DATA PRIVACY NOTICE


Stage Art Dance (SA DANCE) GDPR PRIVACY NOTICE

The General Data Protection Regulation (GDPR) comes into effect on 25 th May 2018.

This notice will provide information on how we, Stage Art Dance (SA DANCE) are complying with this Regulation.

Stage Art Dance (SA DANCE) is comitted to ensuring the data processed by our school remains safe and secure.

The main aims for this policy is to specify the data Stage Art Dance (SA DANCE) collects, how it is stored/protected and the reason for collecting it, state how the personal data is used in processing, to disclose who has access to the data and how long we retain information for, and to explain data subeject's rights.


Introduction

The General Data Protection Regulation (GDPR) ensures a balance between an individual's rights to privacy and the lawful processing of personal data undertaken by organisations to protect the rights of individuals about whom data is obtained, stored, processed or supplied and requires that organisations take appropriate security measures against unauthorised access, alteration, disclosure or destruction of personal data.


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. 



The sections towards the end of this Privacy Notice let you know how you can exercise your rights.
You can read more about your rights at  https://ico.org.uk/for-the-public/ .

 


Information Stage Art Dance (SA DANCE) processes


The following sections describe the information that Stage Art Dance (SA DANCE) collects and how it is processed. The sections are split according to the type of information.

Legal basis for processing

The legislation requires that there is a clear legal basis for processing personal information. In general Stage Art Dance (SA DANCE) relies on the individual's consent in order to process their data. Where there are exceptions such as a legal obligation, contractual agreement or Stage Art Dance (SA DANCE) legitimate interest, they will be noted below.

Please note that if consent is withdrawn the level of service that we can offer might be severely curtailed.

Students/Members

We do process members data for the best practice of the Health & Safety and Child Safeguarding policies. Students/members must remain safe at all times, therefore information must be collected in order to create registers, student records and to provide students with appropriate classes according to age groups.
Special category data is only collected with the consent of the data subject. Special category data we collect includes but is not limited to: Medical/Disability information and Gender. As physical activity providers it is crucial that this consent is given should a participant have any medical/disability needs as it will allow us to incorporate participants safely into classes.

How We Obtain Personal Data

Information provided by student/member or parent/ guardian:

You may be providing us with personal data in the following ways:

-                  By completing the form on the website to enrol in our classes

-                 By signing the terms of engagement on the questionnaire

-               Through email or over the telephone

-                  By using a credit card for online payments

What data is collected

Participant/Student/Member Personal Data

Full Name - GDPR Article 6(1)(f)
Date of Birth - GDPR Article 6(1)(f)
Home Address - GDPR Article 6(1)(f)
Sex - GDPR Article 6(1)(f)
Permission to go home alone - GDPR Article 6(1)(f)
School/Educational Institution - GDPR Article 6(1)(f)
Exam results (vocational dance exams) - GDPR Article 6(1)(f)
Classes attended/Price paid - GDPR Article 6(1)(f)

Participant/Student/Member Special Category Data:

Medical Information/History : GDPR Article 9 (a)
Disability Information - GDPR Article 9 (a)
Gender/Sex : GDPR Article 9 (a & j) further explicate consent sought

Parent/Guardian Personal Data

Name - GDPR Article 6(1)(f)
Address - GDPR Article 6(1)(f)
Email Address - GDPR Article 6(1)(f)
Mobile Telephone Number - GDPR Article 6(1)(f)
Work/Home Number - GDPR Article 6(1)(f)
Emergency Contact Number - GDPR Article 6(1)(f)

Parent/Guardian Special Category Data

Bank Details : further explicate consent sought in the instance of refunds etc.

To attend in Stage Art Dance (SA Dance) classes, participants/members/parents/guardians must agree to some processing of their personal data. This is due to Legitimate Interests : GDPR Article 6(1)(f), Legal Obligation GDPR Article 6(1)(c), Contract - Article 6(1)(b) and/or Consent - Article 6(1)(a).

This means that the legal basis of our holding your personal data is for a legitimate interest.

What is done with the data collected

Enrolment forms are done through an encrypted server directly from our website which has controlled access. Received enrolment forms are stored on an encrypted server.

Storage/Retention of data

Data received through enrolment forms is stored in our database, access is restricted though password protection and only available to designated authorised staff members.

Registers and emergency contact lists are stored in encrypted files on office-based hardware and backed up regularly in our encrypted cloud-based server. Access to these files is restricted through password protection and only available to designated authorised staff members.

Once a student/member lapses, we retain sufficient information to identify the previous member. This allows the previous membership to be used again if the member re-joins. Stage Art Dance (SA DANCE) relies on legitimate interest as the legal basis for retaining this information.

Information on how long we store the data: financial records are kept for 6 years due to legal obligation, first Aid records are kept for 21 years due to legal obligation, Child Safeguarding records are kept indefinitely on a case-by-case basis (the minimum these will stored for is 6 years due to legal obligation) and bank details are deleted after the action concerning them is complete.

E-news items

With consent we email items of news that we believe will be of interest to our studnets/members.

We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-news items.

Email addresses

If an email address is provided we assume consent to use it for administrative purposes of membership (e.g. notification of membership renewal, notification of class and performances information, etc.).

We will not use it to send you e-news and marketing items without your explicit consent.

Website visitors

When someone visits www.sa-dance.co.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone.

Use of cookies

You can read more about how we use cookies below on Website Technical details.

Forms

There are various forms on the website used to collect information. That information is only used for the stated purposes which are described in the relevant sections of this Privacy Notice.

