Policies

Legacy XS Management Ltd.

Privacy Policy

At Legacy XS, we care about the privacy of the people who use our services, and this Policy explains how we deal with your personal information.
Throughout this policy, whenever we use the words ‘you’ or ‘your’, this should also be read to include ‘your child’, where you have provided information and consent on behalf of a minor for whom you are responsible.

  1. What type of information does Legacy XS collect about you?
    We collect certain personal information about our customers which allows us to identify you as an individual and which is about you. Depending on your relationship with us and which of our services you are using this may include your name, contact details, date of birth, details of next of kin, details of allergies and medical conditions, and/or a passport-style photograph.
    We limit our use of information which allows us to identify you as a named individual to the details we need to provide the requested Service to you.
    We only collect any sensitive personal information from or about you if it is essential to protect your health whilst using our services; for example, we collect details about your allergies or medical conditions to allow us to safely offer first aid.
    We may store your personal information in both electronic and/or hard copy format.
  2. How does Legacy XS collect your personal information?
    We will normally collect personal information directly from you when you volunteer it to us, or when someone else (such as a parent or trip organiser) gives it to us on your behalf.
    We may also collect additional personal information about you in the course of the provision of our services; for example, CCTV is in use at the Legacy XS skatepark.
    Additionally, photography (both video and still) for publicity purposes is often in use within the skatepark or during our events and activities. This will normally be ‘group shots’ or ‘action shots’ where your personal data is not the primary focus of the photography; if you have any objection to such photography please make it known to a member of Legacy XS staff at the time. If we wish to take individual photographs or video recordings that are specifically focussed on you then we will always ask for your specific consent at the time.
  3. Why does Legacy XS use your personal information?
    Legacy XS may use your personal information for a variety of purposes, depending upon the service you have requested or are using. Normally, this will simply be to do what you have requested, such as to deal with your enquiry, give you access to the skatepark, manage your membership, or manage your attendance at one of our clubs or activities.
    Other uses of personal information will be to ensure that Legacy XS can meet its legal, regulatory and good governance obligations, such as meeting accounting or insurance requirements.
    In carrying out the above, Legacy XS processes your personal data in a variety of ways, each of which may have a different legal basis, which you will be informed of at the point where we collect you information. We may process your personal data because:
    • It is necessary for the performance of a contract with you (e.g. the purchase of membership or other goods or services)
    • We are under a legal obligation to do so (e.g. for health & safety monitoring purposes)
    • It is in your vital interests (e.g. provision of data about allergies and medical conditions)
  4. Does Legacy XS share personal information with third parties?
    Your personal information will be made available to those members of our staff who need to see it in order to perform their functions/roles/responsibilities at Legacy XS in respect of the Services you have requested or agreed to use.
    Your personal information may be held by us in a membership management database, to ensure we have clear and accurate records about your use of our Services. This database is backed up to Google Drive, which means that your personal data may be stored in the United States of America. Standard Google Inc terms and conditions (which include the US Privacy Shield provisions) apply, and can be found online at https://policies.google.com/privacy.
    We may share personal information within Legacy XS’ directors as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding our service offering, order or customer request fulfilment.
    Where thought necessary by Legacy XS, in limited cases, your personal information may also be shared with other people and organisations outside Legacy XS to the extent permitted or required by law, such as
    • government authorities, law enforcement, and other regulatory authorities where required or permitted by law, and for tax or other lawful purposes
    • external parties in response to legal process, and when required to comply with laws, to respond to an emergency, or to enforce our agreements, policies, rules and terms, or to protect the rights, property or safety of our staff, customers, and other users of our services
    • parties to whom you authorise us to release your personal information
    • other entities (including actual or prospective buyers of one of our services) in the event that we are involved in a reorganization, divestment, or sale of any of our organisation and/or assets
  5. Will Legacy XS send your personal information overseas?
    You should be aware that the recipients of your personal information (as set out in this policy) may be located in countries or territories outside the European Economic Area (“EEA”) which may not have data protection laws equivalent to those in the UK.
    Where we (or our third party service providers acting on our behalf) transfer your personal information to countries outside of the EEA, we will put in place such other measures as are required by law to ensure that those transfers are adequately protected.
  6. What are your choices relating to contact from us?
    We may contact you with information that may affect your use of a service, for example, disruptions to services, closures, lost property, or in relation to breaches of our disciplinary policy. Please note that you will not be able to unsubscribe from administrative and service-related communications unless you unsubscribe from the relevant services, for example by closing your membership.
    Legacy XS will not use your contact details to send you marketing material.
    Where you sign up to Legacy XS’ presence on social media platforms such as Facebook, we will only contact you directly (e.g. by ‘private message’) in response to a request or query made by you.
  7. How does Legacy XS keep your personal information safe?
    Legacy XS takes steps to seek to protect the security of your personal information, in accordance with our legal obligations, both in hardcopy and electronic form.
    Please note that we cannot guarantee the security of any transmission of personal information over the Internet. Communications sent over the Internet, such as emails, are not necessarily secure. While we strive to protect your personal information, we cannot guarantee the security of any information transmitted to us over the internet. Therefore, please do not submit personal information to us online unless you accept the security risks of doing so.
  8. What are your rights in relation to your personal information?
    You have a number of legal rights in relation to your personal information.
    You are entitled to:
    • request copies of, and/or access to your personal information.
    • request that your personal information be corrected where inaccurate or incomplete
    • request that your personal data be deleted (or that we stop using your personal data) where it is no longer necessary
  9. Retaining your personal information, we will keep your details on record until we have completely dealt with your request, enquiry, or our contract with you, and then for a reasonable period afterwards, in accordance with data protection and other applicable legislation. Legacy XS may keep your details on record for as long as is necessary for the purposes for which it may use your personal information, as set in Section 3 of this policy. If Legacy XS decides that holding your details is no longer necessary we will securely delete / destroy your details. In general, we will retain the personal information that you have provided to us for seven years since your last contact with us, for the purposes of audit, analysis and customer management, and the defence of legal claims.
  10. Changes to this Privacy Policy. We may change this policy from time to time to reflect changes in the law and/or our privacy practices. We will update the date at the bottom of this page whenever we do that. We encourage you to check this policy (and any other policies we have provided to you) for changes, for example when you revisit our websites.
  11. By submitting your personal information to us, you are indicating that you consent to our use of your personal information as described in this policy (as amended from time to time).

