Privacy Policy

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Data Protection Policy (GDPR)

We, Manor House Barn are “controllers” of the information which we collect from or about you – “Personal Data”. As controllers, we are responsible for the security and processing of your Personal Data. This Privacy Notice explains why and how we process your data.

The word ‘process’ covers most things that can be done with personal data, including collection, storage and destruction of that data.

Manor House Barn Swim School (MHB) is a private company.

Address:    

Manor House Barn

Mill Lane

Wall Hill Road

Dobcross

Saddleworth

OL3 5GS

Email:

info@manorhousebarn.com

If you have any queries about your data or anything related to data protection, please contact us on info@manorhousebarn.com.

You have certain rights in relation to your personal data including the right to object to processing of your data in certain circumstances.

1. Policy Statement

a. Everyone has rights with regard to how their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, and we recognise the need to treat it in an appropriate and lawful manner.

b. The information, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the General Data Protection Regulations (GDPR) and other regulations.  The GDPR imposes restrictions on how we may use that information. Section 15 of this Policy deals with Access to Personal Information. 

c. This Policy does not form part of any employee's contract of employment, and it may be amended at any time.  Each member of staff is obliged to assist to ensure full compliance.  Any breach of this Policy will be taken seriously and may result in disciplinary action. 

d. All staff members will be trained on the basic principles and relevant procedures as part of their induction process and will receive updates from time to time.   If a member of staff is unsure of their obligations, they are urged to seek clarity immediately from their line manager, or the Data Protection Officer.

2. Status of the Policy

a. This policy sets out our rules on data protection and the legal conditions that must be satisfied in relation to the obtaining, handling, processing, storage, transportation and destruction of personal information.  

b. The Finance Director is responsible for ensuring compliance with GDPR and with this policy. The post of the Data Protection Officer is currently held by Jane Dronsfield. Any questions or concerns about the operation of this policy should be referred in the first instance to your line manager, or to the Data Protection Officer. 

c. If you consider that the policy has not been followed in respect of personal data about yourself or others you should raise the matter with your line manager in the first instance, and also notify the Data Protection Officer.

3. Definition of Data Protection Terms

The terms referred to in this document are defined below:

a. Data is information that is stored electronically, on a computer, or in certain paper-based filing systems.

1. Data subjects for the purpose      of this policy include all living individuals about whom we hold personal      data. A data subject need not be a UK national or resident. All data      subjects have legal rights in relation to their personal data.
2. Personal data means data      relating to a living individual who can be identified from that data (or      from that data and other information in our possession).  Personal      data can be factual (such as a name, address or date of birth) or it can      be an opinion (such as a performance appraisal).
3. Data controllers are the people      who or organisations that determine the purposes for which, and the manner      in which, any personal data is processed.  They have a responsibility      to establish practices and policies in line with GDPR. We are the data      controller of all personal data used in our business.
4. Data users include employees whose work involves      using personal data.  Data users have a duty to protect the      information they handle by following our data protection and security      policies at all times.
5. Data processors include any      person who processes personal data on behalf of a data controller.      Employees of data controllers are excluded from this definition, but it      could include suppliers that handle personal data on our behalf.
6. Processing is any activity that involves use of the      data.  It includes obtaining, recording or holding the data, or      carrying out any operation or set of operations on the data including      organising, amending, retrieving, using, disclosing, erasing or destroying      it. Processing also includes transferring personal data to third      parties.
7. Sensitive personal data includes      information about a person's racial or ethnic origin, political opinions,      religious or similar beliefs, trade union membership, physical or mental      health or condition or sexual life, or about the commission of, or      proceedings for, any offence committed or alleged to have been committed      by that person, the disposal of such proceedings or the sentence of any      court in such proceedings.  Sensitive personal data can only be      processed under strict conditions and will usually require the express      consent of the person concerned.

4. Data Protection Principles

Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be:

a. processed fairly and lawfully.

1. processed for limited purposes and in an      appropriate way.
2. adequate, relevant and not excessive for the      purpose.
3. accurate.
4. not kept longer than necessary for the      purpose.
5. processed in line with data subjects' rights.
6. secure.
7. not transferred to people or organisations      situated in countries without adequate protection.

5. Fair and Lawful Processing

a. The Act is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject.  The data subject is entitled to request and be advised who the data controller is, who the data controller's representative is (the Data Protection Officer), the purpose for which the data is to be processed by us, and the identities of anyone to whom the data may be disclosed or transferred.

b. For personal data to be processed lawfully, certain conditions have to be met.   These may include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, more than one condition must be met. In most cases the data subject's explicit consent to the processing of such data will be required.

