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Internet Privacy & Cookies Policy
This is the internet privacy policy for énergie Global Brand Management which also trades using the following brand names:
énergie Direct Franchising
énergie Fitness
énergie Fitness Clubs
énergie Fitness for Women
Fit4Less
This website is the property of énergie Global brand Management. We take the privacy of all visitors to this Website very seriously and therefore set out in this privacy and cookies policy our position regarding certain privacy matters and the use of cookies on this website.
This policy covers all data that is shared by a visitor with us whether directly via energiegroup.com, effw.co.uk,energiefitness.com, energiefitnessclubs.com, f4l.com or via email.
This policy provides an explanation as to what happens to any personal data that you share with us, or that we collect from you either directly via this Website or via email.
Certain businesses are required under the Data Protection Act to have a data controller. For the purpose of the Data Protection Act 1998 and updates in 2018 our data controller is Dom Greenwood and can be contacted via email at dominic@energiehq.com
Information we collect
We may collect the following information:
Name
Contact information including telephone number and email address
Demographic business information
Other information relevant to customer surveys and/or offers
What we do with the information we gather
In operating our Website we may collect and process the following data about you:
Details of your visits to our Website and the resources that you access including, but not limited to, traffic data, location data, weblog statistics and other communication data.
Information that you provide by filling in forms on our Website, such as when you register to receive information such as a newsletter or contact us via the contact us page.
Information provided to us when you communicate with us for any reason.
Use of cookies
On occasion, we may gather information about your computer for our services, and to provide statistical information regarding the use of our Website to our advertisers. Such information will not identify you personally, it is statistical data about our visitors and their use of our site. This statistical data does not identify any personal details whatsoever. It is used by us to analyse how visitors interact with our websites so that we can continue to develop and improve our websites.
We may gather information about your general internet use by using a cookie file that is downloaded to your computer. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer. They help us to improve our website and the service that we provide to you.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular areas of our Website.
Any advertisement featured on this website or link to a website controlled by a third party may also incorporate cookies over which we have no control. Such cookies (if used) would be downloaded once you click on the advertisement or link to the third party website.
For more information on cookies you can read the guidance at www.allaboutcookies.org
Third Party Cookies: Google Analytics:
We may use Google Analytics for SEO purposes and to improve their online marketing efforts. For a detailed explanation of how Google Analytics cookies work and what data it gathers, please visit: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Sharing Your Information With Our Partners
We partner with certain organisations to carry out certain aspects of our operation. For example, we use a company called Harlands to make direct debit collections on our behalf for members of our clubs in the UK. We share with Harlands all of the information which is necessary to make these collections and in order for them to be able to meet their obligations under the Direct Debit Guarantee Scheme.
Storing your personal data
We may transfer data that we collect from you to locations outside of the European Economic area for processing and storing. In addition, it may be processed by staff operating outside the European Economic area who work for us or for one of our suppliers. For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your data is treated securely and in agreement with this privacy policy.
Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into via our site will be encrypted to ensure its safety.
The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential.
Policy for use of CCTV in énergie Clubs
1. Introduction
The énergie group operates a health and fitness franchise business in the United Kingdom as well as in several other countries.
This is the policy for the use of CCTV in clubs operating under the following brands in England and Wales:
• énergie Fitness
• énergie Fitness Clubs
• énergie Fitness for Women
• Fit4Less
2. Purpose of the Policy
The purpose of this policy is to make a clear statement of the way in which énergie, and the clubs operating under its various brands in the United Kingdom, make use of CCTV.
The policy describes the following:
• The rationale for using CCTV
• The areas in which we use CCTV and the areas in which we do not use CCTV
• How we make members of the public, staff who work in the clubs and any other visitors aware of the fact that CCTV is in operation
• How we store the recorded images and how long we keep them for before destroying them
• The circumstances under which we would consider releasing the images to a third party such as the police or other law enforcement agencies
• Request from individuals who believe they have appeared images captured on CCTV – Data Access Requests
• Responsibilities
• Our use of security companies
3. Rationale for the Use of CCTV
CCTV allows us to monitor activity in and around our clubs. It can be used to help us investigate the actions of individuals in connection with specific events such as an accident, theft or assault.
