Data Privacy Policy

Bluecoat Sports (BCS) is committed to protecting your privacy when you use our services. This privacy policy sets out how we obtain, store and use your personal information and applies to all personal information processing activities carried out by BCS. We respect individuals’ rights to privacy and to the protection of personal information.

We may update our Privacy Policy from time to time. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.

Who are we?

Our registered company name is Bluecoat Sports and our company number is 04384765. More information about Bluecoat Sports can be found at www.bluecoatsports.co.uk and by clicking on ‘About Us’. We are registered with the ICO (Information Commissioner’s Office) and our reference number is ZA674596.

How to contact us

We have a Data Protection Manager (DPM) who makes sure we respect your rights and follow the law. If you have any concerns or questions in connection with our processing of your personal data, please contact the DPM in one of the following ways:

By telephone on 01403 247572
By letter addressed to Data Protection Manager, Bluecoat Sports Health & Fitness Club, Christ’s Hospital, Horsham, West Sussex, RH13 0YB, United Kingdom.
By email at info@bluecoatsports.co.uk

Why we collect your personal information

What is Personal Information?

Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.

Information we may collect about you may include (but is not limited to):

• Name
• Address
• Telephone numbers
• Email addresses
• Date of birth
• Gender
• Occupation
• Bank details
• Credit / Debit Card details
• Health data
• CCTV images
• Computer IP address
• Dependent Details (only where applicable)

Did you know that some of your personal information might be classified as ‘special’? Some information is ‘special’ and needs more protection due to its sensitivity. It’s often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal information relating to your:

• Sexuality and sexual health
• Religious or philosophical beliefs
• Ethnicity
• Physical or mental health
• Trade union membership
• Political opinion
• Genetic/biometric data

We will not routinely collect any of this information from you, and should we need this information, we will tell you why we need it and ask for your consent to hold it.

Why do we need your personal information?

We may need to use some information about you to:

• check the quality of our services;
• deliver services and support to you;
• to carry out our obligations arising from any contracts entered into between you
  and us;
• manage those services we provide to you;
• service improvement
• prevention/detection of crime/fraud
• help investigate any complaints you have about our services;

How the law allows us to use your personal information

There are a number of legal reasons why we need to collect and use your personal information. Generally, we collect and use personal information for the purposes of where:

• you are entering or have entered into a membership with us
• you, or your legal representative, have given consent
• it is necessary to protect someone in an emergency
• it is required by law
• you have made your information publicly available
• it is necessary for legal cases
• it is necessary for archiving, research, or statistical purposes

How we communicate with you

At Bluecoat Sports we believe in putting our members in the driving seat when communicating. When we communicate with you, we will do so either because it forms part of your membership arrangements with us, we have your consent or where we have a legitimate interest to communicate with you.

We have outlined our primary communication activities below which tells you how we may communicate with you and how you can update your preferences.

Customer service communications

We may contact you or send communications to tell you about a service enhancement such as improvements to BCS or to keep you informed of your current membership status. We won’t need your consent to communicate with you in this way because we have assessed that it forms part of our membership agreement with you. We will most likely contact you through email for these service communications.

Customer communications may also include customer surveys as we feel understanding your experiences to help us improve the service we provide you forms an integral part of our relationship. We do not ask for your consent to contact you for these surveys as we have assessed that it is in our legitimate interest to contact you in this case. You can tell us to stop at any time – all our customer surveys will always contain an easy opt-out link.

Customer service communications via calls

If you supply us with your telephone contact details, we may use them to call you.

Examples of where we might call you include:

• Asking you to contact a named person or department
• Confirming an appointment, that you have requested
• Notification of a cancelled class or booking
• Emergency site updates

Prospective customer communications

When you make an enquiry with us, we may send you occasional messages to keep you informed about products or service information. We will keep your contact information for nine months after which time we will delete your data from our systems if you have not become a member or have not been communicating back with us. We will always give you an opt-out route when communicating with you. To make sure you keep receiving our latest offers beyond this time, email info@bluecoatsports.co.uk confirming that you opt in or just speak to a member of our membership team.

We may also contact you to follow-up on any failed online purchases where we feel we can help you.

We do not ask for your consent to contact you for these product or service messages as we have assessed that it is in our legitimate interest to keep you informed for a limited period. You can tell us to stop at any time – all our communications will always contain an easy opt-out link. We will also contact you where we believe you may require support for abandoned online purchases.

Past customer communications

If you are a past member and have not opted out to marketing we would like to stay in touch with you. We will send you occasional messages and keep you informed about products or service information. We will continue to share these updates with you for nine months following the end of your membership, after which time we will stop this communication.

We will always give you an opt-out route when communicating with you. To make sure youkeep receiving our latest offers beyond this time, email info@bluecoatsports.co.uk confirming that you opt in or just speak to a member of the membership team.

We do not ask for your consent to contact you for these product or service messages as we have assessed that it is in our legitimate interest to keep you informed. You can tell us to stop at any time – all our communications will always contain an easy opt-out link.

