Policy prepared by Beverley Proctor. Policy became operational on 21/05/2018. Next review date: 20/07/2020

Data Protection Policy

Context and Overview

About Us

Head Over Heels needs to gather and use certain information about individuals.

These can include customers, suppliers, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Head Over Heels:

  • Complies with data protection law and follow good practice 

  • Protects the rights of staff, customers and partners

  • Is open about how it stores and processes individuals’ data

  • Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations must collect, handle and store personal information. 

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.



Everyone who works for the company has some responsibility for ensuring data is collected, stored and handled appropriately.

Each individual that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

  • The partners (Kate Humphries and Beverley Proctor) are ultimately responsible for ensuring that Head Over Heels meets its legal obligations.

  • The partners are responsible for:

    • Keeping the team updated about data protection responsibilities, risks and issues.

    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.

    • Arranging data protection training and advice for the people covered by this policy.

    • Handling data protection questions from staff and anyone else covered by this policy.

    • Dealing with requests from individuals to see the data Head Over Heels holds about them (also called ‘subject access requests’).

    • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data. 

    • Approving any data protection statements attached to communications such as emails and letters.

    • Addressing any data protection queries from journalists or media outlets like newspapers.

    • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

  • The data processor, Paysubsonline is responsible for:

    • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

    • Performing regular checks and scans to ensure security hardware and software is functioning properly.

    • Evaluating any third-party services the company is considering using to store or process data. 



  • The only people able to access data covered by this policy should be those who need it for their work.

  • Data should not be shared informally

  • Head Over Heels will provide training to all employees to help them understand their responsibilities when handling data. This will be done for all staff annually/on induction.

  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

  • In particular, strong passwords must be used and they should never be shared.

  • All laptops and ipads should ‘auto lock’ after 30 seconds

  • Personal data should not be disclosed to unauthorised people, either within the company or externally.

  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

  • Team members should request help from their head coach if they are unsure about any aspect of data protection. 



These rules describe how and where data should be safely stored. 

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.

  • Head Over Heels team should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.

  • Data printouts should be disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.

  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.

  • If data is stored via a 3rd party e.g. Paysubsonline, , written confirmation of GDPR compliance must be obtained.



Personal data is of no value to Head Over Heels unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, team members should ensure the screens of their laptops/ipads are always locked when left unattended.

  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure. (?????)

  • Personal data should never be transferred outside of the European Economic Area.

  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

  • The following guidelines should be followed when contacting members :

      • Only contact former members who have used the service within the last 24 months. Time period based on known returning cycles

      • Only contact drop outs within 6 months of their last visit. ????????

  • Clear opt out option must be included on all communication



All individuals who are the subject of personal data held by Head Over Heels are entitled to:

  • Ask what information Head Over Heels holds about them and why.

  • Ask how to gain access to it.

  • Be informed how to keep it up to date

  • Be informed how the company is meeting its data protection obligations.


If an individual contacts Head Over Heels requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to info@hohgymnastics.co.uk.

Individuals will be charged £10 per subject access request. Head Over Heels will aim to provide the relevant data within 14 days.

Head Over Heels will always verify the identity of anyone making a subject access request before handing over any information.


In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Head Over Heels will disclose requested data. 



Head Over Heels aims to ensure that individuals are aware that their data is being processed and that they understand:

  • How the data is being used

  • How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

This is available on request. A version of this statement is also available on the company’s website.