Holbrook Swim Privacy Policy

We are committed to respecting your privacy and take data protection very seriously. This notice is to explain how we may use personal information we collect before, during and after your swimming lessons with us. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.

Holbrook Swim is a non-profit making Swim School and registered with the Charities Commission as a Charitable Incorporated Organisation, charity number 1167034. We are also a member of Swim England (formerly Amateur Swimming Association)

Our lawful basis for processing data is legitimate interest.

1. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
We may obtain personal information about you or your child, such as information regarding your:
- personal contact details that allows us to contact you directly such as name, email addresses, postal addresses and telephone numbers;
- Child’s age;
- records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
- any credit/debit card and other payment details you provide and details of the financial transactions with you;
- records and assessment of swim awards

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:

- information about your child’s health, including any medical condition information provided by yourselves on the application form about your child if it is relevant to the safe conduct and health of the child during the swim lesson.

In relation to the special category personal data that we process we do so on the basis that it is based on your explicit consent.

3. WHERE WE COLLECT YOUR INFORMATION
We typically collect personal information about our members when you apply for swimming lessons, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.

If you are providing us with details of family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

4. DISCLOSURE OF YOUR/YOUR CHILD’S PERSONAL INFORMATION
We will NEVER share you or your child’s information to third parties.

The only exception being to medical bodies in case of emergency.

We share some personal information to our swim instructors so that they can carry out their job. Each instructor will only have the relevant pupil information for their own classes for that particular term, and records for previous terms will be deleted/destroyed.

5. RETENTION OF RECORDS
We need to retain records in order to properly administer and manage your membership and run our club and in some cases, we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.

All electronic and physical records are held centrally and securely, password protected or locked away. The only exception being in 4 above, where relevant information is passed termly to instructors so they can fulfil their role as Holbrook Swim instructor.

6. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?
The duration for which we retain personal information will differ depending on the type of information and the reason why we collected it from you. Generally, where there is no legal requirement we retain all physical and electronic records for a period of no longer than 3 years after your last contact with us or the end of your final term of swim lessons.

Exceptions to this rule are:

- Details regarding unsuccessful swim applications where we hold records for a period of not more than 12 months;
- Payment receipt records which are deleted/destroyed after the end of each financial year.
- Information that may be relevant to personal injury may be retained until the limitation period for those types of claims has expired. For personal injury this can be an extended period as the limitation period might not start to run until a long time after the event.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address. You will be able to update the personal information we hold about you via our booking form each term. Alternatively, you can contact us by using the details set out in the "Contacting us" section below.

7. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal information:

- the right to be informed about how your personal information is being used;
- the right to access the personal information we hold about you;
- the right to request the correction of inaccurate personal information we hold about you;
- the right to request the erasure of your personal information in certain limited circumstances;
- the right to restrict processing of your personal information where certain requirements are met;
- the right to object to the processing of your personal information.

8. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will do our utmost to inform you.

9. CONTACTING US
We need to retain records in order to properly administer and manage your membership and run our club and in some cases, we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.

In the event of any query or complaint in connection with the information we hold about you, please email: or write to us at: C/o Wain Cottage, Orvis Lane, East Bergholt, CO7 6TT.