Privacy Policy

Date Adopted: 27th Sept 2023 To be reviewed next on: 27th Sept 2024

2008 (DPA) Updated 2018 (GDPR)

Purpose and Statement:

iSDA Theatre School is committed to ensuring the data processed by our school remains safe and secure.

This policy has been written in line with legislative change, including both the Data Protection Act (1998) and the EU’s General Data Protection Regulation (GDPR).

iSDA Theatre School has determined the lawful reasons with which it processes personal data:

• Legal obligation – GDPR Article 6(1)(c)

• Legitimate interest – GDPR Article 6(1)(f)

• Contract - GDPR Article 6(1)(b)

There is also some limited data we process with consent from the Data Subject; Consent – GDPR Article 6(1)(a).

While iSDA Theatre School avoids sharing data with third parties at most times, some data is shared in accordance with our business practices. The sharing of data with third parties will always be

consensual with the data subject and/or their parent/guardian, and only if iSDA Theatre School is satisfied that their Data Protection policy is GDPR compliant.

Main Aims for the policy:

- Specify the data iSDA Theatre School collect, how it is stored/protected and the reason for collecting it - State how iSDA Theatre School use personal data in processing

- Disclose who has access to the data and how long we retain information for

- Explain Data Subject’s rights with iSDA Theatre School data including access, rectification and erasure

Distribution:

- To be distributed to all stakeholders involved with the school on induction.

- To be displayed on the iSDA Theatre School website

- This policy will be sent directly to members of the public on request

- Confirmation of receipt of information - Signed statement from recipient to be held on file

Review and monitoring of policy:

- Reviewed annually or in instances of legislative change

- Monitoring is part of Management and Supervision

The following policy is based on the below principles:

The GDPR includes the following rights for individuals:

- the right to be informed

- the right of access

- the right to rectification

- the right to erasure

- the right to restrict processing

- the right to data portability

- the right to object

- the right not to be subject to automated decision-making including profiling

General Principles

iSDA Theatre School is committed to providing fair and understandable privacy policies in relation to personal data.

iSDA Theatre School will, at all times, keep data in secure locations (including, but not limited to, encrypted and access restricted files) and not retain data unnecessarily or past the retention length as set out in this policy.

In the rare instance a data processor that is not a iSDA Theatre School employee is used, such as a third party, the data subject will either be asked for consent pre to supplying the data or be notified and have the right to object to processing.

Participants and Customers

How iSDA Theatre School collect personal data:

iSDA Theatre School customers and participants supply their personal data when signing up for classes through our online registration form via Class Manager. Occasionally we may use paper forms and disclaimers. This is either completed by a parent/guardian or the student themselves if they are deemed able to do so.

Personal data may also come to us unsolicited via enquiries through our website and to our generic email account.

Why iSDA Theatre School collect personal data:

To attend any of iSDA Theatre School ’s activities participants/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).

Should iSDA Theatre School be unable to process participant’s data, we would be contravening both our Health & Safety and Child Safeguarding policies. We would also be ignoring best practice regarding working with children/vulnerable adults.

Our participants must remain safe at all times, therefore information about participants must be collected in order to create registers and accurate student records. This information is also used to provide students with appropriate classes, including dividing students into age groups and to determine appropriate examinations.

As physical activity providers it is essential that this consent is given should a participant have any medical/disability needs. This allows us to incorporate participants safely into classes. It is also used in assessing if we can incorporate participants safely into classes.

Ethnicity and other sensitive data is to provide information to examining bodies for statistical purposes.

This data is always provided to third parties as quantified data (i.e. cumulative numerical data only with no identifying information relating to any data subject).

What data we collect:

Personal data and some special category is collected.

It is essential to our primary function (providing classes to participants) that we are provided, and allowed to process and store the following:

Participant 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 exams taken through iSDA Theatre School only) - GDPR Article 6(1)(f)

- Classes attended/Price paid - GDPR Article 6(1)(f)

Participant Special Category Data:

- Medical Information/History – GDPR Article 9 (a)

- Disability Information - GDPR Article 9 (a)

- Ethnicity – GDPR Article 9 (a & j) – further explicate consent sought

- Gender/Sex – GDPR Article 9 (a & j) – further explicate consent sought

- Sexuality – 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. How data collected is sent internally:

iSDA Theatre School transports data with all due diligence.

Enrolment forms are sent to iSDA Theatre School through an encrypted email server directly from Class Manager which has controlled access. Any sensitive information on paper is kept in a locked filing cabinet before being shred and securely disposed of.

Storage/Retention of data:

Data received through enrolment forms is uploaded manually into our database software. Our database is stored both 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 authorised staff members.

Registers and emergency contact lists are created automatically from our database software. Access to these files is restricted through password protection and only available to authorised staff members. Hard copies of registers and emergency contacts are carried by authorised staff members. They are locked away while not in use. When they are no longer in use or out-dated, they are destroyed thoroughly.

Waiting lists are stored on the database software.

