Privacy Policy

1. PURPOSE
The Privacy Policy exists to ensure all swimmers and all members of Penguins Swimming Lessons are aware of how their personal data is administered, held and protected in accordance with the new General Data Protection Regulations (GDPR) 2018. The policy outlines how we use any personal information you provide us with, either in writing via email, verbally or using any other communication method. It includes data gathered via cookies and hyperlinks from the Penguins Swimming Lessons website and also covers our marketing and third party policies.

2. POLICY CONTENT
The Penguins Swimming School Privacy Policy covers the following:
• What personal information we may collect about you
• How we use this personal information
• Third-party disclosure and marketing data
• How we will use your relevant contact details
• When we will contact you
• How long we keep details on file
• How members can review and request changes to held information
• Cookie data and hyperlinks
• How we notify members of material changes to our Privacy Policy

3. PERSONAL INFORMATION
In running and operating Penguins Swimming Lessons, we may collect and process certain data and personal information. We only collect information applicable to delivering the services you require and to ensure they are delivered in an effective and efficient manner.

3.1 Data source
The data that we collect from you is in the form of information you provide on an
enrolment form, communication via email or another communication method.

3.2 Data content
This personal information typically includes:
• Swimmer’s name
• Parent/guardian’s name on behalf of a swimmer under 18
• Postal address
• Email address
• Alternative contact details in case of emergency
• Swimmer’s age
• Swimmer’s date of birth
• Medical details and conditions that are relevant to the provision of safe and effective swimming sessions
3.3 Financial information
Penguins Swimming Lessons uses an external provider called Xero to receive payments made by online banking. Xero is a fully GDPR-compliant data processer. No card information or identifying information is retained by either Penguins Swimming Lessons or Xero.

4. USE OF CONTACT DETAILS
Penguins Swimming Lessons will only contact you directly, with your permission, about urgent announcements, upcoming events or queries relating specifically to your child and their needs.

4.1 Email contact
We send regular emails with information about courses, fees, term dates and other events to current swimmers and members. We only send you information that is essential to your involvement with Penguins Swimming Lessons.

4.2 Newsletter
We send out a monthly newsletter using Mailchimp to all email addresses on our mailing list. This newsletter contains relevant information on courses and events, staff news, swimmer achievements and Penguins updates. Our Mailchimp sign-up form is GDPR-compliant. The button to Unsubscribe is clearly signposted for recipients at all times.

4.3 Social media
We regularly post updates, news and announcements on our Facebook page. We never
share personal information or name individuals via social media channels as we have no
control over who likes or shares our page.

5. DATA RETENTION
Penguins Swimming Lessons will retain the relevant details of current swimmers on its secure systems in order to communicate with them about their courses.

5.1 Leaving Penguins
When a swimmer chooses to end their involvement with Penguins Swimming Lessons,
their data is removed from the database.

5.2 Accident and incident reports
The only acceptation to this rule is accident and incident reports, which will be held on file
for no less than ten years after occurrence and will then remain in archive storage.

6. THIRD PARTY DISCLOSURE
Personal data requested and held by Penguins Swimming Lessons is never shared with third parties for marketing or gain. Swimmer information may be shared securely with external data processors such as invoice platform Xero. We may also share any safety and wellbeing information about swimmers with guest teachers or activity leaders where appropriate. Penguins Swimming Lessons will always remain the controller of any such information.

7. DATA REVIEW AND AMENDMENTS
Should members need to view or amend any details held by Penguins Swimming Lessons, they should contact the office via email info@penguinswimminglessons.co.uk in the first instance. Individual requests and revisions will be administered on an individual basis.

8. WEBSITE DATA
This section refers to data gathered when users visit the Penguins Swimming Lessons website: www.penguinswimlessons.co.uk

8.1 Cookies
A cookie is a small piece of data stored on your hard drive that usually includes an  exclusive identifier sent to your browser from a website server. Each individual website can send its own cookie to your device if your browser’s preferences allow for this. Many sites do this whenever a user visits to monitor online traffic to and from their site. Our cookies record information about how you interact with the Penguins website that allows us to modify the website to your needs. Users can set their devices to accept all cookies, to notify them when a cookie is issued or to not receive cookies at all. If you choose not to receive cookies, it is possible specific services cannot be offered which means you may not be able to view the Penguins website as intended.

8.2 Hyperlinks
A hyperlink forwards you to other content in your web browser, usually to another specific page. These are used to make navigating our website simpler and easier. You will know that something is a hyperlink when your mouse pointer changes to a pointing finger when hovered above the link. Most of the time, hyperlinks appear as images or as underlined words. We will not use hyperlinks on the Penguins site to direct users to external sites for marketing or other gain.

9. CONTEXT
This policy complies with General Data Protection Regulations 2018 and is upheld by internal standards, training and procedures. We regular review and amend this policy and the webpage should be consulted for the most up to date version available. This policy is reviewed after any breach of the policy rules and guidelines.