Crescents Privacy Policy and GDPR Compliance


Jan 23, 2020 06:24 PM



CRESCENTS BALLET SCHOOL PRIVACY POLICY

INTRODUCTION
Crescents Ballet School is committed to protecting you and your dependents’ personal information. We are committed to providing a safe environment for all our customers, employees, casual and freelance workers and everybody who comes into contact with us, both physically and virtually (online). This Privacy Statement relates to the use of any personal information provided to us online or via application forms, telephone, email exchange, letters or correspondence.
Whenever you provide such information, we are legally obliged to use your information in line with current legislation concerning the protection of personal information, including the Data Protection Act 1998 and the General Data Protection Regulations.

DATA PROTECTION PRINCIPLES
The legislation sets out various data protection principles. These include that personal information is:
« Used fairly and lawfully
« Used for limited, specifically stated purposes
« Used in a way that is adequate, relevant and not excessive
« Accurate
« Kept for no longer than is absolutely necessary
« Kept safe and secure
« Not transferred outside the European economic area without adequate protection

YOUR RIGHTS
The legislation conveys various individual rights. These include the following:
« The right to be informed
« The right of access
« The right to rectification
« The right to erase
« The right to restrict processing
« The right to data portability
« The right to object
« Rights in relation to automated decision making and profiling


WHAT INFORMATION DOES CRESCENTS BALLET SCHOOL HAVE ABOUT ME?
The legislation requires that there is a clear legal basis for processing personal information. In general Crescents Ballet School relies on the individual’s consent in order to process their data.
When you participate in or sign up to any Crescents Ballet School class, activity or workshop, we may collect and store personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number and date of birth, depending on how you are engaging with us. By submitting your details, you enable us to provide you with the products or services that you have selected.
When taking pictures of students in class or filming performances, Crescents Ballet School ask for parental permission. Crescents Ballet School may use the images resulting from the photography/video filming, and any reproductions or adaptations of the images for fundraising, publicity or other purposes to help achieve the group’s aims. This might include (but is not limited to), the right to use them in their printed and online publicity, social media, press releases and funding applications.
Crescents Ballet School does NOT share your personal information with third parties, unless clearly stated. We do NOT sell your data, and neither do we buy data from third parties.

HOW WILL YOU USE MY PERSONAL INFORMATION?
We will use your personal information for a number of purposes including:
« To provide you with information about our products, services and activities and to deal with your requests and enquiries, including complaints
« For "service administration purposes", which means that we may contact you for reasons related to the service or activity you signed up for (e.g., change of details regarding a class you attend, etc.)
« To contact you about an application you have made
« To process your application for employment and where applicable your employment once appointed
« As and when we need to use your personal information for reasons other than the ones specified above, we will ensure that we notify you first. You will be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.

USE OF DATA PROCESSORS
Data processors are third parties who provide services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. The following is a list of our main data processors.
« POSTING
When sending letters, parcels, publications and purchases we will share your postal address with the delivery service (Normally Royal Mail or Parcel Force).
« WEBSITE HOSTING
We use a third party service, One.com to host our website. One.com are contractually obliged to treat any information on our private website as confidential and only use such information for the purpose of providing Crescents Ballet School with web hosting.
« CRB/DBS SERVICE
A DBS checking service for Crescents Ballet School teachers and chaperones is provided by Worcestershire County Council. Information provided by them to Crescents Ballet School will only be shared with the individual concerned. The records are kept for 3 years and then deleted.
« REGISTERS, INVOICING AND DATABASE
We use a third party service, Dance Studio Pro software to store your information and use it for administrative purposes such as timetables, registers, emailing and invoicing customers.
« SUPPLIERS / 3RD PARTIES
To send you relevant communications for payment of fees and changes to classes

CRESCENTS BALLET SCHOOL MAY CONTACT YOU
« In relation to any service or activity you have signed up for in order to ensure that we can deliver the services to you
« In relation to any correspondence we receive from you or any comment or complaint you make about our products or services
« To send you information you requested when you voluntarily contacted us via our website

YOUNG USERS
If you are under 18 and you provide us with information on an application form (online or printed), your parent(s)/guardian(s) permission will be required.

HOW LONG WILL WE KEEP PERSONAL INFORMATION?
We keep the information we hold about our customers and students for as long as is necessary to deliver the services we are providing you with.

WHERE IS THE INFORMATION STORED?
We use secure technologies to help protect your personal information from unauthorised access, use or disclosure. We store personal information you provide on computer systems which have carefully controlled access and which are located in secure facilities.
The security measures described above ensure that all reasonable steps are taken to protect your personal information. However, the nature of the Internet means that an absolute guarantee of security cannot be offered, and, as with all Internet transactions, you should be aware that there may be a small security risk when disclosing information online.

