Hayley’s Swimming School respect your right to privacy and comply with obligations under the Data Protection Acts 1988 & 2002 and the EU General Data Protection Regulation 2018 (GDPR).
2. Who we are
We are a small swimming school for children aged 3 upwards, based on the Wirral, where we’ve built reputations for really caring about how children progress in swimming. Our small class sizes of 3-4 children and in water teaching, means we can give every child the attention they deserve to become a confident swimmer.
Our swim school started in 2014, and we now have three main venues in the West Kirby and Woodchurch vicinity. This means we can provide swimming lessons in smaller pools, with room for your child to progress, to swimming 25 metre lengths at Calday Grange pool.
Our swimming lessons are adapted to each child to ensure progress to the best of their ability, while having fun. We believe that every child matters.
Andre Roberts of Hayley’s Swimming School is the Data Controller for all the personal data that you submit.
Contact Name: Andre Roberts
Company Name: Hayley’s Swimming School
Address: 43 South Road, West Kirby, CH48 3HG
Phone: 07480 234807
3. Types of Information Collected
We collect the following types of information:
This is data that identifies you or can be used to identify or contact you, which may include parent/guardian name, child’s name, child’s d.o.b, child’s gender, relevant medical conditions, email address and telephone no. Such information is only collected from you if you voluntarily submit it to us.
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business.
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you. Such as user IP addresses where they have been clipped or anonymised, browser and operating system types and other anonymous statistical data involving the use of our website.
This website collects data on children under the age of 13.
When you book a place with us and attend a swimming lesson or training course we need to collect your child’s personal information so that we can honour your booking and to enable your child to participate in the swimming lessons or outlined course.
If you do not provide us with all of the personal information that we need to collect then this may affect our ability to book your child’s place.
The data we collect may include the child’s name, child’s d.o.b, child’s gender and relevant medical conditions.
When you contact us, whether by telephone, through our website or by e-mail, you must hold parental responsibility if the child you are wanting to book swimming lessons for is under the age of 13. This enables us to gain parental consent to collect the child’s personal information.
4. Purposes for which we hold your Information
We will process any data you provide to us for the following purposes:
- to respond to your comments, queries and support requests.
- to provide you with details of your lesson day time and of any changes to this throughout your time with us.
- to carry out our obligations arising from any contracts entered into between you and us.
- to send you communications in relation to essential membership services, including but not limited to class changes, updates, latest news, up and coming events, renewals, changes in fees’.
- to keep you informed of any changes to the services we provide you.
- to check that use of our services is in accordance with our terms and conditions.
- for the purposes of security, and prevention and detection of fraud.
- We use the Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our website, products and services.
Our legal basis for holding your personal data under GDPR
- We are entitled to use your data as described in point (1) as we are responding to your request and therefore you have given consent to this processing.
- We are entitled to use your data as described in points (2), (3), (4), (5) and (6) as we require to do this as part of our contractual obligations to provide our services.
- We are entitled to use your data as described in points (7) and (8) as the purposes stated are within our legitimate interests.
5. Storage and Management of your Personal Data
The data that we collect in connection with our services is stored locally on our computer system. We also have a local server which securely backs up this data separate to our computer system. Hard copies of lesson registrations are also stored in locked and secure cupboards in our alarmed office.
Data collected through our website and emails is also stored on our secure web server, which is located in a UK Data Centre with 24/7 onsite security.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Cross-Border Data Transfers
When we share your personal information with our partners and service providers (see 7. Disclosure of Information to Third Parties), your personal information may be transferred to and/or made accessible from countries out of the European Economic Area. In such circumstances, we will enter into model contractual clauses as adopted by the European Commission, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules where our partners or service providers have adopted such internal policies approved by European data protection authorities.
Personal Data Retention Schedule
By law we have to keep basic information about customers and their contact details for a minimum of 6 years for tax purposes. We only store your information for as long as is necessary for the purpose it was obtained or for any additional purpose we have explained to you. We also implement policies to regularly audit the personal data we hold to ensure we do not retain any personal data for longer than we are entitled to.
In addition to the data we collect from you for lessons and sessions, we are required by law to collect data for NHS Test and Trace (coming into effect from 2nd July 2020). To support NHS Test and Trace, we must hold records for 21 days. This reflects the incubation period for COVID-19 (which can be up to 14 days) and an additional 7 days to allow time for testing and tracing. After 21 days, this information will be securely disposed of or deleted. When deleting or disposing of data, we will do so in a way that does not risk unintended access (for example shredding paper documents and ensuring permanent deletion of electronic files).
Records which are made and kept for other business purposes will not be disposed of after 21 days. The requirement to dispose of the data relates to a record that is created solely for the purpose of NHS Test and Trace. All collected data, however, must comply with the General Data Protection Regulation and will not be kept for longer than is necessary.
6. Security of your Personal Data
We place great importance on the security of all personally identifiable information associated with our customers. We use technical security measures to prevent the loss, misuse, alteration or unauthorized disclosure of information under our control. We use security measures including and not limited to: physical, electronic and managerial procedures to safeguard and secure the information we collect online. All sensitive information is collected through an encrypted connection on our secure server through Secure Sockets Layer (SSL) technology.
