Privacy Policy

Southern Cygnet Swim School Data Protection

About Us
Southern Cygnet Swim School has been run by Andrew Whiting since April 2019.
Prior to this it was called Cygnet Swim School, run and owned by someone else. All the data captured by the previous owner has been securely destroyed.

About the Information Commissioners’ Office (ICO)
By law, any organisation acting as a data controller who is processing personal information must be registered with the ICO, unless they are exempt.
Southern Cygnet Swim School is registered as a data controller with the Information Commissioner’s Office under registration number A8331007.

Your Information and Consent
Consent is gained via the enrolment and consent paper form that all of our swimmers or their parents (if swimmers are under the age of 18) are asked to complete. This gives us consent to contact you for the reasons stated below as well as take photos and videos of the swimmers to help with promotion via social media channels including Facebook, Instagram and Youtube, our website and on printed leaflets.

We do give you the option to opt out of the photographs and videos but there is no opt out option for providing details that are pertinent to running safe swimming lessons and sessions.

If you have agreed that we can use your data (images and videos) for marketing purposes, you can change your mind by contacting the Director via one of these methods:

Send an email to southerncygnetswimschool@gmail.com or

Write to us at:

Southern Cygnet Swim School

50 Muscliffe Road
Winton
Bournemouth
Dorset
BH9 1NW

We will never lease, distribute or sell your personal data to third parties unless we have your permission, or the law requires us to so.

The information you provide on the enrolment and consent form is treated with confidence.

The paper forms are kept in a filing cabinet in the swim school home office. The cabinet is locked and the only key to unlock it is held by the Director or Southern Cygnet Swim School.

Information on the form is also transferred onto an electronic document kept on a home computer and the database is backed up to the Cloud to allow for access at sessions in case of an emergency situation or cancellation of sessions.

Your address, phone number and email address, children’s information (such as date of birth, health conditions, previous swimming experience and swimming awards) will only be viewable by swimming teachers when necessary and no third parties.

Your address, phone number, email address and swimmers name are added to pre-populated re-enrolment forms (handed out at the end of each term) which are processed through the one office computer and again not saved or backed up to the Cloud or online servers – these templates are securely deleted once they have been printed out.

Your email address is saved in the Southern Cygnet Swim School’s email account address book (Gmail) which allows swift contact to be made when there is a need to contact you – regarding your swimmer, cancellation of sessions, re-enrolments etc.

Your email address is also added to our swim school newsletter account which is via Mailchimp.
A newsletter is sent our once per term (and ad hoc if there is an update in our programme).
We ensure there is an unsubscribe option on every newsletter we send out. If a subscriber decides to unsubscribe your email is removed from the swim school’s Mailchimp account.

Your phone number (usually mobile) is stored on a mobile phone used by the Director of Southern Cygnet Swim School. This account is currently on the EE network and is password secured. This allows for swift contact to be made when there is a need to contact you – regarding your swimmer, cancellation of sessions, re-enrolments etc.

Swimmer Information
Swimmer’s full names are added to paper registers along with a symbol indicating a medical condition if appropriate. This confirms the swimmers in each class to ensure we comply with maximum numbers is our lessons and sessions. The symbol ensures the teacher is aware of any adaptations they may need to make to their lessons with regards to medical conditions and learning difficulties.
In addition prior badges achieved are confirmed on the registers so that termly assessment and progression can be accurate and continuous.
The registers are destroyed after the end of each term.

Once a swimmer has left the swim school all details are removed from the swim school mobile phone, home computer database and email address book.

However we do keep the paper copy of the enrolment and consent form as there are many occasions where people return to us in the future by re – starting lessons and if queries are raised by swimmers or their parents after they have stopped swimming with us.

Types of Data Processed
The types of data Southern Cygnet Swim School collects, stores and processes are detailed below.

Swimmer and Parent or Guardian Information

Data Type Data Collected Legal Basis Retention Period Where Information is kept
Swimmer Enrolment and Consent Form
  • Name
  • Date of birth and age at that time
  • Address
  • Telephone Numbers
  • Email Address
  • Medical Information
  • Parent or Guardian Name
  • Emergency Contact details for adults
Contract for service provision 7 years after swimmer has stopped swimming with the swim school Filing cabinet in swim school office
Booking and Re-enrolment Forms
  • Name
  • Date of birth and age at the time
  • Address
  • Telephone Numbers
  • Email address
  • Medical Information
Contract for service provision 1 year after booking and re-enrolment form completed Filing cabinet in swim school office
Electronic Pupil Database
  • Name
  • Date of birth and age at the time
  • Address
  • Telephone Numbers
  • Email address
  • Medical Information
  • Parent or Guardian Name
  • Emergency contact details for adults
Legitimate Interest Updated each term and swimmers that are no longer part of the swim school are securely removed and deleted from computer Laptop kept in swim school office

