Address), the date and time you accessed the website, passwords to access alerts preferences.

If you do not provide certain personal information which we ask for we may not be able to process a booking for you.

PCT complies with the Payment Card Industry Data Security Standards (PCI DSS). We have in place robust controls surrounding the storage, transmission and processing of cardholder data that we handle.

6. How And Why We Use Your Personal Information

Data protection and privacy laws requires companies to have a “legal basis” or “lawful ground” to collect and handle your personal information. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal justification to do this, for example:

  • it is necessary in connection with the performance of our contract with you or to take steps at your request prior to entering into a contract with us;
  • to comply with our legal and regulatory obligations;
  • for our legitimate interests or those of a third party; or
  • where you have given your prior consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

7. Children’s Data

Our services may be booked directly and used by individuals aged 16 years or over. However, we do not knowingly collect or solicit personal information directly from anyone under the age of 16 or knowingly allow such persons to provide us with their personal information without parent or guardian consent. School, Sports Clubs and community Groups may book space with us and may provide limited information about the children within their group.

If you are under 16, do not send any information about yourself to us, including your name, address, telephone numbers, or email address, unless you have your parent's or guardian's permission.

In the event we learn that we have collected personal information from anyone under the age of 16, and do not have a parent or guardian's consent, we will delete that information as quickly as possible.

If you have any concerns, please contact us at enquiries@pickaquoy.com or call us on 01856 879900

In the event that we do hold personal data about children, we will handle that data in accordance with the terms of this Privacy Policy.

8. Cookies

We use cookies on our website. Cookies are small text files that are downloaded onto your device when you visit a website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

9. When Is Special Category Collected?

Special category personal information is particularly sensitive personal information as defined by the GDPR, including information that reveals racial or ethnic origin, religious beliefs or philosophical beliefs or data concerning health and medical conditions.

PCT does not collect special category personal data as a matter of course, however we may on occasion handle such data where, for example, our customer may: (i) require assistance for a disability; (ii) wish to declare specific medical conditions or dietary requirements; or (iii) share sensitive details in their communications with us. Individuals with pre-diagnosed health conditions should ensure they are familiar with our terms and conditions of use.

Where special category personal information is involved, we will handle that information in accordance with applicable laws, including where:

  • we have your explicit consent – including where you voluntarily provide us with that information;
  • the law permits us to do so, to comply with our legal obligations or to exercise specific legal rights;
  • you have clearly made the sensitive personal information public;
  • processing is necessary for the establishment, exercise or defence of legal claims; or
  • processing is necessary for reasons of substantial public interest.

10. Direct Marketing

We may use your personal information to send you updates (by email, text message, telephone or post) about our services including exclusive offers, promotions or products that we believe will be of interest to you.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and Why We Use Your Personal Information’). This means we do not always need your consent to send you promotional communications. However, where consent is needed, we will ask for this separately and clearly.

You can subscribe to our marketing list by selecting the option to receive marketing communications via our website.

We will always treat your personal information with the utmost respect and never sell your information, or share with other organisations without your prior permission for marketing purposes. We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.

Where applicable, you have the right to opt out of receiving marketing communications by:

  • using the unsubscribe option included on all PCT marketing correspondence or selecting this unsubscribe link or
  • sending us an email to enquiries@pickaquoy.com please ensure you correspondence is marked ‘Unsubscribe: Marketing Contact List’ and include your full name, email and telephone number to ensure your details are fully deleted from our direct marketing system.

11. CCTV

We currently have closed circuit television (CCTV) operating within and outside our facility, for the primary legitimate purposes of: (i) public and worker safety; and (ii) crime prevention and detection. For these reasons, the information processed may include visual images of personal appearance and behaviours and in certain circumstances various sound recordings of workers and general members of the public who were in the immediate vicinity of the area under surveillance.

We display signs to inform customers and workers that they are under surveillance and there may be video and/or sound recording in operation. This information is kept in secure environments and access is restricted to PCT designated trained workers and any use shall be in compliance with PCT Trust privacy policies.

We retain CCTV recordings for up to 17 days, and for a longer period if they are relevant to an incident, complaint, investigation, legal proceedings or for as long as legally required by regulatory bodies and law enforcement agencies.

12. ActiveLife Membership

If applying for our ActiveLife Membership, you will be asked to complete an application which includes your name, address, telephone contact details, direct debit details, email contact details and the option of further communication. For our Budget Membership, we will require evidence of your eligibility, a copy of which will not be retained by us. This will allow you to have an ActiveLife Membership which gives exclusive privileges and allow you book quicker online.

