Skip to content

Image Consent - Leisure

Privacy Notice for Adults (over 16 years)

This privacy notice is issued by Serco Leisure Operating Limited (“Serco”, “we”, “us”). We operate leisure facilities for or on behalf of our customers/client (Trusts and/or local authorities) under relevant management agreements. We are a controller under the data protection laws and responsible for the personal information gathered and used in connection with the photographs, film/video footage and recordings that features you (the "Image(s)"). We may amend this privacy notice to keep it up to date, and we will seek to inform you of any such changes as appropriate.

This Privacy Notice was last reviewed and updated in September 2022.

Personal information processed and collected by us

Your participation in the photography/filming is voluntary and you may withdraw your consent to be photographed/filmed at any time prior to the photography/filming. If you participate in the photography/filming, we will collect, store, and process the following personal information (as and when necessary):

  • a photograph and/or a film featuring you;
  • your name and signature;
  • your contact details (e.g. your email address or phone number);
  • parent and/or guardian status (where applicable); and
  • records of any additional communications we might have with you.

We will collect your personal information directly from you, provided to us by you or through you during the photography/filming session.

How we use your personal information, legal basis for processing and sharing with others

Your personal information is collected and used based on our or our third parties (e.g., Local Authority) legitimate interests of:

  • internal and external training, marketing, promotion and publicity purposes with respect to the Serco leisure business;
  • keeping a record of your acceptance of the relevant image release form;
  • maintaining a record of your contact details in the event we need to contact you; and
  • in connection with legal claims, compliance, regulatory and investigative purposes as necessary.

We may share your personal information with the following parties, for the purposes set out above:

  • other companies in the Serco Group within the United Kingdom and Europe who may wish to use the Image(s) but will adhere to the terms of the relevant image release form and the Serco Group data sharing arrangements;
  • the owners of the leisure centres managed by Serco (e.g. a Trust or Council), acting as a Controller, in order to promote that leisure centres activities or related promotional materials;
  • trusted third party service providers within the United Kingdom and Europe who assist with our business including marketing agencies, copyrighters, publicists, printer and information technology suppliers;
  • professional advisors including legal advisors;
  • media outlets, including local press; and
  • Government agencies and regulatory bodies.

We may disclose your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition, sale, transfer of assets or if there is a change of operator for the leisure facilities or in the event that there is a hand back of the operation to the customer/clients. Serco contracted third-party service providers are required to take appropriate security measures to protect your personal information in line with our contract and the laws. 

Security, storage and retention of personal information

We store and protect personal information in accordance with appropriate safeguards, which include the following: 

  • act reasonably to ensure that the Image(s) are accurately reproduced and featured in context;
  • where appropriate, remove additional personal information about you which may feature in the relevant Image(s);
  • a model, or their guardian (where required), is provided with and signs an image release form, which includes the conditions for Serco’s use of the personal information
  • limit access to the name and contact details of the models to those employees, agents, contractors and third parties who have a business need to know;
  • have put in place appropriate security measures to prevent your personal information from being accidentally lost or used or accessed in an unauthorised way; and
  • have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Retention

Your Image(s) will be used for internal and external training, marketing, promotion and publicity purposes for five (5) years from the date the relevant image release form was signed, at which time the Image(s) will be removed from the Serco Leisure Brand Bank and cannot be used in new projects for these purposes. However, the Image(s) will be retained in our internal records as set out below. 

Generally, we will retain your personal data collected in relation to these Image(s) in accordance with any applicable limitation period (as set out in applicable law) plus one (1) year to allow reasonable time for review and destruction of the information held. This will usually be seven (7) years from the date the Images were removed from use from the Serco Leisure Brand Bank. We will therefore usually retain personal information related to the Images for a maximum of twelve (12) years.

We may be required to retain your personal data further for the purposes of satisfying any legal, regulatory or reporting requirements or for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Legal rights

You have legal rights under data protection laws in relation to the way we hold 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); request correction of the personal information that we hold about you; request erasure of your personal information (commonly known as the "right to be forgotten"); in certain circumstances object to processing of your personal information by us or on our behalf; request the restriction of processing of your personal information; including withdraw consent to processing where the legal basis for processing is solely justified on the grounds of consent. If you would like to exercise any of these rights, please submit your requests to the address below. Please note, to ensure security of personal information, we may ask you to verify your identity before proceeding with any such request. We also reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

Contact us

The primary point of contact for all queries arising from this privacy notice or how your personal information is handled, including requests from you to exercise your rights, is at [email protected].

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing any questions about privacy in relation to the Form. If you have any question, please contact the DPO using the details set out below.

Data Protection Officer

Serco Limited,
Enterprise House
18 Bartley Wood Business Park
Bartley Way, RG27 9XB

Email:  [email protected] or Telephone: +44 (0)1256 745900.

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with your local data protection supervisory authority at any time (which in the UK is the Information Commissioner's Office).  We ask that you please attempt to resolve any issues with us first by contacting [email protected] or the DPO, before contacting your local data protection supervisory authority.

