Kingswim is committed to protecting your privacy when you engage with us.
Kingswim supports and endorses the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act) and will only collect, use, disclose, and store personal information in accordance with these principles.
This policy outlines how we will comply with our obligations under the Privacy Act.
Personal information means 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.
Sensitive information is a special category of personal information. Sensitive information means:
- information or an opinion about an individual’s (i) racial or ethnic origin, (ii) political opinions, (iii) membership of a political association, (iv) religious beliefs or affiliations, (v) philosophical beliefs, (vi) membership of a professional or trade association, (vii) membership of a trade union, (viii) sexual orientation or practices, (ix) criminal record, that is also personal information;
- health information about an individual,
- genetic information about an individual that is not otherwise health information;
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification, or
- biometric templates.
What type of personal information do we collect?
The type of information that Kingswim collects and holds will depend on the nature of your involvement with us.
Depending on the reason for collecting the personal information, the personal information that we collect may include (but is not limited to) name, age, residential address, suburb, postcode, date of birth, phone number, email address, bank account details, next of kin details and images.
We may also collect sensitive information from a person including a working with children check or a police check.
Whilst you are not required to provide the personal information and/or sensitive information requested by Kingswim, if you choose not to provide information as requested, it may not be practicable for us to service your needs. For instance it will not be possible for us to enrol your child into a swimming program, if you want to remain anonymous or use a pseudonym.
We don’t usually receive unsolicited personal information but in circumstances where we do receive unsolicited personal information we will usually destroy or de-identify the information as soon as practicable if it is lawful and reasonable to do so unless the unsolicited personal information is reasonably necessary for, or directly related to, our functions or activities.
How do we collect personal information?
Our Customer Contact Centre based in our Head Office in Mornington is primarily responsible for collecting personal information from you at the time when you make an enquiry or enrol your child into a swimming program.
However, there are other avenues by which we collect personal information, including via our Centre teams when a person walks in to a Centre with an enquiry and also online via our website.
We will endeavour wherever practicable to collect personal information directly from you. Information is collected in a number of ways including from when you fill in a form, make an enquiry online, attend a face-to-face meeting, provide email correspondence, engage with us on social media, phone us, or make a payment.
Kingswim may collect personal information from individuals such as staff members, current parents and/or guardians and their children, future parents and/or guardians and their children, visitors, contractors, and supplier.
We will generally obtain consent from the owner of personal information to collect their personal information. Consent will usually be provided in writing however sometimes it may be provided orally or may be implied through a person’s conduct.
We will endeavour to only ask for your personal information if it is reasonably necessary for the activities that you are seeking to be involved in.
In relation to the collection and disclosure of sensitive information, we are bound by the APPs, which provide for the circumstances in which disclosure is permitted, or required by law.
How will we use your personal information?
Kingswim may collect, hold, use or disclose your personal information for the following general purposes:
- to identify you;
- for the purpose for which the personal information was originally collected;
- for a purpose for which you have consented;
- for any other purpose authorised or required by an Australian law; and
- for any other purpose authorised or required by a court or tribunal.
Our primary purpose of collecting the personal information of children and their parents/guardians is to enable us to provide swimming lessons to children and fulfil our duty of care obligations.
In relation to the personal information of prospective and current staff members and contractors, we the personal information for purposes including:
- to enable us to carry out our recruitment functions;
- correspond with you, provide training and professional development;
- fulfil the terms of any contractual relationship; and
- ensure that you can perform your duties to facilitate the swimming lessons.
If you have any concerns about your personal information being used by Kingswim in any of these ways, you must notify us.
From time to time, and in support of Kingswim’s future development and growth, Kingswim will send direct marketing material if you have consented to receiving such information.
If you do not want to receive any such information, you can contact Kingswim by email on firstname.lastname@example.org
Once we receive a request to “opt out” from receiving marketing information, we will cease sending such information within a reasonable period of time.
How do we store personal information?
Kingswim takes all reasonable steps to protect personal information under its control from misuse, interference and loss and from unauthorised access, modification or disclosure.
We protect personal information in a number of ways including securely storing paper records, using professional software systems, and password restricted access.
Kingswim also has policies in place in relation to archiving, destruction and storage of personal information.
How you can update your personal information?
We are always committed to holding accurate and up-to-date personal information. If you would like Kingswim to update the personal information that it holds about you, you can contact Marketing Manager via email on email@example.com .
How a person can access personal information?
If you wish to access personal information held about you or your child in order to seek correction of such information you may do so by contacting the Customer Contact Centre.
In accordance with the Privacy Act, Kingswim may refuse access to personal information in a number of circumstances including where giving access to the information would pose a serious threat to the life, health or safety of a person, giving access would have an unreasonable impact on the privacy of a person, the information relates to existing or anticipated legal proceedings and would not be available under the discovery process, or denying access is required or authorised by an Australian law or court order.
We will seek to handle all requests for access to personal information as quickly as possible.
Photos and Videos
At Kingswim, we understand that capturing special moments of your child’s swimming lesson on camera or video can be important, however, the privacy of others must be respected.
If you wish to use a camera/video at any Kingswim centre, it is conditional upon the following only:
- If you capture an image of another child or individual, you must have all relevant parental consent to use images.
- You do not broadcast or publish images or video footage without consent.
- If parental consent from others is not provided, photos are to be deleted from all devices.
- If you capture a private conversation of others when using a video camera or mobile phone, please respect the moment and either delete the footage or obtain all relevant individual consent to retain, use or broadcast the footage.
- Under no circumstances are cameras, video cameras or mobile phones to be used in change room areas or showers.
- You agree to comply with any request by Kingswim staff to discontinue use of your camera, mobile phone or video, and to delete the requested images or footage, where Kingswim staff reasonably consider that you are not respecting the privacy of others under this policy.
If you have any questions relating to this policy, or you would like to lodge a complaint you must contact in writing the Customer Contact Centre. We will investigate any complaint and will notify the complainant, in writing, of any decision in relation to the complaint as soon as practicable.
If you are not satisfied with the response you can refer the complaint to the Office of the Australian Information Commissioner.