Privacy Policy

AllWays Able LTD

You Can. Always.

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Policies & Procedures | Website Edition

Updated: 22 October 2026 | Document status: Draft for final operational and legal verification

This document explains how AllWays Able LTD aims to deliver inclusive fitness and music services safely and respectfully. It should be read alongside individual consent and health-
screening forms, booking terms and any relevant organisation-specific safeguarding

arrangements. It is not a substitute for an internal safeguarding procedure, risk assessments or
a complete GDPR privacy notice.

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1. About us and our services
AllWays Able LTD provides inclusive, adapted fitness and interactive music experiences, with

particular experience supporting people with intellectual disabilities. Activities may include in-
person group fitness, individual fitness sessions in Dublin, online individual fitness, pre-
recorded adapted fitness content, and live online music classes. Our focus is enjoyment,

participation, confidence, accessibility and individual choice.
Current regular live online music class: Thursdays, 5:30–6:15 pm (Ireland time). Each week a
new Zoom link is issued; eligible members receive an updated link via Wednesday email. We
do not currently advertise a regular Monday online fitness/dance class as an established
service.
Current published offers may include: individual music membership (€55/month), combined
fitness and music membership (€90/month), residential-house music membership (€85/month
per house for two or more participants), and music-class pay-as-you-go (€15/class). Each
separate residential house needs its own plan. In-person 1-to-1 fitness is generally €65 for 45
minutes; online 1-to-1 is €50. Group fitness quotations are agreed separately. Prices and
inclusions displayed at checkout or in an agreed written quotation take precedence if updated.

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2. Inclusion, dignity and choice
We welcome participants of differing abilities and support needs. We seek to make reasonable,
practical adaptations to communication, movement, pacing and participation. Participants can
take breaks, decline an activity or stop at any time. We do not guarantee that every activity is
suitable for every individual; an alternative or additional support may be needed following
assessment.

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3. Registration, consent and capacity
Before physical activity, we request appropriate registration, health screening (such as PAR-Q
or equivalent), emergency contact details and informed consent. Where a participant needs
help to understand information or make decisions, we communicate accessibly and involve
appropriate supporters in accordance with the person’s rights and applicable law. A family

AllWays Able LTD • Policies & Procedures • 22 October 2026

member or staff member does not automatically have legal authority to consent for another
adult. Consent for participation, photography/publicity and marketing are separate decisions
and may be withdrawn where applicable.

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4. Safeguarding children and adults at risk
We do not tolerate abuse, neglect, exploitation, bullying or inappropriate conduct. Any
disclosure or concern must be listened to calmly, recorded factually, shared only with those
who need to know, and escalated promptly using the applicable safeguarding pathway. Never
promise absolute secrecy. If someone is in immediate danger, call 112 or 999. Concerns
involving a child may require reporting to Tusla and/or An Garda Síochána; adult safeguarding
concerns may require contacting relevant HSE safeguarding services and/or Gardaí. Staff must
follow the host organisation’s reporting arrangements where relevant without allowing those
arrangements to delay urgent protection.
Before publication, AllWays Able must identify its named safeguarding lead,
deputies/escalation contacts, and whether a Child Safeguarding Statement and associated risk
assessment are legally required for its specific services. The operational safeguarding policy
should include allegations against staff, incident recording, confidentiality and referral
pathways.

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5. Garda vetting and safer recruitment
Garda vetting is obtained through the National Vetting Bureau process where legally required
for relevant work involving children or vulnerable persons, via an authorised relevant
organisation. Vetting is one safeguarding measure, not proof that a person poses no risk. We
also use role-appropriate recruitment checks, references, induction, training, supervision and
conduct expectations. Staff or volunteers must not begin duties requiring vetting before the
relevant vetting requirements have been satisfied. We will provide organisations with
appropriate confirmation of vetting status where lawful and relevant, without disclosing
confidential vetting details.
Important: this document does not certify that either founder or any assistant has completed
Garda vetting; individual status must be verified against current records before making that
claim.

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6. Professional boundaries and conduct
Danny is a qualified group fitness instructor; Shoba supports activities in an assistant capacity.
We will accurately describe each person’s qualifications and scope of practice. We maintain
respectful communication, appropriate professional boundaries and no discriminatory,
abusive or sexualised conduct. We do not provide clinical treatment, physiotherapy, dietetic
advice or specialist healthcare services. Support staff from a residential house or day service
retain their own care responsibilities unless expressly agreed otherwise.

AllWays Able LTD • Policies & Procedures • 22 October 2026

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7. Health, safety and risk management
We assess activity, venue, equipment and participant-related risks proportionately before
sessions and revisit them when circumstances change. Exercises are adapted to individual
abilities; safe technique, appropriate rest, hydration and accessible movement options are
encouraged. Participants should disclose relevant information that may affect safe
participation, including mobility or balance needs, seizure management, medication-related
effects and emergency plans, only to the extent necessary. Participants must stop and alert the
instructor if they experience pain, dizziness, unusual breathlessness or distress.
For in-person sessions we confirm suitable space, equipment, accessibility, emergency exits,
first-aid arrangements and an agreed emergency response. For online sessions, the participant
or responsible support person must ensure a safe space and appropriate on-site supervision
where required. Remote instructors cannot physically intervene in an emergency.

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8. Emergencies, incidents and first aid
For an emergency call 112 or 999, give the location, follow dispatcher instructions and contact
the designated emergency contact when appropriate. Staff should act within their training and
record incidents and near misses promptly, factually and securely. Relevant accidents may
need reporting under applicable Irish health and safety law. Medical emergency plans,
including seizure action plans where applicable, should be agreed before participation when
needed. A person requiring continuous supervision must not be left unsupported during a
session.