Employee Information

Data Type Data Collected Legal Basis Retention Period Where Information is kept
Employee Records
  • First and Surname
  • Date of Birth
  • Address
  • Contact phone numbers
  • Email Address
  • Parents First and Last names
  • Emergency Contact Details
  • Medical Conditions
  • Bank Account Details
  • Copy of Passport for proof of right to work in the UK
  • Statement of Terms and Conditions
  • Sickness and Absence Records
  • Annual Leave Records
  • Training Agreement Records
  • Copy of Qualifications
Contract of Employment As long as employee works for Southern Cygnet Swim School and 7years thereafter. File in swim school office and where applicable on the laptop kept in the swim school office.
DBS checks completed by Online Disclosures
  • First name Surname
  • Date of birth, Postcode
  • On application ID document numbers are typed in to confirm identity
Contract of Employment Record kept online indicating when last check was completed Online third party company

Storage

Name Purpose Location Security
Internal database systems Southern Cygnet Swim School computer files for electronic customer and employee records Swim School office Password protected to GDPR required standards

Security
Southern Cygnet Swim School takes your data security very seriously. Where online records are kept – these are password protected to comply with GDPR requirements.

Paper copies are kept in a locked filing cabinet only accessible by one key that is securely kept by the Director of the swim school.

Sub-Contract Processing
Southern Cygnet Swim School uses the following organisations, who process your personal data, in order to provide its products and services to you. All organisations which the swim school works with comply to the relevant legislation, including the General Data Protection Regulations (GDPR), and are monitored and audited frequently.
We will not pass your details on to marketing companies.
Google
For email communication via Gmail
For statistical analysis of your interactions with Southern Cygnet Swim School website via Google Analytics (www.dorsetswimschool.co.uk).
MailChimp
Operate, host and provide the functionality enabling Southern Cygnet Swim School to send marketing email communications to customers.
SurveyMonkey
Operate, host and provide the functionality enabling Southern Cygnet Swim School to send marketing email communications to customers usually to perform an audit on the current swim programme and what session work or questions or what customers would like to be include.
RWB Tax Consultants
For employee payroll and communication regarding this to HMRC
Online Disclosures
For processing of enhanced Disclosure and Barring Service checks for all employees over the age of 16.
• After 6 months, the following application data remains on their system including First name, Surname, Date of birth, Postcode, Certificate No, Certificate Date, Organisation ID, Organisation name, Certificate type requested (i.e product and barring list/workforce)
• 1 month, after 3 years, all completed applications will have their data deleted.

Your Rights
The Right to Be Informed
You have the right to be informed about the collection and use of your personal data. This information is communicated via this privacy policy and via the terms and conditions that are given to you when you complete the enrolment process for either yourself or your children.
You will be notified whenever any changes are made to these.

The Right of Access
You have the right to access your personal data and supplementary information. For access to this information please contact The Director of Southern Cygnet Swim School via email:
southerncygnetswimschool@gmail.com or a written letter sent to: 50 Muscliffe Road, Winton, Bournemouth, BH9 1NW.

The Right to Rectification
You have the right to have inaccurate personal data rectified or completed if it is incomplete. As detailed above, Southern Cygnet Swim School provides this facility via the re-enrolment forms which we require you to check and amend as necessary each term. You are also able to do so verbally or in writing at any other time.

The Right to Erasure
The GDPR introduces a right for you to have your personal data erased if, for instance, the personal data we hold for you is no longer necessary for the purpose for which it was originally collected or processed. The right to erasure is also known as ‘the right to be forgotten’. The right is not absolute and only applies in certain circumstances where applicable.

The Right to Restrict Processing
You have the right to request the restriction or suppression of your personal data in order to limit the way that we use your data; this is an alternative to requesting the erasure of your data. This is not an absolute right and only applies in certain circumstances. You can make a request for restriction verbally or in writing.

The Right to Data Portability
The right to data portability gives you the right to receive your personal data you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transmit this data directly to another data controller. This right only applies to data collected by us using automated means (i.e. excluding paper files).

The Right to Object
You have the right to object to your information being processing based on:
Legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
Direct marketing (including profiling)
Processing for purposes of scientific/historical research and statistics.
Rights in Relation to Automated Decision-Making and Profiling
Southern Cygnet Swim School does not undergo automated decision-making on your personal data.

External Links
Our websites and online services may contain links to other websites.
Please note that we have no control of websites outside the following Southern Cygnet Swim School domain:
www.dorsetswimschool.co.uk

If you provide data to a website to which we link, we are not responsible for its protection and privacy.
Always be wary when submitting data to websites—read the site’s data protection and privacy statement fully.

Cookies
Cookies are small text files that are sent to and stored on your computer, smartphone or other devices for accessing the internet, whenever you visit a website. Cookies are useful because they allow a website to recognise a user’s device.
More information about cookies can be found on www.allaboutcookies.org.

We use analytics cookies to help us make our website better for those who visit it regularly. They help us work out the number of visitors to the site, where visitors have come from, the pages visited, what users like, don’t like and how we can improve things for you. These collect information anonymously.

You can set your browser to accept or reject all specific cookies. You can also set your browser to alert you each time a cookie is presented to your computer.
If you would like to restrict or block cookies that are set by websites, you can do this through your web browser settings. Please refer to your browser’s help section for further information.

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