Service: Scarborough Spa
The following information provides details on how we may collect use and where appropriate share personal information in accordance with the General Data Protection Regulations (GDPR). It should be read in conjunction with Scarborough Borough Council’s privacy notice document.
We obtain information about you when you use our website, for example, when you contact us about products and services, or if you register to receive one of our newsletters. We will also collect information from you when you use any of our products and services or receive support from us.
Why we collect your Personal data
We collect your personal data to understand your needs and provide you with a better service. We collect information about you in order to provide services, comply with regulations, and to build stronger relationships. We may collect information on paper or online forms, by telephone, email or a member of our team may collect information from you in person.We may use your information for the following reasons:
• To process bookings for room hire
• If you contact us with a query or for more information
• If you wish to sign up to our newsletters
• To periodically send you communications, which you have requested, and that may be of interest to you. These may include information about our campaigns activities, and promotions.
• contact you by post, email or telephone;
• understand your needs to provide the services that you ask for or need;
• understand what we can do for you and inform you of other relevant services and benefits;
• ask your opinion about our services;
• update your customer record;
• help us to build up a picture of how we are performing at delivering services to you and what services may need;
We may need to pass your information to other people and organisations that provide a service on our behalf. These providers are obliged to keep your details securely, and use them only to provide the service to you in accordance with our instructions.
Personal Information you give to us:
You give us your personal information
• when you apply for our products and services
• when you talk to us on the phone or at one of our reception areas
• when you use our websites, mobile device apps
• in emails and letters
• In customer surveys
• if you take part in our consultations, questionnaires or promotions
• When you engage with us on social media (by mentioning/tagging us or by contacting us directly)
What Personal data we collect
The personal data we collect from you directly can include your name, email address, mobile/landline telephone number, date of birth, address, your purchasing activity, your credit, or debit card or other payment information, and information you give us when you contact our customer services team, when you engage with our social media platform (for example by tagging us in a post) or when you sign up for any of our membership activities.
If you are using a mobile device and shopping with us online or browsing our website, we may collect your IP address or other device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other portable device information.
Where you are using a mobile device whilst in one of our venues with its WiFi capability switched on or have access to our free in-venue WiFi, we may additionally collect your MAC address and location data whilst you are within our venues or immediately within its perimeters. If you do not want us to track your device or use your information in this way, please turn off the WiFi capability on your phone or other electronic device within your settings.
All of our transactions automatically take place on a secure server. All of your personal information is encrypted before it is transmitted over the Internet.
For further details about how we define personal data and non-personal data please see our Data Protection Policy.
We may monitor and record electronic communications (website, social media, email and phone conversations) for a number of reasons such as:
• staff training
• records of conversations
• the detection, investigation and prevention of crime
We will inform you if your call is being recorded or monitored.
Emails that we send to you or you send to us, may be retained as a record of contact and your email address stored for future use in accordance with our retention periods. If we need to email sensitive or confidential information to you, we may perform checks to verify the correct email address and may take additional security measures.
How we use your personal data
We'll only use your personal data in accordance with data protection legislation, and for the purposes stated in this privacy notice.
• only ask for what is necessary for the purposes of dealing with your request or enquiry
• protect it and make sure nobody has access to it who shouldn’t
• ensure you know if you have a choice about giving us personal data
• only share your personal data with other Scarborough Borough Council departments or with external partners, agencies and contractors involved in delivering services on our behalf, eg, brochure distribution companies.
• make sure we don’t keep it for longer than is necessary
• delete or destroy it securely when we no longer have a need to keep it
We use your personal data to provide you with the information, products and services that you request or purchase from us (i.e. to complete certain tasks, processes or orders on our website or within our apps, take payment online (where applicable) and deliver your products or services), and to communicate with you regarding those products and services that you purchase from us and respond to your questions and comments;
We may also use your personal data to measure how satisfied our customers are and provide customer service (including troubleshooting in connection with purchases or your requests for services or when you ask us questions on social media);
For administrative and internal business purposes We may use your personal data for our internal business purposes, such as enhancing our site, improving our services and products and identifying usage trends. We may also use your data to monitor the use of our website and ensure that our website is presented in the most effective and relevant manner for you and your device and setting default options for you (such as language and store location);
It is in our legitimate interests as a business to use your personal data in this way. For example, we want to ensure our website is customer friendly and works properly and that our products and services are efficient and of high quality. We also want to make it easy for you to interact with us. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
For security and legal reasons
We use your personal data to:
• ensure the personal and financial information you provide us is accurate;
• conduct fraud checks or prevent other illegal activity;
• protect our rights or property (or those of others); and
• fulfil our legal and compliance-related obligations.