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9. Online Zoom classes and digital safety
Zoom access is intended for the registered participant or purchasing residential house; links
should not be posted publicly or forwarded beyond the authorised group. We may use waiting
rooms, meeting controls and changing weekly links. Participants and supporters should use
respectful names and behaviour, avoid disclosing private information about others, and follow
facilitator instructions. Unauthorised recording, screenshots or redistribution of classes is not
permitted. Participants may keep their camera off if appropriate, subject to any safety or
support arrangements agreed for an activity.
Live music classes are interactive entertainment and community activities, not personal care
or clinical supervision. A parent, guardian or designated support worker should be present or
readily available when the individual’s needs require it. Technical problems should be
reported promptly; alternative access or a remedy will be considered fairly where the service
cannot be delivered.

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10. Photography, video and social media
We will seek specific, informed permission before using identifiable images, voices, names or
testimonials in advertising or social media. Refusing permission will not prevent someone
from participating. Consent can be withdrawn for future use, although material already
lawfully distributed may not be fully retrievable. Organisational permission alone does not

AllWays Able LTD • Policies & Procedures • 22 October 2026

automatically replace an individual’s consent or other lawful basis. We will avoid identifying
sensitive health or disability information without an appropriate legal basis and safeguards.

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11. Privacy, confidentiality and data protection
We collect only information reasonably needed to manage enquiries, bookings, payments,
membership access, accessibility and safe participation. Some information, such as health
details, is sensitive and requires additional safeguards and a valid lawful basis under GDPR.
We use appropriate access controls and secure storage, restrict access on a need-to-know basis
and retain records only as long as justified by the relevant purpose and legal obligations.
We may use service providers for our website, payments, email and online classes (including
Wix and Zoom). Information may be shared when necessary to provide the service, comply
with law, protect safety or with valid permission; it is inaccurate to promise that data is never
shared. Individuals have GDPR rights, subject to legal conditions, including access, correction,
erasure, objection and complaint to the Irish Data Protection Commission. For privacy requests
email contact@allwaysableltd.com. A separate detailed website privacy notice must specify
data-controller identity, legal bases, processors, retention periods, international transfers and
cookie practices.

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12. Memberships, billing and cancellation
Monthly memberships renew automatically according to the billing terms shown at purchase
until cancelled. Customers can request cancellation at any time; cancellation normally stops
future renewals rather than reversing charges already incurred. Each residential-house
membership applies to one house, not multiple separate houses. A first live music class may be
offered free to new participants by arrangement. Pay-as-you-go sessions are purchased
separately.
We do not ordinarily refund a class simply because a participant chooses not to attend, but this
does not affect statutory consumer rights or any applicable cooling-off rights. For cancelled or
materially undelivered services, we will provide the remedy required by law and the agreed
terms. Where scheduled music classes are not delivered over a holiday period, we will
communicate arrangements and make appropriate adjustments or refunds; any December
2026 partial refunds will be calculated with regard to the member’s actual billing period and
affected sessions. No policy here excludes rights under Irish consumer law.

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13. Booking changes, lateness and service disruption
Individual and group booking times, cancellations and any charges should be agreed in writing
before booking. We aim to provide advance notice when rescheduling is necessary and offer a
suitable alternative or applicable refund. We may pause or end a session where there is an
immediate safety or safeguarding concern. For events outside our reasonable control, we will
communicate promptly and apply relevant consumer rights.

AllWays Able LTD • Policies & Procedures • 22 October 2026

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14. Insurance
AllWays Able has arranged an insurance policy and can provide its current certificate of
insurance to organisations on request. Insurance applies only subject to the exact named
insured, insured activities, policy dates, exclusions, limits and conditions in the issued policy
documents. We will not imply that every online or in-person activity, assistant, venue or
participant circumstance is covered without checking the wording or written insurer
confirmation. Organisations should request the current certificate and relevant written
clarification where needed.

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15. Complaints, feedback and communication
We welcome feedback and take complaints seriously. Please contact
contact@allwaysableltd.com with the issue, relevant date and preferred contact details. We
aim to acknowledge non-urgent concerns within two working days, investigate fairly and
communicate an outcome or update as soon as reasonably possible. Safeguarding concerns and
emergencies are escalated immediately rather than handled as ordinary complaints. No one
should be disadvantaged for raising a concern in good faith.

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16. Responsibilities of families, carers and organisations
Please provide accurate information relevant to safe participation, notify us of meaningful
changes, make agreed support or supervision available, ensure the participant has appropriate
space and equipment, and respect others’ privacy. Residential services and day services remain
responsible for their own staffing, care plans, medication, emergency arrangements and
regulatory obligations unless a specific written agreement states otherwise.

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17. Policy review and contact
We review this pack at least annually and sooner following a material service, legal,
safeguarding or insurance change. The latest version should be made available on our website.
This public summary does not replace operational procedures, signed agreements, insurer
documents or statutory duties.

AllWays Able LTD | You Can. Always.

Email: contact@allwaysableltd.com | Website: https://allwaysableltd.com
Instagram and Facebook: @allwaysableltd

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Publication checklist — internal, remove before website upload
 Confirm named safeguarding lead, referral pathways and Child Safeguarding Statement
applicability.
 Verify Garda vetting status for each relevant worker and retain evidence securely.
 Check current insurance schedule, exact activities, named insured and assistant cover
against insurer confirmation.
 Approve written session cancellation terms and website checkout disclosures, including
consumer withdrawal rights.
 Publish a separate detailed GDPR privacy and cookies notice, plus media consent process.

AllWays Able LTD • Policies & Procedures • 22 October 2026

 Confirm emergency, incident-reporting, recruitment and risk-assessment procedures are
actually in use.
 Verify all prices, links, class schedules and complaint-response commitments before
publication.