SEVEN STAR MARTIAL ARTS
PRIVACY POLICY (FULL GDPR NOTICE)
Issued by Seven Star Martial Arts & Fitness
1. Introduction
Seven Star Martial Arts & Fitness is committed to protecting the privacy, safety, and wellbeing of all students and families. Because we work with children, young people, and vulnerable individuals, we take data protection and safeguarding extremely seriously.
This Privacy Policy explains:
What personal data we collect
Why we collect it
How we use, store, and protect it
Who we share it with
Your rights and how you can exercise them
This notice is written clearly for parents, carers, and students so that you know exactly how your family’s information is handled.
This Privacy Policy is issued in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Who We Are
Seven Star Martial Arts & Fitness
Warehouse Rear of 17/18 London Road
Neath, SA11 1LE
We are the Data Controller, meaning we are responsible for deciding how your data is used.
Data Protection Contact:
Paul Summers
Email: [email protected]
3. The Types of Data We Collect
We collect personal data so that we can provide safe, high-quality martial arts training and meet safeguarding obligations. This includes:
A. Student Data
Full name
Date of birth
Address
Emergency contacts
Parent/guardian contact details
Attendance records
Belt/grade history
Medical or injury information relevant to training
ID photo used on DojoExpert
Photos/videos for social media (only with consent)
Instructor notes (senior students only: red belts, black belts)
B. Parent/Guardian Data
Names
Addresses
Phone numbers
Email addresses
Membership and communication preferences
Payment information (managed through secure third-party processors)
C. Sensitive / Special Category Data
Processed only where necessary and in line with safeguarding duties:
Medical needs, allergies, injuries
Doctor’s letters where participation requires medical clearance
SEN or additional support information shared voluntarily
Safeguarding disclosures, risk information, or welfare concerns
These categories are covered in more detail in the Safeguarding & Special Category Data Annex.
4. How We Collect Data
We collect data through:
Enrolment forms (signed by parents/guardians for under-18s)
DojoExpert (our membership system)
Attendance logs
Email or telephone communication
Accident or injury reports
Instructor observations (senior ranks only)
5. Why We Use Personal Data (Our Purposes)
We process data to:
A. Deliver Martial Arts Training
Register students
Track attendance
Monitor progress and belt gradings
Keep accurate class lists
Manage memberships
Provide age-appropriate and safe sessions
B. Safeguard Students and Ensure Welfare
Understand medical needs or injuries
Record accidents or incidents
Communicate with parents regarding safety or wellbeing
Share information with safeguarding authorities when legally required
C. Operate the Business
Manage payments (GoCardless, Stripe, SumUp)
Send essential updates via email, SMS, or app
Organise gradings, events, seminars, and holiday closures
Maintain accurate accounts and financial records
D. Marketing (Only with Consent)
Share photos/videos on social media
Send optional marketing updates, event news, or promotions
Use testimonials or media (with signed permission)
6. Legal Bases for Using Personal Data
We rely on the following lawful bases:
Contract
To provide martial arts training and manage membership.
Legitimate Interests
For:
Attendance tracking
Belt progression
Instructor notes for senior ranks
ID photos used internally
Essential communication with parents
These are necessary for safe and effective operation.
Consent
For:
Photos and videos for marketing
Optional marketing communications
Consent can be withdrawn at any time.
Vital Interests
For protecting a student in a life-or-death situation or medical emergency.
Legal Obligation
For:
Accident reporting
Safeguarding referrals
HMRC and accounting requirements
Substantial Public Interest (Safeguarding)
For processing sensitive data when needed to protect children or vulnerable individuals.
7. How We Store Data
Digital Systems
DojoExpert (CRM, attendance, grading records)
Outlook (email)
Dojo Login App (member access)
All accounts are password-protected, restricted by role, and cloud-backed.
Paper Systems
Enrolment forms stored in a locked filing cabinet within a restricted-access office.
Spreadsheets
Graduation/grading spreadsheets are stored on a password-protected office computer accessible only to Paul.
8. Data Sharing
We only share data when necessary, safe, and lawful.
A. Internal
Instructors: access essential attendance, risk, and safety information.
Leaders: aware only of relevant medical/additional needs for risk management.
B. External Providers
GoCardless – Direct debit payments
Stripe and SumUp – Card payments
DojoExpert – Membership, app, attendance
Outlook – Emails
SMS and Facebook Messenger – Parent communication
All of these operate under their own GDPR-compliant arrangements.
C. Social Media Platforms (With Consent Only)
Website
TikTok
D. Safeguarding Agencies
Police
Social Services
Local safeguarding board
Schools (where appropriate and lawful)
E. Insurance and Legal
Insurers
Legal representatives (if an injury claim arises)
F. IT Support and Website Maintenance
Access is limited and granted only when necessary. Confidentiality obligations apply.
9. Data Security
We use multiple layers of protection:
Physical Security
Locked filing cabinet
Restricted admin office
CCTV and alarmed building
Digital Security
Password-protected devices
Auto-locking security
Antivirus and anti-malware
Instructor devices secured by passcode/biometric access
Permission-restricted instructor accounts
No student data stored on personal computers
DojoExpert cloud storage and secure backups
10. International Data Transfers
Some third-party platforms (for example, email systems, app providers, social media) may store data outside the UK. Where this occurs, data is protected using legally approved safeguards such as Standard Contractual Clauses.
