Seahorses Swim School Privacy Policy

1. Introduction

   1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. OR By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications in form of a Newsletter if and when this is sent by Seahorses Swim School and limit the publication of your information. You can access the privacy controls via the website, ebcsltd.co.uk, then entering your email address into the Newsletter Signup Box. Instructions will then be displayed allowing you to Unsubscribe and also to update your profile.

1.5 In this policy, “we”, “us” and “our” refer to Seahorses Swim School. For more information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent using the ‘ACCEPT’ button displayed when first visiting the website OR our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent using the ‘ACCEPT’ button displayed when first visiting the website OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details.The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent using the ‘ACCEPT’ button displayed when first visiting the website OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

3.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include all data supplied by you for the purpose of allowing Seahorses Swim School to provide the service you requested such as providing Building Control Certification. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent using the ‘ACCEPT’ button displayed when first visiting the website OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent using the ‘ACCEPT’ button displayed when first visiting the website OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent using the ‘ACCEPT’ button displayed when first visiting the website.

3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent using the ‘ACCEPT’ button displayed when first visiting the website.

3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.11 We may process all data submitted via the website and sent via other means such as email and by post. This data may include that requested by the following forms:

• Training Course Booking Enquiry
• Contact Form

The legal basis for this processing is by using the ‘ACCEPT’ button displayed when first visiting the website OR our legitimate interests, namely, providing the service requested. This data may be processed for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 We may disclose personal data sent to our suppliers or subcontractors insofar as reasonably necessary.

4.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 We currently do not transfer data to any non-EEA countries.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) Website – Currently no data is stored on the website. However, the data submitted using the contact & training booking forms is kept for a short period in order to respond to the request. These include Name, Address, Phone Number, Email Address, Location.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy by email or by displaying a message on our website.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request your personal data by contacting Seahorses Swim School using one of the methods displayed on the contact page of the website: seahorsesswimming.co.uk/contact-us/

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) cookie consent – we use cookies to store the fact that the Cookie Consent notice has been shown on the website.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1 This website is owned and operated by Seahorses Swim School.

13.2 You can contact us:

(a) using our website contact form: seahorsesswimming.co.uk/contact-us

(b) by telephone, on the contact number published on our website or

(c) by email, using the email address published on our website.

14. Data protection officer

14.1 Our data protection officer’s contact details are: Sophie Hart

Data Protection and Confidentiality

All personal information provided to Seahorses is used solely for administrative purposes and will not be shared with any third parties. You may request access to the information we hold about you at any time. All medical information is treated as strictly confidential and is only shared with your child’s teachers or other relevant personnel when necessary for safety reasons.

All written correspondence, including emails, between Seahorses and yourself is confidential and should not be shared with others, even after your child leaves the school. If you wish to have your personal information removed from our records upon leaving, please contact us to request deletion.

Seahorses Swim School Code of Conduct Policy

 

1. Purpose

This Code of Conduct outlines the standards of behaviour expected from all swimmers, parents/guardians, staff, volunteers, and visitors attending or representing the swim school.

The aim is to:

• Ensure a safe, positive, and inclusive learning environment
• Promote respect and professionalism
• Protect the welfare of children and vulnerable individuals
• Maintain high standards of safety and behaviour

2. Scope

This policy applies to:

• All swimmers (children and adults)
• Parents and guardians
• Swim teachers and assistants
• Volunteers
• Contractors and visitors

3. General Conduct Expectations

All individuals must:

• Treat others with dignity and respect
• Follow pool rules and staff instructions at all times
• Act in a way that promotes safety
• Use appropriate language and behaviour
• Respect facilities, equipment, and property
• Promote an inclusive, non-discriminatory environment

Bullying, harassment, discrimination, aggressive behaviour, or abusive language will not be tolerated.

