GDPR & PRIVACY
Policy issue date ; 23rd May 2018
The Starlets school of performing arts 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
Kept for no longer than is absolutely necessary
Kept safe and secure
Not transferred outside the European economic area without adequate protection
The legislation conveys various individual rights. These include the following:
The right to be informed
The right of access
The right to rectify
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 THE STARLETS SCHOOL OF PERFORMING ARTS HAVE ABOUT ME?
The legislation requires that there is a clear legal basis for processing personal information. In general The Starlets school of performing arts relies on the individual’s consent in order to process their data.
When you participate in or sign up to any Starlets 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, we will ask for parental permission. We 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.
The Starlets school of performing arts will NOT share your personal information with third parties, unless clearly stated. For example, when competing in Exams, competitions or dance shows with reputable comps is, such as Mardi Gras, Chance2dance etc... The information we share will only be transferred electronically. We will NOT sell your data, and neither do we buy data from third parties.
Securely recorded performances of individual, duo, trio and troupe performances are also stored, when required, for audition purposes on a password protected device.
These will be reviewed on a yearly basis and deleted if no longer required.
Invoice books are kept securely, these contain the child’s name, details of classes they have attended and the amount owed, these are completed by Kathy Langham.
It is also necessary to provide individuals with time tables for competitions and exam programmes, because of this your child’s details (names and ages) will be shared to the organisers and will be seen by other competitors.
WHAT ARE COOKIES AND HOW DO YOU USE THEM?
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.
HOW WILL YOU USE MY PERSONAL INFORMATION?
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.
When sending letters, parcels, publications and purchases we will share your postal address with the delivery service (Normally Royal Mail or Parcel Force).
We use a third party service, Wix, to host our website. Wix are contractually obliged to treat any information on our private website as confidential and only use such information for the purpose of providing The Starlets school of performing arts with web hosting.
A DBS checking service for The Starlets school of performing arts teachers and chaperones is provided by Leicestershire County Council or Leicester City Council . Information provided by them to us and vice versa will only be shared with the individual concerned. The records are kept for 3 years and then deleted.
In the event of your child needing either a performance licence to perform in ANY Starlets school of performing arts performance, including dance shows, pantomimes and dance performances produced by a third party ALL documentation will be stored securely. As required by the child performance licence application guidelines, it is necessary to share individual details with the child’s school and the relevant councils issuing the licence.
PERFORMANCE REGULATION PROCEDURES
It is also required for The Starlets school of performing arts to share individual performers details with Head Chaperones at any performance that your child may be in attendance. Thus is a legal requirement, under current Safeguarding guidelines. A signing in sheet is also required at every performance, that has to be completed and retained at the performance by the named Head chaperone.
SUPPLIERS / 3RD PARTIES
To send you information you requested when you voluntarily signed up to our website
For costume providers, it will be necessary to share your child’s name and dress size measurements. These will be destroyed as soon as your child receives their costumes.
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 WILL WE KEEP PERSONAL INFORMATION?
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 THE STARLETS SCHOOL OF PERFORMING ARTS HOLDS ABOUT ME?
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.
THE STARLETS SCHOOL OF PERFORMING ARTS GDPR POLICY
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.
The Starlets school of performing arts 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.
GENERAL DATA PROTECTION REGULATION POLICY STATEMENT
1) THE RIGHT TO BE INFORMED
The Starlets school of performing arts 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 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, The Starlets school of performing arts 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. This1 information is also required for Disclosure and Barring Service checks (DBS) and proof and eligibility to work in the UK. This information is sent via a secure file transfer system to the relevant companies for the processing of DBS checks. DBS Numbers and date of issue are also held on a central staffing record. Copies of teachers DBS are shared with the respective schools in which the teachers work in for Safeguarding purposes.
2) THE RIGHT OF ACCESS
At any point an individual can make a request relating to their data and we will need to provide a response (within 1 month). We 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 The Starlets school of performing arts has a legal duty to keep children’s and parents details for a reasonable time, we will retain these records for 3 years after leaving the dance school, children's accident and injury records for 3 years.
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 The Starlets school of performing arts 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
If The Starlets school of performing arts requires data to be transferred from one IT system to another; such as from us to the Local Authority, for performance 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. The Starlets school of performing arts 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 Kerry's personal residence.
For each class your child attends, their registration sheet will be taken by Mrs Kerry Daisley or a designated member of the Starlets team, to their class, this is to ensure we have emergency contact details and any relevant medical information with your child at all times. Weekly attendance registers will also be kept in class and completed by Teresa Austin or Kathy Langham, my appointed representatives on the daily running of classes and returned to the same locked filing cabinet.
Members of staff can have access to these files but information taken from the files about individual children is confidential. 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 after the relevant retention period.
The Starlets school of performing arts 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 file and stored appropriately.
The Starlets school of performing arts 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.
Access to all of The Starlets school of performing arts computers are password protected. When a teacher leaves the company these passwords are changed in line with this policy and our Safeguarding policy. Any portable data storage used to store personal data, e.g. USB memory stick, are password protected and/or stored in a locked filing cabinet.
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 by the principal of The Starlets school of performing arts, Mrs Kerry Daisley in April 2018 and is signed on behalf of The Starlets school of performing arts
Mrs Kerry Daisley - 2019