Our standard retention policy (without the data subject’s right to access, rectification and erasure etc.) is THREE YEARS post final attendance.

Exceptions to our retention policy:

- Financial records are kept for 6 years due to legal obligation

- First Aid records are kept for 21 years due to legal obligation

- Photo consent may be kept indefinitely

- 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

- Bank details are deleted after the action concerning them is complete

- Unsolicited enquiries that do not turn into bookings with current classes are deleted after they

have been dealt with

Third Parties/Data Processors:

iSDA Theatre School does not actively share data with third parties, however there are certain instances where sharing information is crucial to our business processes.

Freelance Teachers:

As many of iSDA Theatre School teachers are freelance staff, we have confidentiality and data processor agreements in place. Teachers will never be provided with personal details aside from participant’s first names and any medical information that is pertinent to the running of a class (subject to consent from

the data subject)

MailChimp:

iSDA Theatre School uses a USA based company ‘MailChimp’ to provide newsletters and marketing via email. This is an optional process, which people consent to during enrolment. Data Subjects can opt-out and erase/rectify their record stored with MailChimp at any time.

iSDA Theatre School is satisfied that their GDPR regulations are thorough, and the information stored in MailChimp (email addresses) is secure. We have a processor contract in place, and copies are available upon request.

Class Manager:

iSDA Theatre School uses a UK based company ‘Class Manager’ for the administration of class registers, invoices and student information.

iSDA Theatre School is satisfied that their GDPR regulations are thorough, and the information stored in Class Manager is secure.

Track and Trace COVID-19 Service:

iSDA Theatre School has an obligation to inform the COVID-19 Track and Trace system if a student or staff member tests positive for the virus. This will involve passing names and phone numbers on to the service.

Child Performance Licensing:

In order to process child performance licences, iSDA Theatre School are legally required to provide some personal data to local councils (including but not limited to: full name, date of birth and school details). This is an optional consent, which will be sought at the time of sending participation consent forms.

iSDA Theatre School is satisfied that their GDPR process are thorough and any data will be stored in a secure environment, and not unnecessarily retained.

Child Safeguarding Concerns:

In the unlikely event iSDA Theatre School has a safeguarding concern in relation to one of our participants, iSDA Theatre School are legally required to provide data to the safeguarding board at the local council.

iSDA Theatre School is satisfied that their GDPR process are thorough and any data will be stored in a secure environment, and not unnecessarily retained.

Event Programmes:

iSDA Theatre School may occasionally produce programmes for events. These will only ever contain the first name and first initial of a child’s last name (unless otherwise consented to). The name of a child’s class may also be included. Participants/their Parent and/or Guardians may choose if they want to be included in the programme when they agree to participate at an event.

Examination Entry:

In order to enter examinations, iSDA Theatre School must provide some personal data to examination boards. Currently iSDA Theatre School work with the International Dance Teachers Association (IDTA). This sharing of data is to be consented to by the data subject and/or parent/guardian upon being entered for the exam.

Schools and Nurseries:

iSDA Theatre School must sometimes share personal data with schools and nurseries (names, DOB and payment information) when taking part in an internal class (after school and lunchtime clubs) in order for them to check persons attending. This also helps the school work out iSDA Theatre School ’s payment in terms of renting space.

iSDA Theatre School is satisfied that their GDPR process are thorough and any data will be stored in a secure environment, and not unnecessarily retained.

Rights of the data subject and iSDA Theatre School compliance with responses:

Any data subject with personal data stored within iSDA Theatre School is entitled to the rights of:

- Access

You may contact iSDA Theatre School at any time to access all data held relating to you and/or your child(ren). iSDA Theatre School will ensure that we respond to a subject access request without undue delay and within one month of receipt. If the information request will also include data regarding others, iSDA Theatre School has the right to refuse the request or take steps in order to obtain consent from other involved parties.

The right of access does not apply to iSDA Theatre School ’s legal obligations such as Child Safeguarding records.

- Rectification

You may contact iSDA Theatre School at any time in order to rectify data held relating to you and/or your child(ren). iSDA Theatre School will ensure that we respond to a rectification request without undue delay and within one month of receipt.

The right to rectification does not apply to iSDA Theatre School ’s legal obligations such as payment record information.

- Erasure

You may contact iSDA Theatre School at any time in order to erase data held relating to you and/or your child(ren). iSDA Theatre School will ensure that we respond to an erasure request without undue delay and within one month of receipt.

The right to erasure does not apply to iSDA Theatre School ’s legal obligations such as First Aid records.

- Restrict Processing

You may contact iSDA Theatre School at any time in order to restrict the data we process relating to you and/or your child(ren). iSDA Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt.

However, due to our legitimate interest in most of the data collected- we may have to revoke your membership with iSDA Theatre School until the restriction is lifted. This is due to Health and Safety and Child Safeguarding.