4. Swimmer Code of Conduct

Swimmers must:

• Arrive on time and prepared for lessons
• Not attend swimming lessons whilst unwell, including colds, or with any condition where it is not recommended to swim
• Listen carefully to instructions
• Follow pool safety rules
• Inform the teacher if feeling unwell

Swimmers must not:

• Enter the pool without permission
• Use equipment without instruction
• Disrupt lessons or distract others

5. Parent / Guardian Code of Conduct

Parents and guardians must:

• Supervise children outside lesson times, including on the premises, changing rooms, showers, and toilets, including if children leave the lesson for any reason
• Ensure children are supervised until they are invited back into the lesson by the swimming teacher, and not allow children to re-enter the pool in any way until they are invited to do so
• Ensure children use the toilet and shower before lessons
• Inform staff of medical conditions or changes to personal details, including phone number, email address and home address
• Follow all swim school rules and policies
• Speak respectfully to staff and other families

Parents must not:

• Interrupt lessons
• Coach from poolside
• Use abusive or threatening language
• Film or photograph anywhere on the premises without express permission
• Eat or drink anywhere on the premises, except water
• Smoke anywhere on the premises
• Have mobile phones or other devices visible anywhere on the premises except in an emergency

Concerns should be raised calmly through the appropriate management channels.

6. Staff & Instructor Code of Conduct

All staff must:

• Act professionally at all times
• Prioritise safeguarding and welfare
• Maintain appropriate boundaries
• Follow safeguarding and health & safety policies
• Hold required qualifications and training
• Wear appropriate uniform/identification
• Report incidents promptly

Staff must not:

• Engage in inappropriate physical contact
• Be alone with a child in an unsupervised setting
• Share personal contact details with swimmers
• Use mobile phones during lessons (unless authorised or in an emergency)

7. Safeguarding Commitment

The swim school is committed to safeguarding children and vulnerable adults. All concerns must be reported immediately to the Designated Safeguarding Lead. Any allegation of misconduct will be taken seriously and investigated appropriately.

8. Health & Safety Compliance

All users must comply with:

• Pool Normal Operating Procedures (NOP)
• Emergency Action Plan (EAP)
• Hygiene rules (including showering and using the toilet before swimming, and wearing a swimming hat if required by lesson type)
• Illness policies

9. Equality & Inclusion

The swim school promotes equality of opportunity and prohibits discrimination based on:

• Age
• Disability
• Gender
• Race
• Religion or belief
• Sexual orientation
• Pregnancy or maternity

Reasonable adjustments will be made where possible.

10. Social Media & Online Conduct

• Staff must not engage with swimmers via personal social media accounts
• Parents must not post images of other children without consent
• Negative or defamatory online comments may result in removal from the programme

11. Breach of Code

Failure to comply with this Code of Conduct may result in:

• Verbal warning
• Written warning
• Removal from lessons
• Termination of employment or contract (for staff)
• Immediate suspension in serious cases

The swim school reserves the right to refuse service where behaviour compromises safety or welfare.

Seahorses Swim School Smoking Policy

At Seahorses Swim School, the health and safety of our swimmer, staff, and visitors is our top priority. In line with this commitment, we maintain a strict no-smoking policy across all our premises.

Policy Details:

1. No Smoking – Smoking of any kind, including cigarettes, cigars, or other tobacco products, is strictly prohibited on the premises.
2. No Vaping or E-Cigarettes – The use of electronic cigarettes, vapes, or any similar devices is also strictly prohibited anywhere on the property.
3. Scope – This policy applies to all indoor and outdoor areas, including:
   • Swimming pools and poolside
   • Changing rooms, showers & toilets
   • Anywhere on the site premises including outdoors
4. Enforcement – Any person found violating this policy may be asked to leave the premises immediately. Repeat violations may result in further action, including removal from the swim school without refund.
5. Awareness – Signage indicating the smoke-free policy is displayed prominently throughout the premises to ensure everyone is aware.

We appreciate your cooperation in helping us maintain a safe, healthy, and family-friendly environment for all who visit Seahorses Swim School.