Further information on ActiveLife is available. ActiveLife Link

13. Refusal of Access

PCT keeps a record of the names of individuals that will not be allowed access to PCT for a limited or unlimited period of time, based on its legitimate interests, as those individuals have interfered with the safety, security or public order, either within the centre itself or whilst on the surrounding campus, or harassed or acted inappropriately to our staff team in person or in other communication such as by email or on the telephone.

These individuals are personally informed (in writing where possible) that their name has been placed on our barred list and the details about how long these measures will apply to them. Once their name is removed from our barred list, these details will only be retained in associated incident reports.

14. Sharing Your Personal Information With Others

We will only disclose personal information to a third party in very limited circumstances, or where we are permitted to do so by law. The third parties to whom we provide your personal data include:

  • The Orkney Islands Council, for the purposes of contract management review such as incident reports or customer correspondence.
  • third parties we use to help deliver our products and services to you, e.g. banks and payment providers;
  • other third parties we use to help us run our business (e.g. marketing agencies, IT support service providers, analysis experts, communication platform providers);
  • third parties approved by you (e.g. when you request your details to be transferred);
  • our professional advisers (e.g. law firms, insurers and brokers); and/or
  • Government, regulatory and law enforcement bodies where we are required in order:

a) to comply with our legal obligations;
b) to exercise our legal rights (e.g. pursue or defend a claim); and
c) for the prevention, detection and investigation of crime.

Less commonly, we may process and share your personal data where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent.

We also impose data protection obligations on contracted third parties to ensure they can only use your data when providing services to PCT for the purposes listed above. These third parties cannot pass your details on to any other parties unless instructed to by us.

15. Security Of Your Personal Information

PCT takes precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, modification, disclosure, alteration and destruction. We protect personal data using a variety of security measures including:

  • password access;
  • data back-up;
  • encryption;
  • firewalls;
  • destroying personal information if it is no longer needed for the purposes it was collected;
  • placing confidentiality requirements on employees and service providers and providing training to ensure that your personal data in handled correctly; and
  • secure physical storage units for hard copy files with appropriate security restrictions, preventing damage, and unauthorised access to your personal information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Please ensure that any passwords which you are given or created by you to access our services are kept secure and safe.

16. How Long Do We Keep Your Personal Information?

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Policy. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner.

In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with contractual, legal, regulatory, tax and/or accounting requirements.

17. Your Legal Rights In Respect Of Your Personal Information

You have legal rights in connection with personal information. Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly 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 information we hold about you corrected.
  • Portability of the personal information you provided us, in certain situations.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
  • Object to processing of your personal information by us or on our behalf for direct marketing (including profiling) and in certain other situations (such as processing carried out for legitimate interests).
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
  • Withdraw consent to processing where the legal basis for processing is solely justified on the grounds of consent (please refer to section 10 for details about withdrawing consent to marketing).

If you would like to exercise any of these rights, please submit your requests to the Data Protection Officer at the following details:

The Pickaquoy Centre Trust
Muddisdale Road
Kirkwall
Orkney
KW15 1LR
Email: enquires@pickaquoy.com
Telephone: 01856 879900

Please note, to ensure security of personal information, we may ask you to verify your identity before proceeding with any such request.

18. Requests About Your Child’s Information

We hold very little data about children and do not actively market to them. Children have the same rights over their own personal information as an adult. However, as young children may not understand these rights or are not capable of exercising these right, in some cases their parents may do so on their behalf.

19. Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Policy. If you have any questions about this Privacy Policy or how we handle your personal information, please address to:

Data Protection Officer
The Pickaquoy Centre Trust
Muddisdale Road
Kirkwall
Orkney
KW15 1LR

Alternatively, please email enquires@pickaquoy.com or call 01856 879900.

20. Complaints

You also have the right to contact the Information Commissioner’s Office and file a complaint. (https://ico.org.uk/concerns/ or telephone: 0303 123 1113). The Information Commissioner’s Office will then investigate your complaint accordingly.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your Information Commissioner’s Office at any time.

21. Privacy Policy Changes

We may amend our Privacy Policy from time to time to keep it up to date with legal requirements and also the way we operate our business. This Privacy Policy was last reviewed and updated in September 2020.

Please regularly check this page for the latest version of this Privacy Policy. If we change this Privacy Policy, we will post the details of the changes on this page. 


 

You can download a PDF version of our Privacy Policy here.