Consent and your preferences

To support our ongoing relationship, we may send you information on other products and services we offer, and which we think will be of interest to you. We will rely on consent for the majority of our direct marketing. We will ask for your consent to communicate this type of information to you. You can remove your consent and ask us to stop at any time.

Where we can, we’ll only collect and use personal information if we need it to deliver a service or meet a requirement.

If we don’t need personal information we’ll either keep you anonymous if we already have it for something else or we won’t ask you for it. For example, in a survey we may not need your contact details so we’ll only collect your survey responses.

If we use your personal information for research and analysis, we’ll keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.

We won’t sell your personal information to anyone else.

What you can do with the personal information we hold about you

The law gives you a number of rights to control both what personal information we hold about you and what we do with it.

The right to be informed

You have the right to be informed about the collection and use of your personal data. This is
covered in the earlier parts of this policy.

The right of access

You can ask for access to the information we hold on you. When we receive a request from you in writing, we must give you access to what personal information we’ve recorded about you. However, we can’t let you see any parts of a record which contain:

• Confidential information about other people; or
• May be held in preparation to defend legal claims

This applies to personal information that is in both paper and electronic records. If you ask us, we’ll also let others see your record (except if one of the points above applies).

A request for personal information can be made via email or in writing. This is known as a subject access request. In order to make a subject access request you will need to provide the following information:

• your name
• your address
• enough information to identify your records

If we have doubts about your identity or we are finding it difficult to locate your personal information we may ask you to provide us with proof of identity. We will not start your subject access request until we are satisfied that you have provided us with enough information for us to identify you.

Your subject access request should be in writing either via email to info@bluecoatsports.co.uk or sent to the following address:

Data Protection Manager
Bluecoat Sports Health & Fitness Club
The Counting House
Christ’s Hospital
Horsham
West Sussex
RH13 0YB

Once you have made a request you will receive an acknowledgement, and your request should be answered within one month. In certain circumstances, we are allowed to take longer but we will tell you without undue delay if we feel this is the case.

The right to rectification

You can ask to change, update or complete information we hold about you that you believe is inaccurate. You should let us know if you disagree with the information we have recorded about you, either in writing at info@bluecoatsports.co.uk or by speaking to one of our membership team.

We may not always be able to change or remove that information, but we’ll correct factual inaccuracies and may include your comments in the information to show that you disagree with it.

The right to erasure

In some circumstances you can ask for your personal information to be deleted, for example:

• Where your personal information is no longer needed for the reason why it was
  collected in the first place
• Where you have removed your consent for us to use your information (where there is
  no other legal reason for us to use it)
• Where there is no legal reason for the use of your information
• Where deleting the information is a legal requirement

Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure.

The right to restrict processing

You have the right to ask us to restrict what we use your personal information for where:

• you have identified inaccurate personal information, and have told us of it
• where we have no legal reason to use that information but you want us to restrict what  we use it for rather than erase the information altogether 

We will assess whether you have a right to a restriction and where restriction of use has been granted, we’ll inform you before we carry on using your personal information. 

Where possible we’ll seek to comply with your request, but we may need to hold or use  information because we are required to by law or we have a legal basis to do so.

The right to data portability

You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability. 

However, this only applies if we’re using your personal information with consent (not where we are processing your personal information for contractual, legitimate interests, legal obligations or vital interests as a legal basis) and if decisions were made by a computer and  not a human being. 

It’s likely that data portability won’t apply to most of the services you receive from BCS.

The right to object

You have the right to object to the processing of your personal data in certain circumstances. You should give specific reasons why you are objecting to the use of your personal data.

You have a right to object to the use of your personal data for direct marketing purposes at any time. We will always provide an option for unsubscribing from any direct marketing information sent to you. This does not mean that your personal data will be deleted, merely that it will be suppressed to ensure that your preference not to receive direct marketing is respected in the future.

The right to understand automated decisions made about you, including profiling

You can ask to have any computer made decisions explained to you, and details of how we may have ‘risk profiled’ you. 

You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you’ve consented to it. 

You also have the right to object if you are being ‘profiled’. Profiling is where decisions are made about you based on certain things in your personal information, e.g. your health. 

If your personal information is used to profile you, to deliver the most appropriate service to you, you will be informed. If you have concerns regarding automated decision making, or profiling, please contact the  DPM at info@bluecoatsports.co.uk who will be able to advise you about how we are using  your information.

Video and photograph consent

BCS often takes and/or uses photographs or video recordings for publicity purposes. These images may appear in any of our marketing materials including printed mediums, digital  (including web and social media including Facebook and Instagram) and within local media. 

Prior to using any personal information captured in either photographs or video recordings we will always ask for your permission and will request your permission on behalf of you and your child/children. 

Please be aware that social media platforms and web publications are available worldwide, including in countries where there may be no data protection legislation.

CCTV

BCS uses Closed Circuit Television (CCTV) cameras in various locations throughout the Club. We have assessed the use of CCTV to be in our legitimate interest to keep you safe and secure  when using the Club. The camera footage is not live monitored but is recorded in order that  we can refer to it should we feel it necessary. 

Please be advised that some of the cameras in this system are operated by Christ’s Hospital and they will therefore have access to the personal data that these cameras capture. 