Seahorses Swim School Health & Safety Policy

 

Poolside Guidelines and Responsibilities

• Mobile Phones: Mobile phones are not permitted to be used anywhere on site, including in changing rooms, showers, toilets, or on the poolside. Mobile phones should be kept in bags at all times, and are only permitted to be used on site in a medical emergency. If you see someone using a phone at the pool, please let us know.
• Footwear: Everyone entering the pool complex must remove shoes and socks and place them on the shoe racks provided.
• Attire & Comfort: Poolside can become very warm. Please dress appropriately and bring water to stay hydrated.
• Siblings & Spectators: Siblings are welcome to watch lessons but remain the responsibility of their parents or guardians. They must be seated well away from the pool edge and under full supervision at all times. We strongly encourage only one parent/guardian per family on the poolside where possible, as space is limited. Seahorses cannot accept responsibility for spectators at any time.
• Supervision of Swimmers: Our responsibility begins when we invite swimmers into the water and continues only while they are participating in the lesson. Children leaving the pool for any reason (e.g., toilet breaks) are the responsibility of their parent/guardian. Please inform the teacher before taking your child out, and wait for the teacher’s instruction before rejoining the class.
• Poolside Conduct: When children are in the water, parents/guardians should avoid direct communication beyond simple encouragement, such as a thumbs-up or smile. This ensures children remain focused on their teacher and lesson for safety and learning purposes. If a child is consistently distracted, we may suggest that parents/guardians watch from the changing room.
• Support During Lessons: Any adjustments required during the lesson (e.g., loose goggles, hat adjustments) will be managed by our experienced teachers. New preschoolers and younger children may take a few weeks to settle in, and our staff are trained to support them during this transition.
• Prohibited Items: No food, drink (except water in a plastic bottle), glass, or talcum powder is allowed in the pool complex. All litter should be disposed of in the bins provided. Smoking is strictly prohibited anywhere on site.
• Parental/Guardian Presence & Contact: Parents/guardians must remain on site unless a prior arrangement has been made. We require a current mobile number at all times.
• Behaviour & Respect: We reserve the right to ask anyone to leave the poolside at any time. All interactions with staff must be polite and respectful. Discussions about children other than your own are not permitted, either on poolside or in private.

Safeguarding

We adhere to the Wavepower Safeguarding Policy, which can be found here.

Welfare Officer

Name:            Sophie Hart

Tel:                 0777 616 4792

Children’s Services

Tel:                 0300 123 1630

Swimline

Tel:                 0808 100 4001

Out Of Hours/Emergency Team
Tel:                  01252 792098

Local Safeguarding Children Board (LSCB)

Tel:                  01372 833330

Local Authority Designated Officer (LADO)

Tel:                  0300 200 1006

Police Child Protection Investigation Team
Tel:                  101, ext 39667

Multi Agency Safeguarding Hob (MASH)
Tel:                  01483 518505

National Governing Body (NGB)
The SE Legal Affairs Department
Pavilion 3, SportPark
3 Oakwood Drive
Loughborough University
Leicestershire LE11 3QF

Tel: 01509 640270
E-mail: legal@swimming.org
Website: www.swimming.org

SE Child Safeguarding Team
Keith Oddy:
Independent Child Protection Officer (ICPO)

Jenni Dearman:

National Child Safeguarding Coordinator (NCSC)
At the NGB address above.
Tel: 01509 640270
E-mail: jenni.dearman@swimming.org

SE Disclosure and Barring Service
Samantha Massey: DBS Coordinator
Tel: 01509 618738
E-mail: dbs@swimming.org

Child Power
Leaflets available from
jenni.dearman@swimming.org

Website and under 16s section: www.swimming.org/asa/clubs-and-members/under-16s-advice/

SE Office of Judicial Administration (OJA)
Tel: 0161 2731044
E-mail: kerry.moss@swimming.org

Swimline SE/NSPCC Child Protection Helpline
Tel: 0808 100 4001

Other Services

NSPCC Child Protection in Sport Unit (CPSU)
Tel: 0116 366 5590
E-mail: cpsu@nspcc.org.uk
Website: www.thecpsu.org.uk

NSPCC Helpline
Tel: 0808 800 5000
Website: www.nspcc.org.uk

ChildLine
Tel: 0800 1111
Website: www.childline.org.uk