Our website utilises industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of potentially sensitive information such as your name, address and other critically sensitive information. Information passed between your computer and our website cannot be read in the event someone else intercepts it. This technology includes the following features:
- Authentication – this assures your browser that your data is being sent to the correct computer server, and that the server is secure.
- Encryption – this encodes the data, so that it cannot be read by anyone other than the secure server.
- Data Integrity – this checks the data being transferred to ensure it has not been altered.
When you access a website secured by an SSL certificate, you will see https:// at the beginning of its URL. Your web browser may also show the connection as secure by displaying a “lock” icon in the address bar.
Website, Email & Server Security
We ensure best to our ability that our systems and servers are protected from hackers, viruses, intruders and other online and offline problems by utilising the latest web security features, along with real-time file scanning for malicious files, a comprehensive firewall and advanced email filters to protect our systems.
7. Disclosure of Information to Third Parties
We share personal information in the following ways:
- Partners and Sponsors. Some of our services may be offered or promoted in conjunction with a partner or sponsor, or another brand. We may share your information with these parties to offer the product or service or to facilitate your use of additional amenities.
- Service Providers. We may transfer (or otherwise make available) your personal information to third parties that help us provide our services or provide services on our behalf. For example, we use service providers to authorise and process online payments, to raise and issue our invoices, to host our website and provide our email services. Our service providers are given the information they need to perform their designated functions, and we do not authorise them to use or disclose personal information for their own marketing or other purposes.
- Legal and Compliance Reasons. We may access, preserve and share your information with companies, organisations, governmental entities or individuals outside of our Company if we believe, in good faith, that the law requires us to do so. This may include, but is not limited to, responding to court orders or other legal processes (such as law enforcement requests). We may also access, preserve and share your information as necessary to: (i) establish or exercise our legal rights or defend against any legal claim; (ii) investigate, prevent, or take action regarding suspected fraud or other illegal activities; (iii) prevent death or serious physical harm to any person; or (iv) investigate violations of our Terms & Conditions.
Our legal basis for disclosing your personal data under GDPR
- We are entitled to disclose your data as described in points (1), (2) and (3), as the purposes stated are all within our legitimate interests.
- We are entitled to disclose your data as described in point (4), on the basis that we are legally required to do so.
This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Any cookies that may be used by this website are used either solely on a per session basis or to help improve and maintain the website. Cookies are not shared with any third parties. This website uses session cookies to count visits to each webpage and generate statistics. This information helps us improve and maintain our website. Also known as browser cookies or tracking cookies, cookies are small, often encrypted text files, located in browser directories. They are used by web developers to help users navigate their websites efficiently and perform certain functions.
9.What cookies are used on this Website?
The cookies we use on this website are broadly grouped into the following categories:
- Essential – Some of the cookies on our website are essential for us to be able to provide you with a service you have requested. An example of this would be a cookie used to enable you to log into your account on the website or which allows communication between your browser and the website. You may not be able to use our website without these cookies.
- Analytics – We use analytics cookies to helps us understand how users engage with our website. An example is counting the number of different people coming to our website or using a particular feature, rather than the total number of times the site or feature is used. Without this cookie, if you visited the website once each week for three weeks we would count you as three separate users. We would find it difficult to analyse how well our website was performing and improve it without these cookies.
10. Controlling and Opting Out of Cookies
Your browser or device may offer settings that allow you to choose whether browser cookies are set and to delete them. For more information about these controls and to exercise your cookie preferences, visit your browser or device’s help material. If you choose to reject cookies, as noted above, you may not be able to use certain features of our websites and services.
11. Links to external websites
13. Your Rights
You have the right to object to how we use your personal information. You also have the right to see what personal information we hold about you. In addition, you can ask us to correct inaccuracies, delete or restrict personal information or to ask for some of your personal information to be provided to someone else.
Right to Object
You can object to our processing of your personal information. Please contact our Data Controller, providing details of your objection.
Access to Your Personal Information
You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access by contacting us at ‘Hayley’s Swimming School, 43 South Road, West Kirby, CH48 3HG’. Please make all requests for access in writing and provide us with evidence of your identity.
Right to Withdraw Consent
If you have given us your consent to use personal information, you can withdraw your consent at any time and, update your marketing preferences by contacting our Data Controller.
You can ask us to change or complete any inaccurate or incomplete personal information held about you.
You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
Portability You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
Restriction You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
Personal Data Breach Notification
We ensure best to our ability that our systems and servers are protected from hackers, viruses, intruders and other online and offline problems, however if we experience a data breach of any kind, where a customer’s data has been compromised, a notification will be sent to all those affected within 72 hours of becoming aware of the breach.
Make a Complaint
You can make a complaint about how we have used your personal information to us, by visiting your local branch, by contacting our Data Controller. You also have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office at ico.org.uk We will not make any charge for responding to any request from you to exercise your privacy rights, and we will respond to your requests in accordance with our obligations under data protection law.
14. Document version control
|Version||Changes made||Date of changes|
|1.1||Updated Personal Data Retention Schedule to include schedule for NHS Test and Trace data – Page 6.||24/10/2020|
|1.1||Updated contact details for Hayley’s Swimming School and data controller||07/06/2022|