DATA PRIVACY POLICY (SEPTEMBER 2023)
Background
Every member of Water Wizards Swim School is required to complete forms which including a Personal Information form that asks for personal data including medical information relevant to swimming. The details you provide are used solely for the purposes of your swim school membership and will never be used for commercial or marketing purposes. Your details are securely held by us in both hard copy and electronic form so that places a responsibility upon us in relation to the General Data Protection Regulation (the “GDPR”).
Data Privacy Policy
This Data Privacy Policy describes the way in which Water Wizards Swim School Ltd deals with the information and data you provide in order for us to manage your membership. We will process any personal data provided to us or otherwise held by us relating to you in the manner set out in this Privacy Policy. Information may be provided via the forms you fill in when joining, our website (swimwithwaterwizards.co.uk or waterwizardsswimschool.com), telephone calls, emails, SMS, contact forms or any other means.
Who are we?
References in this Privacy Policy to “we”, “us” or “our” relate to Water Wizards Swim School Ltd. We control the ways your Personal Data is collected and the purposes for which your Personal Data is used by us, acting as the “data controller” for the purposes of applicable European data protection legislation.
Your personal data, what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
How do we process your personal data?
Water Wizards Swim School complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
Information we may collect from you
Information is collected by Water Wizards Swim School for and on behalf of Water Wizards Swim School. The information and data about you which we may collect, use and process includes the following:
• The information you provide to us by filling in forms, contacting us on our website or any other information you submit to us via email, text message, voicemail or telephone.
• Records of correspondence, whether via the website, email, telephone or other means.
• Your responses to surveys or research that we may carry out.
• Details of the transactions you carry out with us, whether via the website, telephone or other means.
• Details of your visits to our website including, but not limited to, traffic data, location data, weblogs, cookies and other communication data.
We only ask for the absolute minimum personal data required for the swim school to carry out its membership activities. This may include member names, dates of birth, postal addresses, email addresses, telephone numbers and any medical conditions (related to swimming only). This information is needed to carry out our membership activities efficiently and safely. The swim school’s legal basis for collecting this personal data is for our “Legitimate Interest”.
Special category data – swimmers’ medical details (appropriate to swimming).
The safety of our swimmers is of paramount importance to us. Given the nature of swimming, it is essential that Water Wizards teachers are aware of any health issues that could impact a member’s safety, particularly when poolside. We therefore require each member to provide us with detail relating to any health issues that in your judgement you feel the swim school should be made aware of. Any such medical information you provide to us is held by us in both hard copy and electronic form and is used solely for the safety of your swimmer, and will only be shared with authorised personnel of Water Wizards Swim School and will not be shared with any other third party without seeking your permission first, unless duty bound to do so, by law.
This type of personal date is classed as “Special category data” and we require your consent to hold and process such special category data. If you choose to provide us with any medical conditions related to swimming we will require your consent via email or your signature on the membership form as our means of discharging our responsibility.
What do we use your personal information for?
Respond to your enquiry.
To administer membership records.
Inform you of enrolment and re-enrolment procedures.
Fulfil any contract that we may enter with you.
To notify you about changes to our swim school, its membership or the services it provides and the events that it promotes.
For Health and Safety and to contact you in an emergency.
Where any relevant medical conditions, physical or mental impairments are disclosed to ensure, in consultation with you, that these factors are taken in to consideration in relation to swimming lessons and other activities within the swim school. All such data shall be treated as sensitive data.
For other reasonable purposes such as notification of pool closure etc.
The GDPR requires each organisation that holds personal data on individuals to define the legal basis on which they hold and use this data. Water Wizards Swim School primarily holds data for the purposes detailed in these documents, the legal basis as allowed by the GDPR is “Legitimate Interest”.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you (i.e. your membership with the swim school) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with normal services offered to swim school members). In this case, we may have to cancel your membership, but we will notify you if this is the case at the time.
Sharing your personal data
We will only share your data with third parties outside of Water Wizards Swim School with your consent unless duty bound to do so, by law. The information will be disclosed only to those members of Water Wizards Swim School for whom it is appropriate and any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights.
We use the following companies to help us administer our membership records and/or manage our business. They may process your personal data as part of their relationship with us:
Google
Twitter
Facebook
Tsohost
WhatsApp
Office365 (Microsoft)
WordPress
How long do we keep your personal data?
We will keep your data for the period that you are a member of Water Wizards Swim School. Whenever your data is kept by us we will ensure that it is appropriately protected and only used for acceptable purposes. If you are no longer a member of Water Wizards Swim School, we will keep your data for the minimum length of time required to comply with the purposes set out in this Policy and any relevant legal or regulatory obligations.
Changes to our Privacy Policy and your duty to inform us of changes
Any changes we may make to our Privacy Policy in the future will be posted on the website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your membership with us.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
The right to request a copy of your personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary for us to retain such data;
The right to withdraw your consent to the processing at any time;
The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability).
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable).
The right to lodge a complaint with the Information Commissioners Office.
Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact:
Director: Zoe Anstiss
Email: zoe@swimwithwaterwizards.com
Mobile: 07858 306584
Web: www.swimwithwaterwizards.co.uk
Water Wizards Swim School Ltd
c/o Northampton School for Girls
Spinney Hill Road
Northampton
NN3 6DG
Next review date: MAY 2024