The main reasons we use CCTV include, but are not limited to, the following:
• To protect the health and safety of visitors and staff
• To help us to ensure that club rules are respected
• To help with training and giving feedback to our staff
• To assist the law enforcement authorities in a bid to deter and detect crime
• To protect our buildings, equipment and other resources by deterring those who might damage or steal them
• To monitor the behaviour of our staff while they are at work
• To investigate whether there is any fraudulent use of our clubs, for example, when a membership card or fob is used by an individual other than the one to whom it was issued
4. The Areas in which we Use CCTV
The layout of our clubs varies from site to site. However, in general terms, we would use CCTV in the following areas:
• In the reception area
• On the main gym floor
• In the studio if there is one
• In the free weights area
• In the corridors and stairwells
• In the areas around the outside of the building including the car park if there is one – this could include areas such as the pavement or a road which were used by members of the public who have no connection with énergie or any of it franchises or clubs
• In areas used by staff which ae not normally accessible to the public, such as an office or staff room
• Any other areas not specifically mentioned in the exclusions below
We would never install CCTV in the following areas:
• Changing rooms
• Showers
• Toilets
• Sauna/steam room
5. How we Publicise our Use of CCTV
We make members of the public, staff who work in the clubs and any other visitors aware of the fact that CCTV is in operation by displaying prominent signage such as the example shown below:
cctv
A sign such as the above would be displayed in each area in which a camera was located. We will also publicise the reasons why we are making recordings as well as the contact details for the data controller. For example, by display information such as the following:
WARNING CCTV cameras in operation
Images are being monitored and recorded for the purpose of crime-prevention, for the safety of our staff and visitors and for the protection of énergie fitness, its franchisees and their property. This system will be in operation 24 hours a day, every day. These images may be passed to the police or any law enforcement authority
This scheme is controlled by énergie Global Brand Management and operated by The Control Group
For more information contact 0845 363 1020
We do not conceal our cameras. They are clearly visible and would be recognisable by the overwhelming majority of the public. We are very happy to point out the location of all cameras in areas normally accessible to the public to any person who makes a request to have this happen.
6. Storing of Recorded Images
We store the images we record in two main ways:
• In a small and reducing number of clubs, we store images on a hard drive located in a secure area of the club
• In the majority of clubs, and in all new clubs, we store images on a secure server in the cloud
In all cases, these stored images are accessible only by properly authorised individuals. Access to them is protected by passwords and other security. Supervising access to the images and maintenance of the CCTV systems are the responsibility of the franchisee or club manager.
Images are normally stored for 30 days before being automatically deleted. Images of specific events or incidents might be kept much longer than this, particularly, although not exclusively, if they were connected with an accident or were the subject of a police investigation.
7. Release of Images to Third Parties
We would release images to third parties outside of the énergie group under very limited circumstances which would include the following:
• Requests from the police and other law enforcement authorities for images taken at a specific time or over a specific period
• To data subjects (or their legal representatives), pursuant to an access request where the time, date and location of the recordings is furnished to énergie Global Brand Management or one of its franchisees – see Access requests below
• Any other circumstances where we were legally obliged to do so, for example in connection with legal proceedings resulting from an accident
• To an agent we had appointed to act on our behalf, for example, to a lawyer or barrister we had appointed to act for us or one of our franchisees following an assault.
8. Data Access Requests
Any person whose image has been recorded has a right, on written request, to be given a copy of the information recorded which relates to them, provided always that such an image/recording exists i.e. has not been deleted and provided also that an exemption/prohibition does not apply to the release. Where the image/recording identifies other individuals, those images may only be released where they can be redacted/anonymised so that no other individual is identifiable. To exercise their right of access, a data subject must make an application in writing to énergie Global Brand Management or the franchisee which owns the club in qeuestion.
An applicant should provide all the necessary information to assist énergie Global Brand Management or its franchisee in locating the CCTV recorded data, such as the date, time and location of the recording. If the image is of such poor quality as not to clearly identify an individual, that image may not be considered to be personal data and may not be handed over.
In giving a person a copy of their data, the énergie Global Brand Management or its franchisee may provide a still/series of still pictures, a tape or a disk with relevant images. However, other images of other individuals will be obscured before the data is released.
9. Responsibilities
Our franchisees are responsible for the operation of the clubs which they own, except in the case the clubs are owned directly by énergie Global Brand Managament or one of its subsidiaries. Compliance to this policy is part of the operation of each club and will be scrutinised as part of the audit process to which every club is periodically subjected. 10. Security Companies
The CCTV systems in use in énergie’s clubs are controlled by a security company contracted by énergie Global Brand Management and its franchisees.
