Shapland Swim Schools Pty Ltd ACN 051 839 242 (Shapland) respects the privacy of individuals by treating all personal information as confidential and by handling it in accordance with this policy and the Australian Privacy Principles (Schedule 1, Privacy Act 1988 (Cth) (Privacy Act)).
Any references in this policy to "you" or "your" includes your child/ren as their parent or guardian (as applicable).
What is your personal information?
Personal information is defined in the Privacy Act to mean information or an opinion about an identified individual, or an individual who is reasonably identifiable:
• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.
For example, personal information includes an individual's name, address, telephone number, email address, bank account or credit card details.
Collection of personal information:
Shapland has operated swim schools since 1948 as well as franchising it's business since 1992. Shapland's Swim Schools principal function is to teach private swimming lessons to children of all ages (Services). As part of providing the Services, Shapland also runs promotional activities and allows individuals to subscribe to Shapland's mailing list. It is also the policy of Shapland in providing the Services, to further develop its own website located at the domain name www.shapland.com.au/ (Website)
Shapland only collects personal information that is reasonably necessary to provide the Services. The types of information collected by Shapland include, but may not necessarily be limited to:
• Details you provide us with when you visit our locations or enter our promotions;
• Your name, postal address, telephone number and email address from promotion entrants;
• Your name, the name and date of birth of any minors who you enrol in our Swim Schools, your mailing address, email address, phone number and credit card information;
• Any medical information about any persons enrolled in our Swim Schools which we need to be aware of to provide safe lessons;
• Details of website usage from visitors to our Website;
• Images collected by the CCTV system (if applicable to your swim school location).
Other than outlined above, Shapland will not collect sensitive information about you )such as your race or ethnic origin, political beliefs or religion). If Shapland needs to collect any other sensitive information, it will ask your consent when it collects this information (unless an exemption applies).
Shapland may collect personal information in the following ways:
• when you provide us with information at one of our locations;
• when you visit one of our swim school locations:
• when you enter a promotion;
• and on an on-going basis, whenever you visit or use Shapland's Website.
If reasonable and practicable to do so, Shapland will collect personal information directly from you.
Shapland will only collect personal information from you by lawful and fair means.
Use and disclosure of personal information collected by Shapland:
We will use, hold and in limited circumstances or with your consent, disclose, your personal information primarily for the purpose of providing the Services and also for security, operational, quality control and educational purposes.
Shapland may use your information to process your transaction; administer your account; for Shapland's own internal purposes (such as risk management, staff training and billing); to help Shapland develop its website to be more specific to Customers' needs and user friendly; to advise you about upcoming events and promotions, and for any other use which you authorise.
In addition, Shapland may also use your information to contact you regarding its services. However, Shapland will not do this by email (except as part of an email which facilitates, completes or confirms a transaction with you) unless we have your consent to do so.
These emails will include an "unsubscribe" facility. Alternatively, if you no longer wish to receive emails, you can contact us by phoning your nearest Shapland location, details of which are available on the Locations page of our website.
Subject to provisions below relating to CCTV footage, in some circumstances your personal information may be disclosed to service providers that perform a range of services on behalf of Shapland including auditors and solicitors, accountants, information technology vendors and other consultants.
Shapland may also disclose your personal information to law enforcement agencies (if required by law) and businesses within the Shapland Swim Schools group. Shapland is unlikely to disclose your personal information to overseas recipients.
Security of your Information:
We use industry-standard safeguards to ensure the confidentiality of your personal information and we will take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. To the maximum extent permitted by law, however, we accept no responsibility for any loss, misuse, unauthorised access or disclosure, alteration or destruction of personal information which you submit to Shapland.
Reasonable steps will be taken to securely dispose of personal information that is no longer needed for the purposes for which it was collected.
Access and updates to your personal information:
Subject to certain exceptions, Shapland will provide you with access to your personal information upon receiving a written request via our Contact Us form. Shapland will endeavour to acknowledge such requests within 14 days of receiving the request and provide the requested information within 30 days.