6. Processing for Limited Purposes

a. Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for any other purposes specifically permitted by the Act.  This means that personal data must not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose before any processing occurs.

7. Adequate, Relevant and Non-Excessive Processing

a. Personal data should only be collected to the extent that it is required for the specific purpose notified to the data subject. Any data that is not necessary for that purpose should not be collected in the first place.

8. Accurate Data

a. Personal data must be accurate and kept up to date. Information that is incorrect or misleading is not accurate, and steps should therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out of date data should be destroyed.

9. Timely Processing

a. Personal data should not be kept longer than is necessary for the purpose.  This means that data should be destroyed or erased from our systems when it is no longer required.  For guidance on how long certain data is likely to be kept before being destroyed, contact the Data Protection Officer.

10. Processing in Line with Data Subject's Rights

Data must be processed in line with data subjects' rights. Data subjects have a right to:

a. request access to any data held about them by a data controller.

1. prevent the processing of their data for direct marketing purposes.
2. ask to have inaccurate data amended.
3. prevent processing that is likely to cause damage or distress to themselves or anyone else.

11. Data Security

a. We must ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.  Data subjects may apply to the courts for compensation if they have suffered damage from such a loss.

b. The GDPR require us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction.  Personal data may only be transferred to a third-party data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.

Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:

a. confidentiality means that only people who are authorised to use the data can access it.

1. integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
2. availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on our central computer system instead of individual PCs.

12.  Dealing with Subject Access Requests

a.  Any member of staff who receives a request from a data subject for information that we hold about them should forward it to their line manager immediately.  The procedure to be followed is set out in Section 15.

13. Providing Information over the Telephone

Any member of staff dealing with telephone enquiries should be careful about disclosing any personal information held by us. In particular, they should:

a. check the caller's identity to make sure that information is only given to a person who is entitled to it.

1. suggest that the caller put their request in writing if they are not sure about the caller's identity and where their identity cannot be checked.
2. refer to their line manager or the Data Protection Officer for assistance in difficult situations.  If in doubt do not disclose and ask for advice.

14. Monitoring and Review of the Policy

a. The Directors review this policy annually.  Recommendations for any amendments are reported to the Data Protection Officer.

b. We will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives.

15. Access to Personal Information

a. What we do with your Data

This document gives details of the data that MHB holds on you as a customer, where this data has been obtained from and what the reasons are for our holding it.

It is vital that MHB holds accurate information and ensures that records are up to date.  It is the responsibility of all involved to ensure that the privacy, security and confidentiality of all personal information are respected within the employment relationship.

The GDPR states that MHB should hold only that data, which is relevant, and that the data should be used only for the purposes of which it was collected.

You have the right to request a copy of any data that MHB holds relating to yourself.

b. Methods of Collection of Personal Data

There are a number of sources of personal data that are received both during the booking process and through your time with us at the swim school as customers. The main sources of this information are:

1. Address and contact details 
2. medical information that you’ve shared with us 
3. progression data related to yourself or      children / children in your care 
4. bank details for booking purposes 
5. medical reports (only with explicit prior      consent); personal (customer) feedback received by MHB 

This list is not exhaustive and there may be other sources of personal data that are received and processed during your time as a customer with us. 

c. Reasons for Collecting Personal Data

Different personal information will be required at different stages.  Information will be requested only when it is necessary. But the majority of personal data will be collated when you 1st join us as a swim school customer. 

d. Medical Issues

Where an individual has a medical condition, which affects their ability in the pool, MHB will collate this data so we can provide the best service possible and cater to individual needs. Medical information is required to enable informed planning and appropriate support is given. 

e. What MHB does with your Data

Once personal information is collected, it is stored on our secure lesson management system.  

16. Access to Personal Information Procedure

Under the GDPR, customers have a right to request details of any personal data held by MHB and to be informed why it is being held.  They also have the right to be provided with copies of the relevant data.

An individual can only request data held by MHB relating specifically to them. MHB cannot accept requests from any other person such as family members. 

All requests for access to personal data must be formally submitted and sent to the Finance Director, the reasons for requiring access and what information is to be accessed must be stated.

Arrangements will be made for the customer to view the personal data within 1 month of the request being submitted. Under no circumstances must the original personal data be removed from the office.  Copies of personal data may be made with permission from the Finance Director.