The contract with the security company details the areas to be monitored, how long data is to be stored, what the security company may do with the data, what security standards should be in place and what verification procedures apply. The contract also states that the security company will give the fitness club all reasonable assistance to deal with any subject access requests made under section 4 of the Data Protection Acts 1988 and 2003 which may be received by the club.
Security companies that place and operate cameras on behalf of clients are considered to be “Data Processors.” As data processors, they operate under the instruction of data controllers (their clients). Sections 2(2) and 2C of the Data Protection Acts place a number of obligations on data processors. These include having appropriate security measures in place to prevent unauthorised access to, or unauthorised alteration, disclosure or destruction of, the data, in particular where the processing involves the transmission of data over a network and against all unlawful forms of processing. This obligation is met by having appropriate access controls to image storage or having robust encryption where remote access to live recording is permitted. Staff of the security company have been made aware of their obligations relating to the security of data.
11. Contacting us
We welcome any queries, comments or requests you may have regarding this policy please do not hesitate to contact us via the website www.energiefitness.com
If you would prefer to write to us, then our contact address is:
CCTV Use Enquiries
énergie Central
1 Pitfield
Kiln Farm
Milton Keynes
Buckinghamshire
MK11 3LW
12. Revision History
Version Date Of Revision Author Description Of Changes
1.0 28th May 2017 David Waugh Initial Version
APPENDIX 1 – DEFINITIONS
Definitions of words/phrases used in relation to the protection of personal data and referred to in the text of the policy;
CCTV – Closed-circuit television is the use of video cameras to transmit a signal to a specific place on a limited set of monitors. The images may then be recorded on video tape or DVD or other digital recording mechanism.
The Data Protection Acts – The Data Protection Acts 1988 and 2003 confer rights on individuals as well as responsibilities on those persons handling, processing, managing and controlling personal data. All staff must comply with the provisions of the Data Protection Acts when collecting and storing personal information. This applies to personal information relating both to employees of the organisation and individuals who interact with the organisation
Data – information in a form that can be processed. It includes automated or electronic data (any information on computer or information recorded with the intention of putting it on computer) and manual data (information that is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system).
Personal Data – Data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller.
Access Request – this is where a person makes a request to the organisation for the disclosure of their personal data under Section 3 and/or section 4 of the Data Protection Acts.
Data Processing – performing any operation or set of operations on data, including:
– Obtaining, recording or keeping the data,
– Collecting, organising, storing, altering or adapting the data,
– Retrieving, consulting or using the data,
– Disclosing the data by transmitting, disseminating or otherwise making it available,
– Aligning, combining, blocking, erasing or destroying the data.
Data Subject – an individual who is the subject of personal data.
Data Controller – a person who (either alone or with others) controls the contents and use of personal data.
Data Processor – a person who processes personal information on behalf of a data controller, but does not include an employee of a data controller who processes such data in the course of their employment, for example, this might mean an employee of an organisation to which the data controller out-sources work. The Data Protection Acts place responsibilities on such entities in relation to their processing of the data.
APPENDIX 2 – PRIVACY IMPACT ASSESSMENT
In deciding that we will routinely install CCTV in our clubs we undertaken a privacy impact assessment which considered the points listed below and the outcomes of this assessment have informed this policy:
• What is the club’s purpose for using CCTV images? What are the issues/problems it is meant to address?
• Is the system necessary to address a pressing need, such as staff and visitor safety or crime prevention?
• Is it justified under the circumstances?
• Is it proportionate to the problem it is designed to deal with?
• What are the benefits to be gained from its use?
• Can CCTV systems realistically deliver these benefits? Can less privacy-intrusive solutions, such as improved lighting, achieve the same objectives?
• Does the club need images of identifiable individuals, or could the system use other images which are not capable of identifying the individual?
• Will the system being considered deliver the desired benefits now and remain suitable in the future?
• What are the views of those who will be under CCTV surveillance?
• What could be done to minimise intrusion for those whose images may be captured?
• How have staff, members and visitors been assured by the club that they will not be monitored and that the CCTV system will be used only for the stated purposes?
• Does the clubs policy on the use of CCTV make it clear that staff will be monitored for performance or conduct purposes?
• Have the views of staff & members regarding the location of cameras been taken into account?
• Can the location of each internal camera be justified in accordance with the overall purpose for the use of the CCTV system?
An Énergie Master Franchise owned and operated by Namish Inernational under license by Énergie Global Franchising Ltd. and trading as Énergie Fitness India
Copyright © Énergie Fitness India 2022
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