For the purposes of the General Data Protection Regulation (“GDPR”) and UK data protection laws, the controller is Downton Leisure Centre (the “Venue”) of Wick Lane, Downton, Wilts, SP5 3NF.
About this document
How we collect your information
We may collect your personal data in a few limited ways, namely:
- Directly from you, when you fill in an application for membership or a Details Form/Par-Q form, when you make enquiries on our website, when you provide information via the Venue’s club management software or booking systems, or when you interact with us during your time as a member in various other ways (for example, where you enter a competition, renew your membership, sign up for courses or lessons);
- From someone else who has applied for membership on your behalf (for example a family member or your trainer or coach who has provided us with your contact details for that purpose);
The types of information we collect
We may collect the following types of personal data about you:
- Contact and communications information, including your contact details (including email address, telephone numbers and postal address and records of communications and interactions we have had with you);
We may also collect data about your health or medical conditions, where you have volunteered this, for example so that we can cater for you when you use our facilities or when you attend a Venue social event or a course/camp.
How we use personal data
Personal data provided to us will be used for the purposes set out above and, where relevant, in accordance with any preferences you express.
More generally, we will use your personal data for the following purposes:
- Administration of your Venue membership, including:
- informing you about court / facilities opening hours;
- sending notification of membership renewal
- Fulfilment of orders for goods and services, including facility bookings;
- Where this is necessary for the performance of a contract (including any written terms and conditions relating to your membership) with you;
- Research and statistical analysis about who is using our Venue;
- Communication about our Venue activities that we think may be of interest to you;
- Storing your details on the software platform we use for our Venue member management database / booking system.
- Where this is necessary for our legitimate interests (for example in increasing use of our Venue’s facilities);
- Promoting our Venue and promoting goods and services of third parties (for example, equipment suppliers, operators of coaching courses, and organisers of sports events) where we think this will be of interest to you;
- Where this is necessary for our legitimate interests (or the legitimate interests of a third party), and/or where we have your consent, as applicable.
Your marketing preferences
We will always respect your wishes in respect of what type of communications you want to receive from us and how you want to receive them. There are some communications, however, that we need to send you regardless of your marketing preferences in order for us to fulfil our contractual obligations to you as a member of our Venue. Examples of these essential service communications are:
- Records of transactions, such as payment receipts (as applicable).
- Membership related mailings such as your membership renewal reminder, notices of formal meetings and information about venue closures and holiday opening hours.
You are in control of how we communicate with you. You can update your choices and/or your contact details by contacting us at:
Sharing your information with others
We do not sell or share your personal data for other organisations to use other than as set out below.
Personal data collected and processed by us may be shared with the following third parties, where necessary:
- Our employees and volunteers, for the purposes of administering your membership and giving you access to the membership benefits to which you are entitled.
- Our contractors and suppliers, including coaches and trainers and any provider of membership management services.
How long your information is kept
We keep your personal data only for as long as necessary for each purpose we use it. For most membership data, this means we retain it for so long as you have a valid Venue membership and for a period of six years after your last interaction with us (for accounting, tax reporting and record-keeping purposes).
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. You can also withdraw your consent, where this is the basis for our processing your data (without affecting the lawfulness of our previous processing based on consent).
- Request the transfer of your personal data to another party.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner. You can find out more about your rights under applicable data protection laws from the Information Commissioner’s Office website: www.ico.org.uk.
Email: firstname.lastname@example.org Telephone: 01725 557268
Reviewed: November 2022
Next review: November 2025
Downton Leisure Centre Safeguarding Policy Statement
Downton Leisure Centre acknowledges the duty of care to safeguard and promote the welfare of children and adults at risk. The Venue is committed to ensuring our safeguarding practice reflects statutory responsibilities, government guidance and complies with best practice and industry standards.
The Venue’s safeguarding policy recognises that the welfare and interests of children and adults at risk are paramount in all circumstances. It aims to ensure that regardless of age, ability or disability, gender reassignment, race, religion or belief, sex or sexual orientation, socio-economic background, all users of our facilities:
- have a positive and enjoyable experience in a safe and inclusive environment
- are protected from abuse whilst participating in activities at our Venue.
Downton Leisure Centre acknowledges that some children, including disabled children and young people or those from ethnic minority communities, can be particularly vulnerable to abuse and we accept the responsibility to take reasonable and appropriate steps to ensure their welfare.
As part of our safeguarding policy we will:
- promote and prioritise the safety and well-being of children and adults at risk
- ensure everyone understands their roles and responsibilities in respect of safeguarding and is provided with appropriate learning opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children and adults at risk
- ensure appropriate action is taken in the event of incidents/concerns of abuse and support provided to the individual/s who raise or disclose the concern
- ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored
- prevent the employment/deployment of unsuitable individuals
- ensure robust safeguarding arrangements and procedures are in operation.
The Venue’s policy and procedures will be promoted and are mandatory for everyone involved at Downton Leisure Centre. Failure to comply with the policy and procedures will be addressed and may result in dismissal/exclusion from the Venue.
