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Privacy Policy

Swim UK Ltd (“we”, “us”, “our”) is committed to protecting and respecting your privacy, and to complying with the Data Protection Act 2018 and the UK GDPR (General Data Protection Regulation).

This policy explains what data we collect, how and why we use it, how we keep it secure, and what rights you have.

1. Who We Are

Swim UK Ltd is the data controller for all personal data you provide to us. We determine the purposes for which and the manner in which your data is processed. We are registered with the Information Commissioner’s Office (ICO).

We have appointed a Data Protection Officer (DPO) who oversees compliance with this policy.

2. What Data We Collect

The data we collect depends on your relationship with us, but may include:

General Information

  • Full name, date of birth, address, email, and telephone number

  • National Insurance number and passport or other ID

  • Records of prior attainment or qualifications

  • Employment or benefit status (if applicable)

Sensitive Data

In some cases, particularly for funded learners, we are required to collect Special Category Data:​

  • Health or additional needs (to provide support or make adjustments)

  • In some instances, information about criminal convictions or safeguarding disclosures

We only collect this data when necessary and will always inform you why it’s required.

3. Legal Basis for Processing

We only process your data when there is a lawful basis for doing so, such as:

  • Consent: You have given explicit permission (e.g. marketing or enrolment follow-up)

  • Contractual Obligation: Processing is required to deliver a course or service you’ve requested

  • Legal Obligation: We’re required to collect certain information by funding bodies or law

  • Legitimate Interest: We may process minimal data to improve services, evaluate outcomes, or ensure learner safety

4. How We Use Your Data

We use your personal information for the following:

  • Enrolling you on a course and maintaining academic records

  • Contacting you about course details, changes, or support​

  • Sending updates on courses or qualifications you may be eligible for (if you’ve consented)

You will never be automatically enrolled in marketing unless you opt in, and you can unsubscribe at any time.

5. How We Protect Your Data

Your data is stored securely on systems hosted in the European Union. Only trained Swim UK staff access your data, and all our data-handling practices follow strict data processing agreements in line with UK GDPR.

Our software provider, Take A Byte, is contractually bound by data protection requirements.

We maintain physical, digital, and managerial safeguards to prevent data misuse, loss, or unauthorised access.

6. How Long We Keep Your Data

We only retain data for as long as it is legally or operationally required. This may vary depending on the nature of the course.

We regularly audit and review our data retention schedules to ensure compliance with legal, and regulatory obligations.

7. Cookies and Tracking

We use cookies to enhance user experience, track usage for improvement, and deliver targeted advertising (with consent).

Cookies we use may include:

  • Functional cookies – needed for the site to work

  • Statistics cookies – e.g. Google Analytics, to improve usability

  • Marketing cookies – e.g. Facebook Pixel, to support advertising and course promotions

Cookies are managed via our consent banner when you visit the site. You may change your settings at any time.

8. Your Rights

You have the right to:

  • Access the personal data we hold about you

  • Correct inaccurate or incomplete data

  • Request deletion of your data when no longer needed

  • Object to certain types of processing

  • Withdraw consent at any time (for consent-based processing)

  • File a complaint with the ICO if you believe your data is being mishandled

If you request deletion of your data, we will comply unless we are legally obligated to retain it.

9. Data Sharing

We do not share your personal data with any third parties except:

  • Where required by law​

  • When enrolling via a commercial employer booking

We do not sell personal data to any third party under any circumstance.

10. Safeguarding and Special Considerations

In some cases, especially when working with vulnerable adults or young people, safeguarding information may be collected. We follow strict protocols to ensure data is:

  • Only handled by relevant safeguarding staff

  • Stored securely with access control

  • Only shared when legally required (e.g. for safeguarding referrals or DBS compliance)

11. Changes to This Policy

This Privacy Policy is reviewed annually and may be updated as required. If significant changes are made, we will notify you via email or display a notice on our website.

If you have any questions or need to exercise your rights under this policy, please contact us at admin@brightonswimmingschool.com

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