What member data a gym can keep

The question that tidies everything

For every field you ask for, there is one question: what would I no longer be able to do without this? If the answer is nothing, the field goes.

It is a dull question, and it solves almost everything. The full address is for invoicing, and booking a class does not need it. The date of birth is for age groups and for knowing whether someone is a minor. Birthday wishes only go to people who choose to show their birthday.

The four groups, and what changes between them

Health data is a special category under the GDPR, with its own conditions for processing it. In practice, in a gym, that means three things. Ask only for what the class's safety needs. Keep it somewhere with restricted access. And never keep it in a file everyone can open.

Photos and videos

This is where it is easiest to mix two uses. A photo of a full class is the best thing a gym has to show. The practical rule is to keep apart two uses that are not the same:

• A profile photo, so the coach knows who is who on a list, is normal use of the service.
• A photo posted on social media is something else, and needs its own consent, given for that purpose and possible to withdraw.
• A consent given three years ago on a sign-up form is not the same as asking before you post.

For how long

Keeping everything forever is the decision that gets made by default. There are three different time limits in the same gym:

• What tax law requires you to keep stays for as long as the law says, and that is not your choice.
• Usage history makes sense while the person trains, and for a while afterwards, in case they come back.
• The health declarations of people who left years ago serve no purpose. They are the worst file you can keep for no reason.

A file nobody opens is still a risk. It is just one nobody remembers.

What people can ask you for

They can ask to see what you hold about them. To correct what is wrong, and to delete what you no longer need. The practical part is being able to answer without going to five places.

It is also the practical reason not to keep the same information in three places: when someone asks you to delete it, you need to know where all of it is.

What to do this week

One hour with the file open, and always the same question.

1. 1.List the fields you ask for at sign-up. For each one, ask what you could no longer do without it. The ones with no answer come off the form.
2. 2.Check where the health declarations are and who can get to them. If the answer is «the whole team», that is the first thing to change.
3. 3.Choose a time limit for what you keep about people who have left, and write it down. Without a written limit, the default decision is to keep everything forever.