11. Retention Periods
Membership records: 3 years after leaving
Accident/injury records: until student reaches age 21
Safeguarding records: minimum 6 years, longer if required
Payment records: 6 years for legal obligations
Marketing photos/videos: kept only while consent remains active
Instructor notes (senior ranks): kept 3 years after leaving
12. Your Rights
Parents and students have the right to:
Access their data
Correct inaccurate data
Request deletion (where lawful)
Object to legitimate interest processing
Withdraw consent
Restrict processing
Request data transfer
Complain to the ICO
To exercise any right, contact: [email protected]
13. Contact & Complaints
Data Protection Contact:
Paul Summers
Email: [email protected]
If you are unhappy with how your data has been handled, you may complain to the ICO:
https://ico.org.uk/concerns
End of Privacy Policy
SEVEN STAR MARTIAL ARTS
SAFEGUARDING & SPECIAL CATEGORY DATA NOTICE
(Annex to the Privacy Policy)
Seven Star Martial Arts processes certain sensitive types of information to protect the safety, wellbeing, and rights of children, young people, and vulnerable individuals. This document explains how and why we handle this information in line with:
UK GDPR
Data Protection Act 2018
Statutory safeguarding guidance
Duty of care and common law obligations
This annex should be read alongside the main Seven Star Martial Arts Privacy Policy.
1. What Is Special Category Data?
Special category data includes information that is more sensitive and requires extra protection. At Seven Star Martial Arts, this may include:
Medical information (asthma, allergies, injuries, mobility issues, epilepsy, etc.)
Doctor’s letters confirming fitness to participate
SEN or additional support needs
Welfare or safeguarding concerns
Reports of injury or accidents
Information relating to vulnerability or risk
Disability-related information relevant to safe participation
We do not collect unnecessary sensitive data such as ethnicity, religion, or political opinions unless required for safeguarding.
2. Why We Process Special Category Data
We do this for essential safeguarding and safety reasons:
A. To protect students from harm
This includes health, injury prevention, and responding appropriately to risk.
B. To meet safeguarding obligations
We follow statutory guidance for children and vulnerable people.
C. To make reasonable adjustments
Ensuring that students with medical or additional needs can participate safely.
D. To assess risk during training
Instructors need accurate information to deliver safe physical activity.
E. To respond to incidents
We record injuries, accidents, and medical emergencies to fulfil legal duties.
F. To determine whether a student can train safely
For cases of injury or illness requiring doctor sign-off.
3. Legal Basis for Processing
Special category data is processed under the following lawful bases:
A. Vital Interests
To protect a child or individual where life or health is at risk.
B. Legal Obligation
We must record and act upon safeguarding and injury information.
C. Substantial Public Interest
Specifically under the safeguarding conditions in UK GDPR and DPA 2018.
D. Explicit Consent (where appropriate)
For example, where a parent chooses to give additional voluntary information to support their child’s wellbeing or safety.
4. How Safeguarding Information Is Collected
We collect safeguarding-related data through:
Enrolment forms
Conversations with parents
Accident/incident forms
Instructor reports
Direct disclosures from students
Doctor’s letters
Communications from schools or safeguarding agencies
Welfare concerns raised by any party
We record only what is necessary and proportionate.
5. Who Can Access Safeguarding & Medical Data
Access is strictly controlled and limited to those who need to know for safety or legal reasons.
A. Internal Access
Paul Summers (Data Controller and Safeguarding Lead) – full access
Relevant instructors – essential medical and risk information only
Senior instructors – can view necessary training and welfare information
Leaders/helpers – may be aware of additional needs or injuries, but no access to personal records
B. External Access (only where legally required)
Police
Social Services
Local Safeguarding Board
Schools (when appropriate)
Insurers or legal representatives (injury claims)
We do not share sensitive information with anyone else.
6. Instructor Notes (Senior Ranks)
Instructors maintain limited notes for senior students (red belts and black belts) to:
Monitor progression
Support leadership development
Ensure safe training
Track advanced skill work and responsibilities
These notes are not kept for Tigers, Dragons, or junior grades.
7. Injuries, Accidents, and Incident Reporting
We maintain detailed incident logs to:
Protect student safety
Monitor emerging patterns of concern
Provide evidence in the event of medical escalation
Meet legal requirements for accident reporting
Support insurance or safeguarding investigations
All accident and injury forms are stored securely and reviewed regularly.
8. Doctor’s Letters & Medical Clearances
Where a parent informs us of a significant injury, illness, or condition, we may request a doctor’s letter confirming whether it is safe for the student to participate.
This is necessary to:
Protect the student
Protect other students
Protect instructors
Ensure risk is managed professionally
These letters are stored securely and retained for the duration of the condition’s relevance.
9. Sharing Safeguarding Information
We only share safeguarding or welfare information when:
A child is at risk
A criminal offence may have occurred
There is a legal obligation
A statutory agency requests it
It is necessary to protect the life or safety of an individual
We will not tell a parent before making a referral if doing so would place the child or another person at greater risk.
10. How We Store & Protect Special Category Data
Locked filing systems for enrolment forms
Password-protected digital systems
Restricted access on DojoExpert
No unnecessary copies stored locally
CCTV-monitored, alarmed premises
Confidentiality requirements for any third-party IT access
DojoExpert cloud back-ups (encrypted and continually maintained)
Only essential staff can see sensitive information.
11. Retention Periods (Special Category Data)
Accident/injury reports: kept until the student reaches age 21
Safeguarding concerns: kept for a minimum of 6 years, longer if required
Medical information: kept only while relevant to safe participation
After these periods, information is securely deleted or destroyed.
12. Rights Related to Special Category Data
Parents and students may:
Request access to their data
Ask for inaccuracies to be corrected
Request deletion (unless safeguarding law prevents this)
Ask for limited use of certain information
Withdraw consent where consent was the lawful basis
We will always respect parental preferences except where safeguarding law overrides them.
13. Contact for Safeguarding or Data Protection
If you have any concerns about safeguarding or data protection:
Paul Summers
Seven Star Martial Arts & Fitness
Email: [email protected]
End of Safeguarding & Special Category Data Notice