In some cases, these rights are subject to certain conditions and limitations. If you would like more details about these rights, or to exercise any of your rights, please contact Legacy XS in writing at:
Legacy XS Management Ltd
20 Lambeth Road, Benfleet, Essex SS7 4BN
Email: xslegacymanager@gmail.com

Any request received will be processed within one calendar month of Legacy XS accepting your request.
To help us identify the personal information you are referring to, please include any details that will enable us to locate the relevant personal information.
In order to be sure that your personal information is not disclosed to an imposter, we may require you to provide us with proof of identity before any action is taken or personal information is disclosed.
If you are unhappy with our response to such a request you may then complain to the Information Commissioner’s Office (ICO). Details on how to do so can be found on the ICO’s website at https://ico.org.uk/.

DATE: 1/1/24

Safeguarding statement

Legacy XS Ltd takes seriously its responsibility to protect and safeguard the welfare of children and
vulnerable adults.

This Safeguarding Statement applies to all who make up the charity’s ‘workforce’ whether paid or
unpaid, who hold positions of responsibility and work with children or vulnerable adults.

For the purposes of this document the term Charity is used to denote the Trustees who are together
responsible for ensuring that safeguarding policies and procedures are implemented.
For the purposes of this document a child is anyone under the age of eighteen years.

Policy

  1. Legacy XS Ltd has adopted the Church of England Safeguarding Policy 2018.
    A copy of the full relevant policy is obtainable on the Church of England website
    http://www.churchofengland.org/more/safeguarding and a hard copy is kept accessible in the main office.
  2. The Safeguarding Representative at Legacy XS is Matthew Rose and has been appointed by the Trustees.
    Our commitments
    • Promoting a safe environment and culture.
    • Safely recruit and support all those with any responsibility related to children and vulnerable adults..
    • Respond promptly to every safeguarding concern or allegation.
    • Care pastorally for victims/survivors of abuse or other affected persons.
    • Care pastorally for those who are the subject of concerns/allegations of abuse and other affected persons.
    • Respond to those that may pose a present risk.
    To bring this about we will:
    • Formally adopt the Church of England Safeguarding Policy.
    • Review the implementation of the Church of England Safeguarding Policy annually
    • Include Safeguarding as a standing item at Trustee meetings.
    • Ensure that all those authorised to work with children and vulnerable adults are
    appropriately recruited according to safer recruitment practice and are adequately
    supported.
    • Ensure that all those authorised to work with children and vulnerable adults are trained appropriately for their roles
    • Provide appropriate insurance cover for all activities undertaken which involve children or vulnerable adults.
    • Ensure that a Risk Assessment is completed and reviewed (at least once a year) for each activity, which is associated with either children or vulnerable adults and run in the name of the Charity.
    • Comply with Data Protection Principles1 – specifically with reference to storing information
    about the workforce, including volunteers, who have completed a confidential declaration and/or undergone DBS checks.

If you are concerned…..that someone or someone you know is at risk of, or is being abused, or
presents a risk to others, please seek advice from a Safeguarding Advisor or if necessary report the
matter to the Local Authority Social Care Services or the Police without delay.

Local contacts available to speak to if you have any concerns:
Matthew Rose (Legacy XS’ Safeguarding Representative)
01268 565650
matt.rose.legacyxs@gmail.com

Diocesan Safeguarding Team (DST)
01245 294438
safeguarding@chelmsford.anglican.org

Essex Social Care (Concerns about an Adult’s welfare)
0345 603 7630
emergency.DutyTeamOutOfHours@essex.gov.uk

Essex Social Care (Concerns about an Child’s welfare)
0345 603 7627
emergency.DutyTeamOutOfHours@essex.gov.uk

If there is an immediate risk of harm to a child or vulnerable adult then contact the Police on
999

Helplines
NSPCC: 0808 800 5000
Family Lives: 0808 800 2222
Childline: 0800 1111
National Domestic Violence Stop It Now: 0808 1000 900
NAPAC: 0808 801 0331
Helpline: 0808 2000 247
Action on Elder Abuse: 0808 808 8141
Samaritans: 116 123

Revd Peter Hillman – Chair of Trustees
1/1/24