1.0. Peter Ashley Activity Centres beliefs regarding User Privacy and Data Protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We hate spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
2.0 Relevant Legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
UK Data Protection Act 1988 (DPA)
EU Data Protection Directive 1995 (DPD)
EU General Data Protection Regulation 2018 (GDPR)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well.
3.0 Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
3.2 Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link, none of the data that you supply will be stored by this website or passed to/be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. The information contained in the form you supply will be held locally on our secure network. If no bookings or communication is entered into, your information will be deleted after a period of 14 days. If bookings transpire or communication arises from that initial contact then your information will be held for an indefinite amount of time. You can request us to remove all your data at any time by emailing us – see section 8.0 Data Removal below.
3.3 News and Events Subscriptions
If you choose to join our email News and Events subscription, the email address that you submit to us will be forwarded to Jetpack who provide us with email marketing services. We consider Jetpack to be a third party data processor (see section 6.0 Our Third Party Data Processors below). The email address that you submit will also be stored within this website’s own database.
Your email address will remain within Jetpack’s database and our own for as long as we continue to use Jetpack’s services for email marketing or until you specifically request removal from these lists. You can do this by unsubscribing using the unsubscribe links contained in any News and Events that we send you or by requesting removal via email (see section 8.0 Data Removal below). When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our News and Events subscription.
3.4 Comments made to News and Events posts
If you leave a comment to any of our News and Events posts, your name, email address and IP are captured and stored in this website’s secure database. Your comment and information will remain within this website’s database for an indefinite period of time. You can request removal of your information via email at any time (see section 8.0 Data Removal below). When requesting removal via email, please send your email to us using the email account that the original comment was made from.
4.0 How we store your personal information
As detailed in section 3.3 and 3.4 above, if you subscribe to our News and Events service on this website or post a comment, some personal information will be stored within a third party’s database along and/or on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is built on (WordPress). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to. Contact Form and messages via email links sent to Peter Ashley Activity Centres are stored locally and no personal information is stored in this website’s database.
5.0 About this website’s server
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
6.0 Our Third Party Data Processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. These two third parties are based in the USA and are EU-U.S Privacy Shield compliant.
7.0 Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 Data Removal
You can ask us to remove you from our database at any time by e-mailing firstname.lastname@example.org or by writing to us at the address below or calling us on 023 9232 1223.
Fort Purbrook Activity Centre
Peter Ashley Lane,
Portsdown Hill Road,
9.0 Changes to our Privacy and Data Policy
This privacy and data policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.
Privacy and Data Policy updated on 23rd May, 2018.