Hilsea Lido Pool for the People Trust, also known as HLPP Trust, is committed to protecting your privacy when you use our services.

The Privacy Notice below explains how we use information about you and how we protect your privacy.

Our board of trustees are responsible for Data Protection, they make sure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, please contact the board of trustees, at info@hilsea-lido.org.uk

Who Are We?

This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by Hilsea Lido Pool for the People Trust

Our address is Hilsea Lido, London Road, Hilsea, Portsmouth, PO2 9RP.  Hilsea Lido Pool for the People Trust is a registered charity, Reg’d No 1133714.  More information about the charity can be found at www.hilsea-lido.org.uk and by clicking on ‘About Us’.

We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business.

We may update our Privacy Notice 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.

Supplementary notice – COVID-19

This supplementary notice is to make it easier to understand and provide you with more information about how we may process your personal information in relation to the unprecedented challenges we are all facing during the coronavirus pandemic (COVID-19).

At this time, we may seek to share your personal data, limited to contact information only, with the necessary Government bodies in support of the track and trace scheme, to ensure the safety and well-being of all our customers and employees.
Such information will be limited to what is proportionate and necessary, considering the latest guidance issued by the Government and health professionals, to manage and contain the virus.

Any information which is shared will only be shared on a need to know basis, with appropriate individuals. Only the minimum information for the purpose will be shared.

The legal basis for processing the data for this purpose is that it is necessary in order to protect the vital interests of individuals in monitoring and dealing with the COVID-19 pandemic.

How to contact us

If you need to contact us in connection with our processing of your personal data you can contact us in the following ways:

• Data Controller, HLPP Trust, Hilsea Lido, London Road, Hilsea, Portsmouth, PO2 9RP
• Alternatively you can email info@hilsea-lido.org.uk 

Why we collect your Personal Information

Do you know what personal information is?

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

Bank details

CCTV images

Computer IP address

Dependent Details (only where applicable)

We may at times need to share this information. We will only do this if we have your consent or if there are legal requirements for us to do so. We may receive information about you from other data controllers, such as the police who might tell us about a crime they are investigating where this impacts on your contract with us. If you give us this information about yourself when communicating with us, you do so because you consider it forms part of a legitimate interest for us to hold this information on our records.

If we ask for any sensitive personal data about you, we will always 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:

• 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
• check the quality of 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 contract 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 HLPP Trust we believe in putting our customers in the driving seat when communicating. When we communicate with you we will do so either because it forms part of your contract 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 Hilsea Lido, our services or to keep you informed of your current booking status. We won’t need your consent to communicate with you this way because we have assessed that it forms part of our agreement with you. We will contact you through email and SMS 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 SMS/text messaging and calls

If you supply us with your telephone contact details, we may use them to call or send you operational text messages.

Examples of operational text messages include:

• Confirming an appointment, that you have requested
• Emergency site updates

We only use what we need!

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.  

We will always provide an option for updating your marketing preferences on our communications with you.

What you can do with your information 

The law gives you a number of rights to control what personal information is used by us and how it is used by us. 

You can ask for access to the information we hold on you.

You have the right to ask for the information we have about 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.

What types of documents could I submit as proof of ID?

• Copy passport with signature (please remove your passport number)
• Copy driving license picture with signature (please remove your driver number)
• Copy of signed tenancy or contract with us

You can write to us at the following address:

Data Protection Officer

Hilsea Lido Pool for the People Trust

Hilsea Lido

London Road

Hilsea

Portsmouth

PO2 9RP

If you are unable to make a request in writing, please contact us on 07903 823347.

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.

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 if we feel we may need longer without undue delay from when we receive your request.

You can ask to change information you think is inaccurate

You should let us know if you disagree with something we may have recorded about you.

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 record to show that you disagree with it.

Please contact info@hilsea-lido.org.uk and we can deal with your request

You can ask to delete information (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 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.

Please note that we can’t delete your information where:

• we’re required to have it by law
• it is for historical research, or statistical purposes where it would make information unusable
• it is necessary for legal claims

You can ask to limit what we use your personal data for

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, such as a contract.

You can ask to have your information moved to another provider (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 HLPP.

Visiting our websites

When you visit our website, (www.hilsea-lido.org.uk) we collect standard internet log information for statistical purposes.

• We use cookies to collect information in an anonymous way, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
• We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
• When we collect personal information, for example via an online form, we will explain what we intend to do with it.

Using cookies helps us to improve our site and to deliver a better and more personalised service.

Our website may contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our site.

More information is available in our cookie policy.

Keeping your information secure

We store personal information both electronically and in paper form.

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.

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.

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 booking, 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 share your telephone numbers if we are required to by law.

Who do we share your information with?

We may enter into partnerships with other organisations such as the police. In order 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 purposes.

• 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 HLPP Trust’s behalf which may include your personal data for the specific purposes identified. HLPP Trust has appropriate contracts in place to ensure third party data processors comply with necessary regulations:

payment services

Sometimes we 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
• safeguarding of vulnerable individuals

If we’re worried about your physical safety or feel we need to take action 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 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). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
• 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
• Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)

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 purchase contract. When your contract has ended we will keep your personal data for a set time 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 Officer

HLPP Trust

Hilsea Lido

London Road

Hilsea

Portsmouth

PO2 9RP

How to tell us of a data breach

HLPP Trust 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 tell us by emailing info@hilsea-lido.org.uk

Where can I get advice?

If you have any worries or questions about how your personal information is handled please contact our Data Protection Officer at info@hilsea-lido.org.uk

 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 (local rate) or 01625 545 745 if you prefer to use a national rate number.

Alternatively, visit ico.org.uk or email casework@ico.org.uk