The club’s safeguarding policy will be reviewed every three years, or sooner in the following circumstances:
- changes in legislation and/or government guidance
- as required by the Local Safeguarding Children Board
- as a result of any other significant change or event.
Safeguarding Policy Use of terminology
Child: a person under the age of eighteen years.
Note that some legislation in Scotland defines a child as a person under sixteen years old. However, where there is any safeguarding concern, anyone under the age of 18 is regarded as a child unless advised otherwise.
Adult at risk of abuse or neglect: a person aged eighteen years or over who is, or may be, in need of community care services by reason of disability, age or illness; and is, or may be, unable to take care of, or unable to protect him or herself against abuse or neglect.
Safeguarding children: protecting children from abuse and neglect, preventing the impairment of children’s health or development, ensuring that they grow up in circumstances consistent with the provision of safe and effective care, and taking action to enable all children to have the best life chances.
Safeguarding adults at risk: protecting adults from abuse and/or neglect. Enabling adults to maintain control over their lives and make informed choices without coercion. Empowering adults at risk, consulting them before taking action, unless someone lacks the capacity to make a decision, or their mental health poses a risk to their own or someone else’s safety, in which case, always acting in his or her best interests.
This Policy is applicable to all staff, volunteers, coaches and club members. It is in line with national legislation and applicable across the UK.
Responsibility for the implementation of the Safeguarding Policy, Standards, Code of Conduct and Reporting Procedure
SAFEGUARDING IS EVERYONE’S RESPONSIBILITY: NOT RESPONDING TO A SAFEGUARDING CONCERN IS NOT AN OPTION.
- Our Venue’s management has overall accountability for this Policy and its implementation
- Our Venue Welfare Officer is responsible for updating this Policy in line with legislative and Venue developments
- All individuals involved in/present at the Venue are required to adhere to the Policy and Code of Conduct
Where there is a safeguarding concern/disclosure:
- The individual who is told about, hears, or is made aware of the concern/disclosure is responsible for following the Safeguarding Reporting Procedure. Unless someone is in immediate danger, they should inform their Venue Welfare Officer or Safeguarding Lead
- The Venue Welfare Officer and Safeguarding Leads are responsible for reporting safeguarding concerns to the relevant area
- The Venue Welfare Officer and Safeguarding Lead is responsible for assessing all safeguarding concerns/disclosures that are reported to them and to follow up as appropriate on a case-by-case basis, prioritising the well-being of the child/adult at risk at all times. Dependent on the concern/disclosure, a referral may be made to:
- The police in an emergency (999);
- Local Authority Children’s Services (Multi-Agency Safeguarding Hub (MASH) Team on 0300 456 0108 (out of hours: 0845 6070 888) See more at: www.wiltshire.gov.uk/children-young-people-contact
- Local Authority Adult Services
- Designated Officer (England only) for concerns/disclosures about a member of staff, consultant, coach, official or volunteer.
- Disclosure and Barring Service (or Disclosure Scotland; Adult Social Work Team or Health and Social Service Department (Channel Islands) for concerns/disclosures about a member of staff, consultant, coach, official or volunteer.
- The LTA Safeguarding and Protection Committee for advice and guidance.
Breaches of the Safeguarding Policy, Standards, Code of Conduct and Reporting Procedure
Breaches of this Policy and/or failure to comply with the outlined responsibilities may result in the following:
- Disciplinary action leading to possible dismissal and legal action;
- Termination of current and future roles within the Venue and roles in other clubs.
Actions taken by staff, consultants, volunteers, officials, coaches inside or outside of the Venue that are seen to contradict this Policy may be considered a violation of this Policy.
Where an appeal is lodged in response to a safeguarding decision made by the Venue, the individual should adhere to the club’s appeal procedure.
Safe and Inclusive Code of Conduct
- Prioritise the well-being of all children and adults at all times
- Be a positive role model. Act with integrity, even when no one is looking
- Help to create a safe and inclusive environment
- Value and celebrate diversity and make all reasonable efforts to meet individual needs
- Keep clear boundaries between your professional and personal life, including on social media
- Check you have the relevant consent from parents/carers, children and adults before taking or using photos and videos
- Ensure your own roles and responsibilities, and those of everyone you are responsible for, are clearly outlined and everyone has the information, training and support to carry them out
- Where possible, do not be alone with a child or adult at risk
- Do not abuse, neglect, harm or discriminate against anyone; or act in a way that may be interpreted as such*
- Doing nothing is NOT an option: report all concerns and disclosures as soon as possible, following the Concern Reporting Procedure. If someone is in immediate danger, call the police (999)
*It is illegal to have a relationship with someone who is under 18 years old if you are in a position of trust; it is illegal to have a sexual relationship with anyone under the age of 16 whether they give consent or not.
The Code of Conduct should be interpreted in a spirit of integrity, transparency and common sense, with the best interests of children and adults at risk as the primary consideration.