In some cases we will use your personal data because it's necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
In relation to your experience with us
We use your personal data to personalise your experience, to:
• provide you with marketing material via SMS, post and email if you have given us your consent to this;
• process your registration details, account activity and purchase history to analyse how you use our services;
• in some instances we will send specific offers to our customers based on their attendances or on a special occasion such as when we know it's your birthday;
• measure the effectiveness of our marketing campaigns and our advertising;
We rely on your consent to send direct SMS, postal and email marketing messages based on the consent we acquired from you when you signed up, as amended by you from time to time.
In other cases (for example, measuring the effectiveness of our marketing), we will rely on our legitimate interests as a business to communicate with you in an engaging and efficient way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
To personalise and improve our operations
We use your personal data to:
• provide you with marketing material;
• analyse the activities you use. This allows us to provide a browsing experience which is relevant to you.
It is in our legitimate interests as a business to use your data in this way and we do this in order to enhance your experience with us. This allows us to help you find services most relevant to you.
When we send you marketing material, we will rely on our legitimate interests as a business, always ensuring that your rights are protected.
We ask that you:
• give us accurate information
• tell us as soon as possible of any changes
• tell us as soon as possible if you notice mistakes in the information we hold about you
From time to time, we may conduct or ask you to take part in a survey to get your feedback, comments and opinions to help us improve our services.
Marketing - Your choices
We would like to send you information about our products and services which may be of interest to you. You have a choice about whether or not you wish to receive information from us and we will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted.
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind (opt-out) at any time. You can also change your marketing preferences at any time by contacting us by writing to or emailing us.
Who we share your personal data with
Any information we use in presentations or reports will be anonymised and will not identify any individuals. For example a report on the numbers of accommodation bookings made will not feature any of your personal data.
We do not disclose or share sensitive or confidential information without your explicit consent except where disclosure is required by law, or where we have good reason to believe that failing to do so, would put you or someone else at risk.
We may be required or permitted, under data protection legislation, to disclose your personal data without your explicit consent, for example if we have a legal obligation to do so, such as for:
• law enforcement
• fraud investigations
• regulation and licensing
• criminal prosecutions
• court proceedings
We must protect public funds and may use personal data and data-matching techniques to detect and prevent fraud, collect taxes and ensure public money is targeted and spent in the most appropriate and cost-effective way. To do this, your personal data may be shared with other bodies responsible for auditing or administering public funds, including the Department for Work and Pensions, HM Revenue and Customs, the Police and other local authorities.
Our legal basis for collecting and sharing personal data
There are a number of legal reasons why we need to collect and use your personal information. For this service:
6.1 (a) – Consent: you have given your consent. For example, you have signed up to receive marketing information from us.
6.1 (b) Contract: you have entered into a contract with us. For example, room hire and event bookings.
6.1 (f) Legitimate Interests: Alternatively, in some cases, we rely on our legitimate interests as a business (for example, to measure customer satisfaction and troubleshoot customer issues). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
How long we keep your personal data
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We will keep your personal data as set out in our Retention Policy. We will delete or destroy your personal data securely.
At the end of the retention period, we may pass any relevant information to the Archives where it is required or appropriate to do so.
Further processing of your personal data
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we'll provide you with a new notice.
The new notice will:
• explain this new use before we start the processing
• set out the relevant purposes and processing conditions
Where and whenever necessary, we'll seek your consent to the new processing, if we start to use your personal data for a purpose not mentioned in this Privacy Notice.
If you use any of our social network pages or applications or you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts. For instance:
• If you click on a ‘like’, ‘+1’ or ‘tweet’ or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you
• If you ‘like’, ‘+1’ or similar one of our pages on a social network site, we may receive information about your social network profile, depending on your social network account privacy settings.
Reviews, comments and conten
Where you have uploaded product reviews, comments or content to our websites or services and made them publicly visible, we may link to, publish or publicise these materials elsewhere including in our own advertisements.
Links to third party site
Some of our websites may contain links to other third party websites that are not operated by us. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those third party websites. We strongly encourage you to view the privacy and cookie policies displayed on those third party websites to find out how your personal information may be used.
Your rights relating to your personal data
If you no longer wish to be contacted by us about our products or services, or for other marketing purposes, you can amend your preferences or unsubscribe at any point. You can unsubscribe by amending your preference in your online account, following the unsubscribe link provided in our emails or by contacting us.
We want to ensure that all the information we have about our customers is factually correct and up to date. If you find that the personal data we have about you is inaccurate or needs updating (for instance, you may have changed your name or address) then please contact us so that we can correct it. When we collect your personal data we'll tell you how we are going to use it. Where we process your personal data, you have a number of rights under data protection law.
To find out about your rights under data protection law, you can go to the Information Commissioners Office (ICO) https://ico.org.uk/for-the-public/
You can also find information about your rights at https://www.scarborough.gov.uk/home/open-data-and-foi/gdpr
What if I have a concern or complaint?
If you have any questions, want to exercise your rights, or if you have a complaint about how your information has been used, please contact us at [email protected] or on 01723 232323 or write to:
Data Protection Officer
Scarborough Borough Council
St Nicholas Street