Privacy Policy

Effective update: 20 August 2026

Aquatic 2012 CIC (“Aquatic 2012”, “we”, “us” or “our”) is committed to protecting the privacy and personal information of the children, young people, parents, guardians, staff, volunteers and other individuals who use or interact with our services.

This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, who we may share it with, and the rights you have in relation to your information.

For the purposes of UK data protection law, Aquatic 2012 CIC is the Data Controller for the personal information described in this policy.

1. Our Services

Aquatic 2012 CIC provides aquatic activities and opportunities including, but not limited to:

• Swimming lessons and swimming development
• Water polo and Mini Polo
• Development and performance programmes
• Swim & Play and other multi-aquatic activities
• Training camps and clinics
• Competitions, tournaments and festivals
• Community swimming and water polo programmes
• School and community projects
• Holiday programmes
• Events and fundraising activities
• Coach and teacher development
• Online information, registration and membership services

In this Privacy Policy, these activities, together with our website, online forms and associated services, are referred to collectively as our Services.

2. Personal Information We Collect

The information we collect depends on how you interact with Aquatic 2012 CIC.

Parents, guardians and adult participants

We may collect:

• Name
• Email address
• Telephone number
• Postal address
• Emergency contact information
• Communication preferences
• Membership and booking information
• Payment and transaction information
• Records of correspondence with us
• Information provided through registration, enquiry or consent forms

Where payments are made using an external payment provider or banking service, that provider may process payment information on our behalf. We do not normally need to retain full debit or credit card details ourselves.

Children and young people

Because much of our work involves children and young people, we may need to collect information including:

• Name
• Date of birth or age
• Parent or guardian contact information
• Emergency contact details
• Swimming ability and experience
• Relevant squad, class, stage or training group
• Attendance records
• Competition and event participation
• Relevant medical conditions
• Allergies
• Injuries
• Medication or treatments that coaches may need to be aware of
• Additional support or accessibility requirements
• Relevant safeguarding information
• Relevant behavioural or incident information
• Photographic and video permissions
• Performance and development information where appropriate

We aim to collect only the information reasonably necessary to provide our activities safely and effectively.

3. Health and Medical Information

Some of the information we collect about participants, particularly children, may constitute special category personal data under UK data protection law.

This can include information about:

• Medical conditions
• Disabilities
• Allergies
• Injuries
• Medication
• Other health information relevant to safe participation

We collect this information because coaches and staff may need it to keep participants safe and respond appropriately in an emergency.

Where special category information is processed, we will ensure that an appropriate additional legal condition applies. Depending on the circumstances, this may include explicit consent, vital interests or safeguarding and substantial public interest provisions under UK data protection law.

Access to health and medical information is restricted to those who reasonably need the information to keep the participant safe or administer the relevant activity.

4. How We Collect Information

We may collect information:

• When you complete a registration or sign-up form
• When you make an enquiry
• When you join one of our programmes
• When you book a camp, event or competition
• When you communicate with us by email, telephone, messaging service or social media
• Through attendance registers
• From coaches and authorised members of staff
• Through competition or event administration
• From a parent or guardian
• From a partner organisation where there is an appropriate reason for the information to be shared
• Through our website and associated technologies

5. How We Use Personal Information

We may use personal information to:

• Register participants for our programmes
• Deliver swimming, water polo and other aquatic activities
• Allocate participants to appropriate classes, stages, squads or groups
• Manage memberships and bookings
• Communicate timetable or programme information
• Manage competitions, camps, festivals and events
• Record and monitor attendance
• Protect the health and safety of participants
• Carry out safeguarding responsibilities
• Respond to emergencies
• Process payments and maintain financial records
• Respond to questions and enquiries
• Manage complaints and incidents
• Manage insurance matters or legal claims
• Improve our programmes and services
• Maintain appropriate business and operational records
• Send relevant news and programme information
• Promote Aquatic 2012 CIC where appropriate
• Comply with legal and regulatory requirements

6. Our Lawful Bases for Processing

UK data protection law requires us to have an appropriate lawful basis for using personal information.

Depending on the particular purpose, we may rely on:

Contract

Where processing is necessary to provide a service you have booked or requested from us.

