All data subjects whose personal data is collected, in line with the requirements of the GDPR.
The Data Protection Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to in at ‘The Swim Specialist’ collecting/processing their personal data.
All Employees of ‘The Swim Specialist’ who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
Who are we - The Swim Specialist provides swimming lessons for all ages and abilities across the Yorkshire of England as well as accredited and none-accredited courses from a variety of Awarding Organisations.
Our Data Protection Officer (DPO) can be contacted via email@example.com or at the above address.
The personal information we would like to collect from you is:
Swim Academy Lessons—Initial Booking
- Parent / guardian (or your own if aged 18+) contact details comprising of name, address, postcode, telephone numbers(s) and email address
- Swimmers name
- Swimmers DOB
- Swimmers medical conditions
- Consent to photography
As well as the above information we enrol all customers using Direct Debit via a third party company (GoCardless) will process your bank account details on our behalf. The Swim Specialist will not have any access to this information.
In order to process any additional payments we may also take your credit or debit card details, however, this will not be stored or processed by 'The Swim Specialist' and will instead be processed via WorldPay.
Depending upon the course information will be requested about your personal contact details (name, address, email and phone number) as well as proof of identity and any accredited prior learning. For example to complete
Swimming teachers course there is a pre-requisite that a Safeguarding and Lifeguarding course will have been completed before the qualification can be awarded.
- Employees need to provide basic contact information (name, address, telephone number and email address) as well as proof of qualifications.
- We also require some personal information to enable us to process a Disclosure and Barring check via our third party supplier Disclosure Scotland UK. This information will include personal information such as driving license, passport and recent bills. None of this information is stored by The Swim Specialist
The personal information collected is to allow us to run the business. No information is collected unless it is needed for a specific task. For example swim school booking information is required to allow teachers to know who should be in their class while medical information allows us to keep all swimmers as safe as possible.
The Swim Specialist uses the following third party suppliers to process its data:
- Cap2 Solutions – for managing our online systems
- GoCardless—for all online direct debit payments
- WorldPay—for all online card payments
- HR Dept.—for managing our employee HR issues
- Dennis & Turnball Accountancy—for managing our accounts
- MyGov.Scot—who process all of our DBS checks
- Natwest—who provide the company banking facilities
- Firetext—who provide text messaging services linked to our online
The only special category of personal data held by The Swim Specialist relates to medical conditions. This is very brief summaries of any conditions with which we may need to provide emergency medical aid for, or, which may alter how we need to
deliver our lessons or courses.
Basic information is required to process invoices and provide our services. This information is for the administration of lessons and does not usually involve swimmers. The administration here covers the processing of paying for the services which in require to function. For example, pay pool hire, teachers wages, insurances, HR and accountancy support, etc.
Consent - By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for ‘The Swim Specialist’ to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw your consent at any time, however please note that without consent to process your data we will be unable to continue your custom.
Disclosure - The Swim Specialist will not pass on your personal data to third parties without first obtaining your consent.
The following third country organisations may store your personal details to enable The Swim Specialist to successfully manage its business. However, as per the list above these organisations are not involved in processing your data in anyway:
- GoogleDrive— Cloud data Storage
- Dropbox—cloud data storage
All of the above organisations have EU:US Safe Privacy Shield compliance.
Retention Period - The Swim Specialist will process personal data and retain any inactive members for a period of 4yrs.
Your rights as a data subject - At any point while we are in possession of or processing your data you, the data subject have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that organisation Name refuses your request under rights of access, we will provide you with a reason as to why.
You have the right to complain as outlined in below.
All of the above requests will be forwarded on should there be a third party involved as stated above in the processing of your personal data.
Complaints - In the event that you wish to make a complaint about how your personal data is being processed by in at the deep end or third parties as above, or how your complaint has been handled, you have the right to lodge a complaint
directly with the supervisory authority and The Swim Specialist’s Data Protection Officer (DPO).
The DPO can be contacted via the above contact details or on firstname.lastname@example.org
The Supervisory Authority can be contacted, depending upon which organisation is processing your data, by referring to the ‘Our Awarding Bodies’ document from the policies section of our website.
Monitoring and Review
We will monitor all of the feedback that we receive in relation to the issues affected by the Policy and will amend the policy as necessary.
The Policy will be updated with any amendments to existing legislation or new legislation.
In any event, all policies are reviewed annually although updates to versions etc. will only take place every three years should there be no other changes to the policy.
Document Owner and Approval
The Data Protection Officer (DPO) is the owner of this document and is responsible for ensuring that this policy document is reviewed in line with the review requirements stated above.
A current version of this document is available to all members of staff on GoogleDrive.
This policy was approved by the Company Directors on 18th May 2018 and is issued on a version controlled basis under the signature of Managing Director.
Date: May 2018
Author/Contributor: Nathaniel Birkett
Amendment Details: Implementation
Review Date: May 2021