Active health privacy notice

Purpose 

This privacy notice explains how High Life Highland collects, uses, stores and protects your personal information in relation to Active Health exercise programmes for people managing specific health conditions, including cancer, cardiac conditions, falls risk, and Parkinson's.

Who We Are 

High Life Highland delivers Active Health exercise programmes, designed to support people managing specific health conditions, across the Highlands.

Data Controller: The Highland Council

Where High Life Highland delivers services on behalf of The Highland Council, your personal information may be processed under the instructions of The Highland Council as Data Controller.

What Information We Collect 

We may collect:

• Name
• Address, telephone number and email address
• Date of birth
• Emergency contact details
• Details of the health professional who referred you, where you were referred to the programme (for example NHS Highland)
• Information about the health condition relevant to your participation (for example a cancer diagnosis, a cardiac event, a Parkinson's diagnosis, or falls risk)
• Attendance records

We will only collect information that is necessary for the purpose outlined above.

Special Category Data 

Where required, we may collect special category personal information such as:

• Health information relating to the specific condition for which you are attending Active Health (for example cancer, cardiac conditions, falls risk, or Parkinson's)

Where this applies, we will process this information in accordance with UK GDPR and applicable legislation.

Why We Use Your Information 

We use your personal information to:

• Assess your suitability and needs for the programme
• Deliver exercise sessions tailored to your condition
• Contact you about bookings and sessions
• Ensure your safety during sessions

Lawful Basis for Processing 

We process your information under the following lawful basis:

• Consent (Article 6(1)(a))
• Explicit consent (Article 9(2)(a))

Additional Conditions for Special Category Data

Where special category data is processed, the following condition(s) apply:

If You Do Not Provide Information 

If you choose not to provide the information requested, we may be unable to:

• Assess your suitability for the programme
• Deliver a safe and appropriate exercise programme for you

Where We Did Not Collect Your Information Directly From You

Where you have been referred to Active Health by your GP, NHS Highland, or another healthcare professional, we will have received your name, contact details and relevant health information from them as part of that referral, in addition to any information you give us directly.

Who We Share Information With 

We may share information with:

• Trusted third-party software providers

Information will only be shared where there is a lawful basis to do so. For details of our data processors, please visit: Data processors | High Life Highland
 

International Transfers 

Your information is normally processed within the United Kingdom.

Where information is transferred outside the UK, appropriate safeguards will be in place to protect your personal information.

How Long We Keep Information 

Your information will be retained in accordance with High Life Highland's Retention Schedule.

Retention Period: We will retain your data while you are an active participant. Your data will be removed two years after your last engagement with Active Health.

Once the retention period has expired, your information will be securely deleted or anonymised.

Automated Decision Making and Profiling 

Your personal information is not subject to automated decision-making or profiling.

Your Rights 

Under UK GDPR, you have the right to:

• Access your personal information
• Request correction of inaccurate information
• Request erasure of your information in certain circumstances
• Restrict processing in certain circumstances
• Object to processing in certain circumstances
• Request data portability where applicable
• Withdraw consent at any time where consent is the lawful basis

For more information about your rights, visit: Your data protection rights | High Life Highland

Data Protection Officer 

If you have any questions about how your information is used, please contact:

Data Protection Officer
Highland Council
Headquarters
Glenurquhart Road
IV3 5NX

Email: DPO@highland.gov.uk
Telephone: 01463 702029

Complaints 

If you are unhappy with how your personal information has been handled, you may contact:

Information Commissioner's Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Website: https://ico.org.uk