Privacy Notice for Children (0-15 years)

This privacy notice is issued by Serco Leisure Operating Limited (“Serco”, “we”, “us”). We operate leisure facilities for or on behalf of our customers/client (Trusts and/or local authorities) under relevant management agreements. We are a controller under the data protection laws and responsible for the personal information gathered and used in connection with the photographs, film/video footage and recordings that features you and/or your child (the "Image(s)"). We may amend this privacy notice to keep it up to date, and we will seek to inform you of any such changes as appropriate.   

This Privacy Notice was last reviewed and updated in September 2022.

Personal information processed and collected by us

You and/or your child/children participation in the photography/filming is voluntary and you may withdraw your consent for your child/children to be photographed/filmed at any time prior to the photography/filming. If you and/or your child/children participate in the photography/filming, we will collect, store, and process the following personal information (as and when necessary):

  • a photograph and/or a film featuring you and/or your child;
  • your name and signature;
  • your contact details (including your email address and contact number);
  • your parent and/or guardian status (where applicable); and
  • records of any additional communications we might have with you.

We will collect your personal information directly from you and/or your children through your permission, provided to us by you or through you during the photography/filming session.

How we use your personal information, legal basis for processing and sharing with others

Your personal information is collected and used based on our or our third parties (e.g. local authority) legitimate interests of:

  • internal and external training, marketing, promotion and publicity purposes with respect to the Serco leisure business;
  • keeping a record of your acceptance of the relevant image release form;
  • maintaining a record of your contact details in the event we need to contact you; and
  • in connection with legal claims, compliance, regulatory and investigative purposes as necessary.

We may share your personal information with the following parties, for the purposes set out above:

  • other companies in the Serco Group within the United Kingdom and Europe, acting as a joint controller, who may wish to use the Image(s) but will adhere to the terms of the relevant image release form and the Serco Group data sharing arrangements;
  • the owners of the leisure centres managed by Serco (e.g. a Trust or Council) in order to promote that leisure centres activities or related promotional materials;
  • trusted third party service providers within the United Kingdom and Europe who assist with our business including marketing agencies, copyrighters, publicists, printer and information technology suppliers;
  • professional advisors including legal advisors;
  • media outlets, including local press; and
  • Government agencies and regulatory bodies.

We may disclose your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition, sale, transfer of assets or in the event there is a change of operator for the leisure facilities or if there is a hand back of the operation to the customer/clients. Serco contracted third-party service providers are required to take appropriate security measures to protect your personal information in line with our contract and the laws. 

Security, storage and retention of personal information

We store and protect personal information in accordance with appropriate safeguards, which include the following: 

  • act reasonably to ensure that the Image(s) are accurately reproduced and featured in context;
  • where appropriate, remove additional personal information about you or your child which may feature in the relevant Image(s);
  • a model, or their parent/guardian, is provided with and signs an image release form, which includes the conditions for Serco’s use of the personal information;
  • limit access to the name and contact details of the models to those employees, agents, contractors and third parties who have a business need to know;
  • have put in place appropriate security measures to prevent your personal information from being accidentally lost or used or accessed in an unauthorised way; and
  • have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Retention

Your Image(s) will be used for internal and external training, marketing, promotion and publicity purposes for five (5) years from the date the relevant image release form was signed, at which time the Image(s) will be removed from the Serco Leisure Brand Band and cannot be used in new projects for these purposes. However, the Image(s) will be retained in our internal records as set out below. 

Generally, we will retain your personal data collected in relation to these Image(s) in accordance with any applicable limitation period (as set out in applicable law) plus one (1) year to allow reasonable time for review and destruction of the information held. This will usually be seven (7) years from the date the Images were removed from use from the Serco Leisure Brand Bank. We will therefore usually retain personal information related to the Images for a maximum of twelve (12) years.

We may be required to retain your personal data further for the purposes of satisfying any legal, regulatory or reporting requirements or for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or your child.

Legal rights

You have legal rights under data protection laws in relation to the way we hold 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); request correction of the personal information that we hold about you; request erasure of your personal information (commonly known as the "right to be forgotten"); in certain circumstances object to processing of your personal information by us or on our behalf; request the restriction of processing of your personal information; including withdraw consent to processing where the legal basis for processing is solely justified on the grounds of consent. If you would like to exercise any of these rights, please submit your requests to the address below. Please note, to ensure security of personal information, we may ask you to verify your identity before proceeding with any such request. We also reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

Contact us

The primary point of contact for all queries arising from this privacy notice or how your personal information is handled, including requests from you to exercise your rights, is at [email protected].

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing any questions about privacy in relation to the Form. If you have any question, please contact the DPO using the details set out below.

Data Protection Officer

Serco Limited,
Enterprise House
18 Bartley Wood Business Park
Bartley Way, RG27 9XB

Email:  [email protected] or Telephone: +44 (0)1256 745900.

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with your local data protection supervisory authority at any time (which in the UK is the Information Commissioner's Office).  We ask that you please attempt to resolve any issues with us first by contacting [email protected] or the DPO, before contacting your local data protection supervisory authority.