If you believe that Shapland is holding inaccurate or outdated information about you, you should notify Shapland in writing by contacting us at the sent via our Contact Us form or using the contact details below. We will take reasonable steps to correct the information so that it is accurate, up-to-date, complete, relevant and not misleading. Shapland may also contact you from time to time to check that your information is still accurate.
In certain circumstances, Shapland may not be able to correct or provide you with access to your personal information. In these circumstances Shapland will write to you to explain and provide the reasons why.
Some of our swim schools have CCTV systems in place. Cameras are used in each of the following locations: car park, observation room, office, pool area and pool deck (as applicable to the relevant premises). Signage is used to identify/notify you of each camera at each site.
Purposes of CCTV system:
The CCTV system monitors areas within the applicable swim schools to:
• capture incidents which occur in the areas;
• enable quality control of lessons;
• improve teaching methods and educate staff;
• observe pool water quality;
• monitor visitors to the swim schools for safety and security reasons;
• (subject to availability and legal requirements) assist in the investigation of workplace health and safety incidents or other investigations conducted either by Shapland or an external authority (such as a law enforcement agency).
CCTV cameras will not be installed in areas where individuals have a reasonable expectation of privacy, such as toilets, showers and change rooms.
Storage and security:
CCTV footage from the office, car park and pool areas is stored on a hard drive for up to a maximum (which varies from site to site according to the number of cameras) of 30 days before being systematically erased. CCTV footage from the observation room areas (including the pool deck at Gaven swim school) is stored on a hard drive for up to a maximum (which varies from site to site according to the number of cameras) of 14 days before being systematically erased. There is no automatic back up of data. If a particular section of footage is required for future use (for example, to investigate a security incident), this may be stored for a longer period.
The hard drives are stored in locked compartments which are accessible by authorised personnel only. The CCTV footage can only be accessed remotely by those authorised via the software application by those with appropriate access rights as set out below.
Access - Company owned and operated sites:
Only three people have access to the CCTV footage at the company owned and operated swim schools at Warner, Gaven and Stretton: our operations manager, our CEO and Group operational manager.
Access - Franchised Sites:
The franchisee of the franchised site has access to the CCTV footage. Shapland's Group Operations Manager and the CEO may also have access the CCTV footage for the purpose of ensuring the franchisee's compliance with the franchise agreement.
When the CCTV footage may be released to third parties:
CCTV footage may be provided to the Queensland Police Service in accordance with their investigation powers or as otherwise required by law. CCTV footage may also be provided to Shapland's insurers and advisors for the purpose of investigating and responding to an incident.
A request for a copy of any CCTV footage must be made in writing directed or addressed to Shapland's Group operational manager.
The request for footage must specify:
• who is making the request;
• the purpose for which the request is being made;
• if the request is authorised by law, and if so, details of the legal power;
• how the footage will be used (including whether it will be copied or still pictures created from it, and whether it will be necessary to retain a copy of the footage for reasonable record keeping purposes); and
• where and by whom the footage will be kept for the duration of its use for the identified purpose.
Details of the request and of the response to the request will be retained by Shapland for audit and record management purposes.
In the event that footage is provided in response to such a request, unless a copy of the data is required for reasonable record keeping purposes, the data must be returned to Shapland's Group operational manager, after its use and it will be destroyed.
If you consider that Shapland has breached the Australian Privacy Principles, you may make a complaint in writing to Shapland at the contact details below.
Shapland will endeavour to acknowledge the complaint within 14 days of its receipt and investigate the complaint and respond to you advising the outcome of the investigation within 30 days or as soon as practicable.
If you are not satisfied with our response, you may take your complaint to the Office of the Australian Information Commissioner.
Changes to our policy:
Phone: 1 800 TO SWIM (1 800 867 946)
Post: Shapland Swim Schools, PO Box 368, Paddington QLD 4064
(or via the Contact Us page on our Website).
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