Privacy Policy
Privacy Notice Active Trowbridge
1. Introduction
Active Trowbridge collects and uses personal information about you and/or your child so that we can run activities, manage bookings, deliver services safely, and meet our legal responsibilities.
For the purposes of this notice, Active Trowbridge includes:
- Active in Your Park
- Sport Roadshows
- Active Festival
- Holiday Camps
- Walking Sports
- Active Extras
- School Coaching
- Tennis court bookings at Trowbridge Park (including MUGA and memberships)
This Privacy Notice does not apply to wider processing by Trowbridge Town Council or its other services (for example Civic services or the museum). Please refer to the relevant service privacy notices for those activities.
Data controller
Trowbridge Town Council is the data controller for personal data collected, stored and processed in connection with Active Trowbridge activities and services. The Council is registered with the Information Commissioner’s Office (ICO) for the purposes of processing personal data.
This notice explains what personal information we collect and how we use it.
2. How We Collect Personal Data
We collect personal data when you:
- Visit our website
- Contact Active Trowbridge by telephone, email, or website contact form
- Visit in person
- Complete a booking form (e.g. parties, inflatable hire, events, coaching)
- Make online bookings (e.g. tennis courts, MUGA, Active Tots, Active Extras, half-term camps, events)
- Enter competitions
- Make payments to us, or we make payments to you
- Complete medical / wellbeing forms (where needed for safe participation)
- Provide consent for photographs/images for promotional purposes
- Attend sites where CCTV is in operation (e.g. Civic Centre offices)
3. Purpose and Lawful Basis for Processing
We will only use personal information where the law allows us to and for the purpose for which it was collected.
| Activity | Purpose | Lawful basis (UK GDPR) |
| Website use (cookies/analytics) | Website operation, performance and improvement | Consent; Legitimate interests |
| Enquiries and contact | Responding to queries and providing information | Legitimate interests; Contract; Legal obligation |
| Bookings and delivery of activities | Managing registrations, attendance, staffing, invoicing and delivery | Contract; Legal obligation (where applicable) |
| Changes to bookings/events | Informing you of changes, cancellations or terms | Contract; Legitimate interests |
| Marketing and promotional updates | Sending newsletters/updates where you opt in | Consent |
| “Soft opt-in” updates (similar activities) | Informing you about similar activities where you have previously booked | Legitimate interests (with clear opt-out each time) |
| CCTV (where applicable) | Safety, security, incident management | See CCTV Policy |
| Complaints, claims, incidents | Investigating complaints/claims; H&S and safeguarding matters | Legal obligation; Legitimate interests |
| Competitions | Administration and contact of winners | Legitimate interests |
| Payments | Taking payments / issuing refunds / paying suppliers | Contract; Legal obligation |
| Medical / participation forms | Supporting safe participation; responding to emergencies | Vital interests (emergency); Legitimate interests (safety management) |
| Photos/images/video | Promotion of activities and services | Consent |
4. Information We Collect
We may collect, store and use the following (as relevant to the service):
- Name
- Address
- Telephone number
- Email address
- Bank account/payment details (where applicable)
- CCTV footage (where applicable)
- Photographs/video (where consent is provided)
- Date of birth (e.g. age-appropriate sessions)
- Gender (where required for administration/monitoring)
- Online identifiers (IP address, cookies)
Special category data
In limited cases we may also process more sensitive information, such as:
- Medical information (e.g. asthma, allergies, medication)
- Special educational needs and disability information (SEND)
This information is used only where needed for safe participation, appropriate support, and safeguarding.
5. Data Sharing and Transfers
Active Trowbridge uses third-party processors to securely process and store personal data. These may include providers for marketing communications, bookings, payments, and website services, such as:
- Brightside
- Campaign Monitor (Marigold)
- Clubspark
- Stripe
- GoCardless
- Social media platforms (e.g. Facebook, Instagram, X, YouTube)
We may share information where required for:
- Prevention/detection of crime (e.g. with police or other authorised bodies)
- Safeguarding concerns (with appropriate authorities)
- Handling complaints and information rights requests (internally, including the Community Engagement & Governance Manager)
We do not transfer personal data outside the UK GDPR territorial scope unless appropriate safeguards are in place.
Safeguarding
Where there are safeguarding concerns, information may be shared with relevant agencies. Data protection law does not prevent appropriate information sharing where necessary to protect children and individuals at risk. Please refer to the Active Trowbridge Safeguarding Policy.
6. When We Act as a Processor
In some situations, Active Trowbridge may act as a data processor on behalf of another organisation (the data controller), for example where:
- A school or third-party contracts us to provide coaching/activities
- We deliver sessions on behalf of Wiltshire Council
- A school contracts us to provide holiday provision (e.g. summer schools)
In these cases, we will share relevant information with the controller as required to deliver the service. Requests to exercise data rights should be directed to the data controller for that activity.
7. Retention
We retain personal data only for as long as necessary for the purposes it was collected, including legal, accounting, and reporting requirements.
Retention periods are set out in the Council’s Retention Policy and Schedule (Information Governance). When deciding retention periods, we consider:
- Amount, nature and sensitivity of the data
- Risk of harm from unauthorised access/disclosure
- Purpose of processing and alternative means
- Legal and regulatory obligations
Where appropriate, information may be anonymised and used for statistical or planning purposes.
8. Your Rights
You have the right to:
- Request access to your personal data (Subject Access Request)
- Request correction of inaccurate or incomplete data
- Request restriction of processing (including where records are approaching disposal under retention)
- Request transfer of your personal data to another party (data portability, where applicable)
- Withdraw consent (where processing is based on consent)
To exercise your rights, contact the Community Engagement & Governance Manager.
Requests relating to children
If you are requesting personal data for a child under 13, we require evidence of parental responsibility.
9. Contact Details
Community Engagement & Governance Manager
Trowbridge Town Council
St. Stephens Place
Trowbridge
BA14 8AH
informationgovernance@trowbridge.gov.uk
01225 765072
Data Protection Officer
One West
i-west@bathnes.gov.uk
01225 395959
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. However, they would normally expect you to have raised your complaint with us in the first instance.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk
0303 123 1113