Payments

PayPal/Braintree is used to take payments. Only sufficient information to complete the payment is shared with PayPal. For more information see the Suppliers / 3rd Parties section of this Privacy Notice.

Third Parties/Data Processors

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. There may be others from time to time.

Teachers

Stage Art Dance (SA DANCE ) has confidentiality and data processor agreements in place. Teachers are provided with class registers containing students/members names, emergency contact numbers and any medical information that is pertinent to the running of a class(subject to consent from the data subject).

MailChimp

Stage Art Dance (SA DANCE) sends newsletters and marketing emails via a USA based company called MailChimp. It is an optional process, during enrolment people are asked to consent in allowing their email address to be used for these purposes. Data Subjects can opt-out and erase/rectify their record stored with MailChimp at any time.

Stage Art Dance (SA DANCE) is satisfied that MailChimp GDPR regulations are thorough, and the email addresses stored is secured. A processor contract is in place, and copies are available upon request.

Child Performance Licensing

To process Child Performance licenses or chaperone licenses, Stage Art Dance (SA DANCE) is legally required to provide some information to local council and this will be done with consent from the student/member/parent/guardian.

Child Safeguarding Concerns

Stage Art Dance (SA DANCE) is legally required to provide data to the safeguarding board at the local council if requested and we are satisfied that their GDPR process is thorough and if any data is stored it will be in a secure environment.

Event Programmes

Show programmes are printed and will contain the student/member name. Student/Member/ Parent/guardian will be asked for consent for this.

Examinations

At Stage Art Dance (SA DANCE) we provide the option of participating in dance exams with IDTA (International Dance Teachers Association), NATD (National Dance Teachers Association) and/or RAD (Royal Academy of Dance). Some personal data will be shared with these examination boards and parent/guardian will have to consent upon student/member being entered for the exam.

Website hosting

We use a third party service, Digitalocean Ltd to host our website. Digitalocean are contractually obliged to treat any information on our private website as confidential and only use such information for the purpose of providing Stage Art Dance (SA DANCE) with web hosting.

CRB/DBS service

A DBS checking service for Stage Art Dance (SA DANCE) volunteer helpers is provided by Due Diligence Checking Ltd. Information provided by them to SA DANCE will only be shared with the individual concerned. The records are kept for 3 years and then deleted.

PayPal

Where PayPal/Braintree is used to take payments, only sufficient information to complete the purchase is shared with PayPal/Braintree. Stage Art Dance (SA DANCE) does not see nor retain your credit card details since these are handled by PayPal/Braintree.

International Data Transfers

Your personal information will be stored in the EU and in accordance with the GDPR. The GDPR applies to EU residents. If we share personal information of EU residents with suppliers or 3rdparties outside of the EU we will ensure that they meet the requirements of the GDPR. We are committed to complying with the data regulations of non-EU residents according to their jurisdiction.

Security

Stage Art Dance (SA DANCE) has implemented technical and organisational security measures to protect your personal data against unauthorized access, loss or misuse.

Photos/Videos of Students/Members

Stage Art Dance (SA DANCE) may use footage/photos used from classes, exam days, performances, workshops, events and shows for marketing purposes both in print media, website, social media (Instagram, Facebook, Twitter, Email). Any identifying information (age and full names) will not be shared. Practice videos are regularly used for our online dance practice groups and it is a very important tool to help the students progress in class.
Participants/their Parent and/or Guardians may choose if they do not wish themselves/their child to be depicted. Upon application parents are asked to opt in or opt out of photographic consent for their child. Some attendees at events may film/take photos for their own personal use (e.g. parents of other participants).

Website technical details

Forms

We do use electronic forms on our website making use of an available forms module which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate. Data received through these enrolment forms is stored in our database, access is restricted though password protection and only available to designated authorised staff members.

Cookies

In compliance with EU legislation, the following table lists the use of cookies on this web site:

Cookie name

Purpose

Accept Cookies

This is used to store whether you have agreed to receive cookies. Persistent for one year.

Google Analytics

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.


Cookies are small. We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website which in no way collects or discloses any personal information about you as a visitor.

Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below as analytics software also uses cookies to function.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

Analytics

Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

Complaints or queries


Stage Art Dance (SA DANCE) strives to meet the highest standards when collecting and using personal information. Please contact us by writing to the Data Controller at info@sa-dance.co.uk if for any reason you think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

Confidentiality will be preserved during the investigation of a complaint to safeguard the interests of everyone concerned unless disclosure is necessary to progress the complaint. If you feel that your complaint was not handled in the correct manner, or still have concerns, you may contact the Independent Commissioners Office (ICO). ICO Telephone Number: 0303 123 1113

This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the school via our email info@sa-dance.co.uk.

Access to personal information


Stage Art Dance (SA DANCE) tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by asking. This is formally known as a subject access request under the Data Protection Act 1998. If we do hold information about you we will:

give you a description of it.

  • tell you why we are holding it.
  • tell you who it could be disclosed to.
  • let you have a copy of the information in an intelligible form.
    To make a request to Stage Art Dance (SA DANCE) for any personal information we may hold you need to put the request in writing to info@sa-dance.co.uk

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

If we do hold information about you, you can ask us to correct any mistakes.

Disclosure of personal information


Except as described in this Privacy Notice we will not disclose personal data without consent.

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.

Privacy Notice Review

We keep our Privacy Notice under regular review.
This Privacy Notice was last reviewed in May 2018.

Contact us

Please do not hesitate in contact us at info@sa-dance.co.uk if you have any question, concern, advice or complaint.

Aretha Marques
SA Dance Director

Rafael Narezzi
SA Dance IT Director