Aquababies East London
Purpose of privacy notice
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.
One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information.
This means that we will be publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.
This new privacy notice comes into effect and will be published on our website on 25 May 2018.
Who are we?
Aquababies East London is the data controller. This means we decide how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to?
This privacy notice applies to information we collect from:
· Current swimmers
· prospective swimmers
· former swimmers
· visitors to our website;
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data we may hold about you include your patient notes.
How do we process your personal data?
We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.
1. We use your name, your child’s name, child’s date of birth, telephone number and email address to register your place on courses. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit.
2. We keep a permanent attendance register which records all swim lessons taken place. A paper version is used on the poolside to record attendance.
3. We may use your child's date of birth to help identify children with the same name.
4. We keep accident records for any incidents
5. When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
6. We will only use the personal information we collect to process the complaint and to check the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints for our insurance company. Similarly, where enquires are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues to check on the level of service we provide.
7. When someone visits our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
8. We use website cookies to improve user experience of our website by enabling our website to 'remember' users, either for the duration of their visit - using a 'session cookie' - or for repeat visits - using a 'persistent cookie'.
9. We use a third party service (1&1) to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to our website.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will not be shared.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary.
We keep records for a period of 7 years
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
· The right to request a copy of your personal data which we hold about you.
· The right to request that we correct any personal data if it is found to be inaccurate or out of date.
· The right to request your personal data is erased where it is no longer necessary for us to retain such data.
· The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
· The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability),
·The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
·The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
·The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
·The right to lodge a complaint with the Information Commissioner’s Office.
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries of complaints please in the first instance contact us at firstname.lastname@example.org