For further information on CCTV, please refer to our CCTV Policy.

Keeping your information secure

We store personal information both electronically and in paper form. 

Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it. 

We implement security policies, processes and technical security solutions to protect the personal information we hold from: 

• Unauthorised access 
• Improper use or disclosure 
• Unauthorised modification 
• Unlawful destruction or accidental loss 

When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on  your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.

How we use your telephone number

Text messages and contact via telephone provide a direct way to contact and share information with you about the services we can deliver to you. It can also help you to receive important messages about your membership, important site updates e.g. temporary closures and other services that we provide you. 

If you provide your telephone number we may keep in contact with you by text.

Sharing your telephone number with third parties

We may pass your telephone number to third parties so that we can meet our contractual obligations with you. We may also share your telephone numbers if we are required to by law. 

We may supply the details to our approved third-party contractors who are delivering or performing services on our behalf, and these companies must not use your information for any other purpose. We never share or sell your telephone numbers to telesales/marketing companies.

Who do we share your information with

We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements there is always an agreement in place to make sure that the organisation complies with data protection law. 

We may enter partnerships with other organisations such as the police. To protect your information, we will enter into a legally binding data sharing agreement with partner organisations before any sharing takes place. It is not always possible for us to tell you that personal information is being shared, for example when we are working with the police or other agencies to help the investigation or detection of a crime as to do so may prejudice that investigation.

We are likely to share your personal information with the following: 

• Police: We may share your personal information with the police for the purposes of  preventing or detecting a crime or fraud. 
• Safeguarding and Support Agencies: We may need to share your personal information  with support agencies if we suspect that there may be safeguarding concerns about  yourself or those who are your dependent(s). We will not tell you about this  beforehand, we will take steps to only share that personal information which is  necessary for the safeguarding purpose. 
• Debt Recovery Agents: We may share your personal information with debt recovery  agents for the purposes of recovering any outstanding charges owed to us. 
• Legal Services and Partners: We may share your personal information with our legal  services or solicitors if we are preparing or defending a legal claim.

Although this is not an exhaustive list the following third parties process data on behalf of BCS, which may include your personal data for the specific purposes identified. BCS has appropriate contracts in place to ensure third party data processors comply with necessary regulations: 

• • Xn and XnPay – Member payment services 
• • Egym. – BCS App service 

To support the provision of the BCS App we will share your personal information with Egym. By taking up a membership with BCS we will share your personal information to support the set-up of your App invitation as we have assessed that it is in our legitimate interest to offer  you this membership benefit. You can tell us to stop at any time by contacting  info@bluecoatsports.co.uk

Where there is a high risk to your personal information we will complete a privacy assessment before we share personal information to make sure we protect privacy and comply with the law.

We occasionally have a legal duty to provide personal information to other organisations, this is often because we need to give that data to the police, courts, local authorities or government bodies.

We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:

• in order to detect and prevent a crime and fraud; or
• if there are serious risks to the public, our staff or to other professionals;
• for the purpose of safeguarding of vulnerable individuals

If we’re worried about your physical safety or feel we need to act to protect you from being harmed in other ways, we’ll discuss this with you and, if possible, get your permission to tell others about your situation before doing so.

For all of these listed reasons the risk must be serious before we can override your right to privacy. We may still share your information if we believe the risk to others is serious enough to do so. There may also be rare occasions when the risk to others is so great that we need to share information straight away. If this is the case, we’ll make sure that we record what information we share and our reasons for doing so. We’ll let you know what we’ve done and why if we think it is safe to do so and will not cause harm, distress or further risks to you, our staff, other professionals and/or the public.

How do we protect your information

We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them.

Examples of our security include:

• Encryption, meaning that information is hidden so that it cannot be read without
  special knowledge (such as a password).
• Controlling access to systems and networks allows us to stop people who are not
  allowed to view your personal information from getting access to it.
• Training for our staff allows us to make them aware of how to handle information and
  how and when to report when something goes wrong.

How long do we keep your personal information

There’s often a legal or a contractual reason for keeping your personal information for a set period of time. We will keep your information for the duration of providing a service or  product to you under the terms of a contract, such as your membership contract. When your contract has ended we will keep your personal data for a period of nine months for auditing and reporting purposes and for legitimate interest purposes, after that time we will either anonymise or destroy your information.

You can ask us for a copy of our retention periods by contacting us at: 

Data Protection Manager
Bluecoat Sports Health & Fitness Club
The Counting House
Christ’s Hospital
Horsham
West Sussex
RH13 0YB

How to tell us of a data breach

BCS takes responsibility to protect the personal information we hold about those with whom we work seriously. We are accountable for our processing and take necessary technical and operational steps to maintain information security protections.

If you suspect your personal information or that of others may have been at risk of a data protection breach, please contact us.

Where can I get advice?

If you have any questions about this privacy policy or concerns about how we process your data, please contact Data Protection Manager on the contact details above. 

For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at: 

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113

Visit www.ico.org.uk where you can find further information, start a live chat or complete online forms.

Version 2 – CPM
Date of last review: March 2026

Next review due: March 2028