Downton Leisure/Tennis Centre Welfare Officer: John Gibbons
Contact Number: 07786653689; Email: email@example.com
Reviewed: February 2023
Next review: February 2026
Appendix A: Glossary of Terms
Safeguarding: protecting children from abuse and neglect, preventing the impairment of children’s health or development, ensuring that children are growing up in circumstances consistent with the provision of safe and effective care, and taking action to enable all children to have the best life chances. Enabling adults at risk to achieve the outcomes that matter to them in their life; protecting their right to live in safety, free from abuse and neglect. Empowering and supporting them to make choices, stay safe and raise any concerns. Beginning with the assumption that an individual is best-placed to make decisions about their own wellbeing, taking proportional action on their behalf only if someone lacks the capacity to make a decision, they are exposed to a life-threatening risk, someone else may be at risk of harm, or a criminal offence has been committed or is likely to be committed.
Abuse and neglect
Physical abuse: A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child or adult at risk. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces illness
Sexual abuse: Involves forcing or enticing a child or young person to take part in abuse sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children
Emotional abuse: The persistent emotional maltreatment of a child or adult at risk such as to cause severe and persistent adverse effects on their emotional development. It may involve conveying to a child/ adult at risk that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person; not giving them opportunities to express their views; deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed, including interactions that are beyond a child or adult at risk’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing them participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), causing a child or adult at risk to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
Neglect: The persistent failure to meet a child/ adult at risk’s basic physical and/or psychological needs, likely to result in the serious impairment of their health or development. It may involve a parent or carer failing to:
- provide adequate food, clothing and shelter (including exclusion from home or abandonment);
- protect a child/ adult at risk from physical and emotional harm or danger;
- ensure adequate supervision (including the use of inadequate care-givers); or
- ensure access to appropriate medical care or treatment.
It may also include neglect of, or unresponsiveness to, a child’s or adult at risk’s basic emotional needs. Neglect may occur during pregnancy as a result of maternal substance abuse.
Additional examples of abuse and neglect of adults at risk
Financial abuse: having money or property stolen; being defrauded; being put under pressure in relation to money or other property; and having money or other property misused.
Discriminatory abuse: treating someone in a less favourable way and causing them harm, because of their age, gender, sexuality, gender identity, disability, socio-economic status, ethnic origin, religion and any other visible or non-visible difference.
Domestic abuse: includes physical, sexual, psychological or financial abuse by someone who is, or has been a partner or family member. Includes forced marriage, female genital mutilation and honour-based violence (an act of violence based on the belief that the person has brought shame on their family or culture). Domestic abuse does not necessarily involve physical contact or violence.
Psychological abuse: including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supportive networks.
Organisational abuse: where the needs of an individual are not met by an organisation due to a culture of poor practice or abusive behaviour within the organisation.
Self-neglect: behaviour which threatens an adult’s personal health or safety (but not that of others). Includes an adult’s decision to not provide themselves with adequate food, clothing, shelter, personal hygiene, or medication (when indicated), or take appropriate safety precautions
Modern slavery: encompasses slavery, human trafficking, criminal and sexual exploitation, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.
- A person who is being abused may experience more than one type of abuse
- Harassment, and bullying are also abusive and can be harmful
- Female Genital Mutilation (FGM) is now recognised as a form of physical, sexual and emotional abuse that is practised across the UK
- Child Sexual Exploitation is recognised as a form of sexual abuse in which children are sexually exploited for money, power or status
- Child trafficking is recognised as child abuse where children are often subject to multiple forms of exploitation. Children are recruited, moved or transported to, or within the UK, then exploited, forced to work or sold
- People from all cultures are subject to abuse. It cannot be condoned for religious or cultural reasons
- Abuse can have immediate and long-term impacts on someone’s well-being, including anxiety, depression, substance misuse, eating disorders and self-destructive Conducts, offending and anti-social Conduct
- Those committing abuse are most often adults, both male and female. However, child-to-child abuse also takes place.
Appendix B: What to do if a disclosure from a child or adult at risk is made to you:
- Reassure the child/adult that s/he is right to report the behaviour
- Listen carefully and calmly to him/her
- Keep questions to a minimum – and never ask leading questions
- Do not promise secrecy. Inform him/her that you must report your conversation to the LTA Safe and Inclusive Tennis Team (and the police in an emergency) because it is in his/her best interest
- REPORT IT! If someone is in immediate danger call the police (999), otherwise talk to the LTA Safe and Inclusive Tennis Team as soon as possible. Once reported, the Safe and Inclusive Tennis Team will work with you to ensure the safety and well-being of the child/ adult at risk
- Do not permit personal doubt prevent you from reporting the concern/disclosure
- Make an immediate objective written record of the conversation using the Reporting a Concern Form (add link). Make certain you distinguish between what the person has actually said and the inferences you may have made. Your report should be sent to the LTA Safe and Inclusive Tennis Team within 48 hours of the incident, who will store it safely.