CAN I FIND OUT WHAT PERSONAL INFORMATION CRESCENTS BALLET SCHOOL HOLDS ABOUT ME?
You have the right to access certain personal information held about you. If you wish to make a Data Subject Access Request, please contact

LEGAL OBLIGATION
We may disclose your information to governmental agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request.



CRESCENTS BALLET SCHOOL GDPR POLICY

GENERAL DATA PROTECTION REGULATION POLICY STATEMENT
GDPR stands for General Data Protection Regulation and replaces the previous Data Protection Directives that were in place. It was approved by the EU Parliament in 2016 and comes into effect on 25th May 2018.
GDPR states that personal data should be ‘processed fairly & lawfully’ and ‘collected for specified, explicit and legitimate purposes’ and that individuals data is not processed without their knowledge and are only processed with their ‘explicit’ consent. GDPR covers personal data relating to individuals.
Crescents Ballet School is committed to protecting the rights and freedoms of individuals with respect to the processing of children's, parents, visitors and staff personal data.
The Data Protection Act gives individuals the right to know what information is held about them. It provides a framework to ensure that personal information is handled properly.

GDPR INCLUDES 7 RIGHTS FOR INDIVIDUALS
1. THE RIGHT TO BE INFORMED
Crescents Ballet School is required to collect and manage certain data. We need to know parent’s names, addresses, telephone numbers, email addresses. We need to know children’s’ full names, addresses, date of birth along with any SEN or medical requirements.
We are required to collect certain details of visitors and chaperones to our dance school. We need to know visitors and chaperones names, telephone numbers, and where appropriate company name. This is in respect of our Health and Safety and Safeguarding Policies.
Although our teachers are freelance, Crescents Ballet School is required to hold data on its teachers; names, addresses, email addresses, telephone numbers, date of birth, National Insurance numbers and in some cases, photographic ID such as passport and driver’s license, bank details. This information is also required for Disclosure and Barring Service checks (DBS) and proof of eligibility to work in the UK.
2. THE RIGHT OF ACCESS
At any point an individual can make a request relating to their data and Crescents Ballet School will need to provide a response (within 1 month). Crescents Ballet School can refuse a request, if we have a lawful obligation to retain data but we will inform the individual of the reasons for the rejection. The individual will have the right to complain to the ICO if they are not happy with the decision.
3. THE RIGHT TO ERASURE
You have the right to request the deletion of your data where there is no compelling reason for its continued use. However Crescents Ballet School has a legal duty to keep children’s and parents details for a reasonable time, Crescents Ballet School retain these records for 3 years after leaving the dance school, children's accident and injury records for 19 years (or until the child reaches 21 years), and 22 years (or until the child reaches 24 years) for Child Protection records.
Teachers' records must be kept for 6 years after the member of leaves, before they can be erased.
This data is archived securely onsite and shredded after the legal retention period.
4. THE RIGHT TO RESTRICT PROCESSING
Parents, visitors and staff can object to Crescents Ballet School processing their data. This means that records can be stored but must not be used in any way, for example reports or for communications.
5. THE RIGHT TO DATA PORTABILITY
Crescents Ballet School requires data to be transferred from one IT system to another; such as from Crescents Ballet School to the Local Authority, for performance BOPA licences. These recipients use secure file transfer systems and have their own policies and procedures in place in relation to GDPR.
6. THE RIGHT TO OBJECT
Parents, visitors and staff can object to their data being used for certain activities like marketing or research.
7. THE RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION-MAKING INCLUDING PROFILING
Automated decisions and profiling are used for marketing based organisations. Crescents Ballet School does not use personal data for such purposes.

STORAGE AND USE OF PERSONAL INFORMATION
All paper copies of children's and staff records are kept in a locked filing cabinet at Unit G1 Sherriff Street. These records are shredded after the retention period.
Information about individual children is used in certain documents, such as, a weekly register, medication forms, referrals to external agencies and disclosure forms. These documents include data such as children's names, date of birth, contact numbers and sometimes address. These records are shredded or deleted after the relevant retention period.
Crescents Ballet School collects a large amount of personal data every year including; names and addresses of those on the waiting list. These records are shredded if the child does not attend or added to the child’s digital file and stored appropriately.
Crescents Ballet School stores personal data held visually in photographs or video clips or as sound recordings, and written consent has been obtained via the photo and video consent form/permission to Perform agreement form. No full names are stored with images in photo albums, displays, on the website or on Crescents Ballet School's social media sites.
Access to all Crescents Ballet School computers and the Dance Studio Pro database for registers is password protected. Any portable data storage used to store personal data, e.g. USB memory cards, are password protected and/or stored in a locked filing cabinet.

GDPR MEANS THAT CRESCENTS BALLET SCHOOL MUST
« Manage and process personal data properly
« Protect the individual’s rights to privacy
« Provide an individual with access to all personal information held on them
This Policy was adapted at a meeting with Crescents Ballet School in April 2018 and is signed on behalf of Crescents Ballet School:
Jane Chance, Principal of Crescents Ballet School