In applying for The Sunday Swim card, I agree to behave in a manner that is respectful towards others at all times when attending the swim. I understand the swim card remains the property of The Sunday Swim and must be surrendered on request. Loss of the card must be reported to the swim and a replacement costs £3. I understand the swim card exists to enable access to the Arlington Baths for the Sunday night swim only upon payment of the prevailing entry fee at the door. Entry is not guaranteed if the safe capacity of the premises is reached.
I understand that reasonable steps will be taken to protect my personal information which will not normally be shared with third parties. However, my personal information will be available to the Arlington Baths Club and the swim organisers. I agree that the swim organisers may use an online membership management system to store and manage my information.
The Sunday Swim – Privacy Notice
Who we are
The Sunday Swim runs a weekly clothes-free (naked) swim on Sunday evenings in Glasgow’s West End at the Arlington Baths Club.
We are committed to the safekeeping of personal details of our members, and anyone else whose information we hold. This notice explains how and why we use your personal data.
Any references to ‘The Sunday Swim’, ‘the swim’, or to ‘we’ or ‘us’ refer to:
● The Sunday Swim
● The Arlington Baths Club.
We use three key definitions to describe people mentioned in this notice. These are definitions used by the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights (www.ico.org.uk)
● ‘Data subject’: this is you. As the data subject, we respect your right to control your data.
● ‘Data controller’: this is us, The Sunday Swim. We determine why and how your personal data is used (as outlined in this notice).
● ‘Data processor’: this is a person, or organisation, who processes your
data on our behalf. For example, this might be an officer of The Sunday Swim, or a member of staff of Arlington Baths Club which provides storage space for our paper documents (‘processing’ includes the storage of data).
We will never sell your personal data.
Why we collect your data
We collect your personal data in order to process your membership, to keep in touch with you, or for some other legitimate purpose (for example for safeguarding purposes).
We will only ever collect, store and use your personal data when we have an identified purpose and reason to do so. The ICO refers to this as a ‘lawful basis’.
Further information about why we collect your personal data is outlined below.
a) To administer your The Sunday Swim membership
We collect your personal data to administer your membership, which may involve:
● Issuing membership card(s),
● Sending you details of other membership benefits, including details of meetings, social events or dates of closures
● We use the ICO’s definition of ‘contractual’ for the lawful basis for processing your data for these purposes.
We use the ICO’s definition of ‘legitimate interest’ for the lawful basis for processing your data for these purposes.
Unless we hear from you directly, we may continue to send you information about The Sunday Swim for a period of time after your membership has ended.
We respect your right to update the way we get in touch with you about The Sunday Swim at any time.
We, and the Arlington Baths Club, may also hold sensitive information about you (e.g. about any health issues that may impact on your, or other members’ safety).
What data we collect
a) Basic information
We will usually collect basic information about you, including your name, date of birth, postal address, telephone number, email address and photograph.
We then create membership data such as join, expiry and renew dates, status of membership, payment and attendance histories.
Most of the time, we collect this data from you directly. Usually this is in person; other times, it is over the telephone, in writing, through web forms from our online membership system partner or through an email. Occasionally we obtain information, such as your telephone number or other contact details, from external sources (only where we have been assured that you have given permission for such information to be shared).
b) Other ways in which we collect personal data include:
i) Our website
Our website uses ‘cookies’ to help provide you with the best experience possible. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.
Our cookies help us:
● Make our website work as you’d expect
● Remember your settings during and between visits
● Improve the speed/security of the site
● Allow you to share pages with social networks like Facebook
● Continuously improve our website for you
● Track traffic levels on the website and on particular pages
ii) Social media sites, such as Facebook and Twitter, if you have contacted us through these.
b) Sensitive personal data
We routinely collect sensitive personal data (specifically information relating to health) about members on behalf of the Arlington Baths Club on the first visit for safety purposes in case of accident or illness. The information is transferred to the Arlington Baths Club and becomes their responsibility. The Sunday Swim does not retain that information.
We may also collect sensitive personal data if you have an accident whilst on the premises. This information will be retained for legal reasons, for safeguarding purposes and to protect us (including in the event of an insurance or legal claim).
c) Children and young people
We do not admit young people under the age of 18 to the swim.
Sharing your data
We only share your information with third parties in the following circumstances:
i) with your consent;
ii) to any successor organisation carrying on our swim activities following a reorganisation or merger;
iii) with our online membership partner;
iii) if we require to do so in order to comply with a legal, regulatory or safeguarding obligation. This includes exchanging information with other naturist organisations in the event of misconduct.
For the purposes of IT hosting and maintenance, your information may be situated outside of the European Economic Area (EEA).
Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our officers receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
Paper documents are held in a locked cabinet or room when not in use. We cannot guarantee the security of the internet, and any online communications (e.g. information provided by email or our website) are at your own risk.
The Arlington Baths Club has CCTV at its entrance, and you may be recorded when you visit. CCTV is there to help provide security and to protect both you and the Arlington Baths Club.
c) Data retention policy
We will only use and store information for as long as it is required for the purposes it was collected for. We continually review what information we hold and delete what is no longer required.
Unless we require to keep your data for safeguarding or legal purposes, we delete your membership application form after six months if you have not renewed by the end of the current membership year. If you then wish to re-join, you will be asked to complete a new application.
We respect your right to control your data. Your rights include:
i) The right to be informed
This privacy notice outlines how we capture, store and use your data. If you have any questions about any elements of this notice, please contact us.
ii) The right of access
If you wish to obtain a record of the personal data we hold about you, through a Subject Access Request, we will respond within one month.
iii) The right to rectification
If we have captured information about you that is inaccurate or incomplete, we will update it.
iv) The right to erase
You can ask us to remove your personal details from our records.
v) The right to restrict processing
You can ask us to stop using your personal data.
vi) The right to data portability
You can ask to obtain your personal data from us for your own purposes.
vii) The right to object
viii) Rights in relation to automated decision making and profiling
We respect your right not to be subject to a decision that is based on automated processing.
For more information on your individual rights, please see the Information Commissioner’s Office.
If you would like to exercise any of these rights, please contact:
Data Protection Officer
The Sunday Swim, Arlington Baths Club, 61 Arlington Street, Glasgow, G3 6DT.
Making a complaint
There may be times when we do not meet your expectations. When this happens, we want to hear about it, in order to deal with the situation as quickly as possible.
All complaint information will be handled sensitively, in line with relevant data protection requirements.
Overall responsibility for this policy and its implementation lies with the Chairperson of The Sunday Swim.
Information Commissioner’s Office
For further assistance with complaints regarding your data, please contact the Information Commissioner’s Office, whose remit covers the UK.
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow SK9 5AF
Telephone: 0303 123 1113
Leaving our website
We are not responsible for the privacy practices or the content of any other websites linked to our website. If you have followed a link from our website to another website you may be supplying information to a third party.
or speak to any of the swim officers (door team) on a Sunday evening.
Our website is hosted by WordPress and we use Google Gmail for email communication.
Our online membership partner is Membermojo