1. Purpose
This policy sets out how Easy2Swim Swimming Academy captures, uses, and protects photographs and videos of swimmers, families, and visitors in line with the Protection of Personal Information Act (POPIA) and our Safeguarding Policy.
Our aim is to celebrate achievements, promote water safety, and support training — while respecting every person's right to dignity and privacy.
2. Scope
This policy applies to:
- All Easy2Swim staff, instructors, contractors, and volunteers
- All learners and parents/guardians
- Any media (photos, videos, or recordings) taken on Easy2Swim premises or during Easy2Swim activities and events
3. Principles
- The welfare, privacy, and dignity of every child or adult always come first
- Photography and videography are part of our standard service offering for documentation, safety, and promotional purposes
- We respect the right of any participant to opt out of being photographed or filmed
- All processing of images complies with the POPIA principles of fairness, minimality, and purpose limitation
4. Consent Framework
4.1 Default Consent Upon Registration
Opt-In by Default
By registering with Easy2Swim, participants automatically consent to photography and video for:
- Safety and training purposes (stroke analysis, progress documentation)
- Marketing and promotional use (website, brochures, displays)
- Social media (Facebook, Instagram, WhatsApp)
- Certificates and achievement recognition
- Internal training and education
4.2 Opting Out
How to Opt Out
Participants who do not wish to be photographed or filmed must:
- At Registration: Write "No photos" in the comments field during registration
- After Registration: Email info@easy2swim.co.za with "Photography Opt-Out" in the subject line
- Verbally: Inform the instructor at the beginning of each lesson (though written notification is preferred)
Note: Opt-out requests will be honoured within 24 hours and apply to all future photography. Previously captured media may remain in use unless specifically requested for removal.
4.3 Parent-Supplied Photos and Videos
When a parent or guardian sends Easy2Swim any photo or video, that act is considered explicit authorisation for Easy2Swim to use the material in line with the parent's stated or implied intention.
Example: Sending a message like "Please post this on your page!" constitutes permission for public posting.
Example: Sending a clip privately for lesson feedback authorises internal use only.
Parents may revoke permission at any time in writing, and the media will be removed from all Easy2Swim channels within our control.
4.4 Withdrawal of Consent
Consent may be withdrawn at any time by emailing info@easy2swim.co.za. Upon withdrawal:
- No new photos or videos will be taken of the participant
- Existing media will be removed from active use where reasonably possible
- Media already in printed materials or third-party publications cannot be recalled
5. Use of Non-Identifiable Images
Easy2Swim may use images or video footage where individuals cannot reasonably be identified, regardless of opt-out status. This includes:
- Underwater shots showing only limbs or body movement
- Wide-angle or distant group photos
- Silhouettes, blurred faces, or cropped compositions that remove identifying features
Privacy Note
Such images are not considered personal information under POPIA and may be used freely for training, safety promotion, or marketing purposes — provided that:
- No identifying information (such as names, uniforms, or unique accessories) appears
- The context does not make identification possible
If an image or video could reasonably allow identification, it will be treated as personal information and the consent rules in Section 4 will apply.
6. Acceptable Use
For participants who have not opted out, images and videos may be used for:
- Lesson feedback and swimmer progress documentation
- Certificates, newsletters, and internal displays
- Easy2Swim's website and social media pages
- Staff training, recruitment, and educational purposes
- Promotional materials including flyers, banners, and advertisements
- Grant applications and reports to demonstrate our impact
Easy2Swim will never publish names, contact details, or identifying information alongside any image unless specifically authorised.
7. Prohibited Use
Strictly Prohibited
Easy2Swim strictly prohibits:
- Photography or filming in changing rooms, bathrooms, or other private areas
- Photography or filming of other people's children by parents without consent
- Sharing images in ways that could embarrass, distress, or misrepresent an individual
- Using images of participants who have opted out (except non-identifiable images)
- Editing or altering images in a misleading or harmful way
- Selling or transferring images to third parties without explicit consent
8. Storage and Security
- Media files are stored securely on password-protected devices or restricted cloud storage
- Access is limited to authorised staff
- Media is retained only as long as necessary for the approved purpose and then securely deleted
- A register of opt-out requests is maintained and checked before any media use
- Easy2Swim will promptly delete or remove any content if consent is withdrawn
9. Special Events and Competitions
For galas, competitions, and special events, additional photography may occur. Participants who have opted out will be:
- Identified to event photographers where possible
- Seated or positioned to minimise inclusion in group photos
- Excluded from individual achievement photos unless they specifically request inclusion
Note: At public events, Easy2Swim cannot control photography by spectators or other attendees.
10. Complaints and Breaches
Any concern about inappropriate or unauthorised use of images must be reported immediately to the Information Officer (Zandri Stiff). Reports will be handled in line with the Complaints Policy and, where applicable, the Data Breach Response Policy.
Violations of this policy may result in:
- Immediate removal of the offending media
- Disciplinary action for staff members
- Termination of services for participants who violate others' privacy
- Legal action where appropriate
11. Training and Awareness
- Staff receive annual training on consent, privacy, and responsible use of media
- All staff confirm their understanding of this policy before being permitted to capture or share any media
- The opt-out register is reviewed at each staff meeting
- Parents are reminded of this policy at the start of each term