For example, we need a participant’s name, age and contact details in order to manage their membership and provide their sessions.

Legitimate interests

We may process information where it is reasonably necessary for the legitimate operation of Aquatic 2012 CIC, provided those interests are not overridden by the rights and interests of the individual.

Examples may include:

• Programme administration
• Responding to enquiries
• Improving our services
• Managing our organisation
• Protecting our organisation and participants
• Maintaining appropriate records

We take particular care when relying on legitimate interests in relation to children.

Legal obligation

We may process information where we need to comply with a legal or regulatory responsibility.

Vital interests

In an emergency, information may be processed or shared where this is necessary to protect someone’s life or physical safety.

Consent

We may rely on consent where appropriate, particularly for certain optional activities.

For example, we will normally seek appropriate permission before using identifiable photographs or videos of children for promotional or marketing purposes.

Where we rely on consent, it can be withdrawn at any time.

Withdrawal of consent does not affect processing that was lawful before consent was withdrawn.

7. Children and Young People’s Privacy

Children and young people are at the heart of much of Aquatic 2012 CIC’s work.

We therefore take the protection of children’s personal information particularly seriously.

We will:

• Collect only information that has a genuine purpose
• Take additional care when deciding how children’s information is used
• Keep information appropriately secure
• Limit access to those who reasonably need it
• Avoid using children’s information in ways they or their parents would not reasonably expect
• Seek parental or guardian involvement where appropriate
• Give particular consideration to children’s best interests when making decisions about their information

Information such as medical conditions, medication and swimming ability may need to be available to the coaches responsible for that child’s safety.

We may also share information without consent where this is necessary to safeguard a child or another person and there is an appropriate legal basis for doing so.

8. Photographs and Video

Aquatic activities, competitions, festivals and community events may occasionally be photographed or filmed.

Photographs and video may be used for purposes including:

• Promoting Aquatic 2012 CIC
• Social media
• Our website
• News and media coverage
• Funding and sponsorship reports
• Community impact reporting
• Celebrating participant achievements

Where identifiable images of children are being used for promotional purposes, we will normally obtain appropriate parent or guardian permission.

Where an event has specific photography arrangements, additional information may be provided as part of the event registration process.

Safeguarding considerations will always take priority when deciding whether an image should be published.

9. Sharing Personal Information

We do not sell personal information.

We may share information where reasonably necessary with organisations or individuals including:

• Aquatic 2012 CIC employees
• Coaches, teachers and authorised volunteers
• Pool and facility operators
• Schools and community partners
• Competition and tournament organisers
• Partner clubs where relevant to an activity
• Accommodation or travel providers where relevant to an organised trip
• IT, website, database and cloud service providers
• Email and communication providers
• Form and registration providers
• Payment providers
• Accountants and professional advisers
• Insurance providers
• Safeguarding organisations
• Emergency services
• Police or other authorities where required
• Regulators or public authorities where required by law

We aim to share only the information necessary for the particular purpose.

Coaches, staff, contractors and service providers who have access to personal information are expected to handle it appropriately and confidentially.

10. Safeguarding

Protecting children and vulnerable people can require information to be shared.

Where we have a safeguarding concern, we may share relevant information with appropriate individuals or organisations where we believe this is necessary and lawful.

This may include safeguarding professionals, schools, governing or sporting organisations, local authorities, emergency services or the police.

Consent is not always required before information can be shared for safeguarding purposes.

The safety and welfare of the child or individual will be an important consideration in any decision to share information.

11. How Long We Keep Information

We keep personal information only for as long as reasonably necessary for the reason it was collected, including where information needs to be retained for:

• Legal requirements
• Financial and accounting requirements
• Insurance
• Safeguarding
• Resolving complaints or disputes
• Defending or establishing legal claims
• Maintaining appropriate organisational records

Different categories of information may therefore have different retention periods.

When information is no longer required, we will delete, anonymise or securely dispose of it as appropriate.

12. Security

We take reasonable technical and organisational measures to protect personal information from:

• Unauthorised access
• Loss
• Misuse
• Alteration
• Accidental disclosure
• Destruction

However, no method of electronic storage or internet transmission can be guaranteed to be completely secure.

Access to sensitive information is restricted wherever reasonably possible to those who require it to carry out their role.

13. Website Information and Analytics

When you visit our website, certain technical information may be collected automatically, including:

• Internet Protocol (IP) address
• Browser type
• Device type
• Operating system
• Pages visited
• Time and date of visits
• Time spent on pages
• Referring website
• General website interaction information

This information may be used to maintain our website, understand how it is used, improve its performance and protect its security.

We may use third-party analytics providers, including Google Analytics, where configured on our website.

14. Cookies and Similar Technologies

Our website may use cookies and other storage or access technologies.

These may include technologies used for:

• Website functionality
• Security
• Remembering preferences
• Understanding website usage
• Analytics
• Advertising or marketing

Some technologies are necessary for the website to function.

Certain technologies used solely to generate statistical information to improve our website may be used where permitted under the statistical purposes exception to the Privacy and Electronic Communications Regulations, provided the relevant requirements are satisfied, including giving users clear information and an appropriate way to object.

Where consent is legally required, particularly for advertising, remarketing, profiling or cross-site tracking technologies, those technologies will not be used until appropriate consent has been obtained.

Users can change or withdraw their choices where our website provides those controls.

15. Google, Meta and Other Online Services

We may use services supplied by organisations such as Google and Meta for website analytics, advertising, social media or communications.

Where advertising or remarketing technologies involve tracking individuals or their activity across websites or services, we will use those technologies only where the appropriate consent or other legal requirements have been satisfied.

These providers have their own privacy policies explaining how they process information.

16. Marketing Communications

We may contact parents, guardians or adult participants about:

• Existing programmes
• Programme changes
• New sessions
• Camps
• Competitions
• Community activities
• Events
• Other relevant Aquatic 2012 CIC opportunities

Where required, we will obtain consent before sending electronic marketing.

In some circumstances, UK electronic marketing rules allow organisations to contact existing customers about similar services, subject to certain conditions and the right to opt out.

Every person receiving marketing communications from us can ask us to stop sending them.

You can unsubscribe using the instructions in the communication or contact us directly.

Operational messages necessary to administer a programme, booking or membership are not marketing messages and may still need to be sent.

17. International Transfers

Some organisations that provide technology or online services to Aquatic 2012 CIC may process information outside the United Kingdom.

Where personal information is transferred internationally, we will take reasonable steps to ensure that an appropriate legal mechanism and safeguards are in place as required by UK data protection law.

18. Third-Party Websites

Our website, emails or social media accounts may contain links to websites operated by other organisations.

Aquatic 2012 CIC is not responsible for the privacy practices or content of websites we do not operate.

We recommend reviewing the privacy information of any external service before providing it with personal information.

19. Your Data Protection Rights

Depending on the circumstances, individuals have rights under UK data protection law including:

• The right of access – to ask for a copy of personal information we hold about you.
• The right to rectification – to ask us to correct inaccurate or incomplete information.
• The right to erasure – to ask us to delete information in certain circumstances.
• The right to restriction – to ask us to limit how information is used in certain circumstances.
• The right to object – to object to certain uses of personal information.
• The right to data portability – to receive certain information in a structured, commonly used and machine-readable form where applicable.
• The right to withdraw consent – where our processing relies on consent.

Not every right applies in every circumstance.

We may need to verify your identity before responding to a request.

Parents or guardians may make appropriate requests regarding information about their children, although children’s own data protection rights must also be considered as they develop sufficient understanding and capacity.

20. Complaints

If you are concerned about how Aquatic 2012 CIC has handled personal information, please contact us first so that we can investigate.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.

Information about your rights and how to make a complaint is available from the ICO at www.ico.org.uk.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

• Our programmes
• Our technology
• The organisations we work with
• Data protection law
• Our internal procedures

The latest version will be published on our website with an updated effective date.

Where a change is particularly important, we may also notify members directly.

22. Contact Us

If you have any questions about this Privacy Policy, how we use personal information, or you wish to exercise a data protection right, please contact:

Aquatic 2012 CIC

Email: matt@drenchedschool.co.uk