- Data Portability

You may contact iSDA Theatre School at any time in order to obtain the data we process relating to you and/or your child(ren) and reuse it across different services. iSDA Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt. Please note, this does not apply to iSDA Theatre School ’s legal obligations.

- Objection

You may contact iSDA Theatre School at any time in order to object to the processing of data relating to you and/or your child(ren). iSDA Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt.

- Rights related to automated decision making including profiling

You may contact iSDA Theatre School at any time in order to object to profiling relating to you and/or your child(ren). iSDA Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt.

However, due to our legitimate interest in most of the data collected- we may have to revoke your membership with iSDA Theatre School until the profiling restriction is lifted. This is due to Health and Safety and Child Safeguarding.

iSDA Theatre School has a lawful reason for profiling; Legitimate Interests and consent.

None of iSDA Theatre School ’s decision making is automated. Profiling is only used in circumstances where a participant may have certain health/disability needs which may prevent them from taking part in classes (as it would be unsafe to do so).

Any and all verbal requests are noted, and then contacted again either via phone or email to verify the request. Verbal requests will be responded to in the time frames mentioned above.

Photos/Videos of Participants

iSDA Theatre School often use footage/photos used from shows, performances and classes for marketing purposes both in print media and the website. Participants/their Parent and/or Guardians may choose if they do not wish themselves/their child to be depicted.

It should be noted by parents/guardians that, if you agree for your child to perform at a public event with iSDA Theatre School , other parties may film and/or photograph the performance for their own personal use (e.g. parents of other participants).

Participants/their Parent and/or Guardians may elect not allow themselves and/or their children to be depicted iSDA Theatre School will do everything in their power to enforce this. iSDA Theatre School cannot be held liable for any breaches at public events.

Social Media:

iSDA Theatre School regularly share photos/videos of students in workshops, events and performances through social media platforms including; Instagram, Facebook, Twitter, Email. These will never be shared with any identifying information (age, location etc.). There may be times where we will share first names, but will only share full names with the explicit consent of the parents.

Staff (Employees/Freelance), Trustees, Volunteers and Potential Staff/Trustees and/or Volunteers

For the purposes of this policy, the aforementioned persons above will be referred to as ‘staff’.

How iSDA Theatre School collect personal data:

iSDA Theatre School staff supply their personal data when applying for roles within the company. This is either completed through an application form, or submission of a CV.

Further information is collected when applicants are considered successful. Unsolicited data may come to iSDA Theatre School in the form of applicants emailing regarding work/volunteer opportunities.

Why iSDA Theatre School collect personal data:

It is iSDA Theatre School ’s legal obligation to collect staff’s personal data in relation to their employment. This is due to Legal Obligation GDPR Article 6(1)(c) and/or Contract - Article 6(1)(b)

Should iSDA Theatre School be unable to process staff’s data, we would be contravening UK Employment law, our own employment contracts (both PAYE and Freelance) and our own Health & Safety and Child Safeguarding policies.

Special category data is only collected with the consent of the data subject. Special category data iSDA Theatre School collects includes but is not limited to: Medical/Disability information, Ethnicity, Gender and Sexuality. iSDA Theatre School ’s lawful purpose for collecting this data is both Article 6(1)(b) – contract and

Article 9(2)(b) – employment. This also ensures we are confirming to our Equal Opportunities policy. Any data is always recorded as quantified data (i.e. cumulative numerical data only with no identifying information relating to any data subject).

iSDA Theatre School is also entitled to obtain and process data in relation to criminal convictions and DBS checks. Most posts within iSDA Theatre School are exempt from the Rehabilitation of offenders act (1974) by the 1975 and 2001 Exceptions Amendment, as they involve working with vulnerable and/or young people. This is further supported by article 10 of GDPR.

What data we collect:

Personal data and some special category is collected.

It is essential to our business that we are provided, and allowed to process and store the following:

Staff Personal Data:

- Full Name Legal obligation – GDPR Article 6(1)(c) Legal Obligation - Date of Birth - GDPR Article 6(1)(c) Legal Obligation

- Contact Details - GDPR Article 6(1)(c) Legal Obligation

- Pension Information - GDPR Article 6(1)(c) Legal Obligation

- NI number - GDPR Article 6(1)(c) Legal Obligation

- UTR number - GDPR Article 6(1)(c) Legal Obligation

- Right to work in the UK - GDPR Article 6(1)(c) Legal Obligation - References - GDPR Article 6(1)(c) Legal Obligation

- Bank Details - Article 6(1)(b) Contract

- Tax details - GDPR Article 6(1)(c) Legal Obligation

- Qualifications - Article 6(1)(b) Contract

- Pay Details - GDPR Article 6(1)(c) Legal Obligation

- Performance Details - Article 6(1)(b) Contract

- Annual Leave Details - Article 6(1)(b) Contract

- Sick/Compassionate/Maternity/Paternity Leave Details - Article 6(1)(b) Contract

- Safeguarding Concerns - GDPR Article 6(1)(c) Legal Obligation

- Emergency Contact - GDPR Article 6(1)(b) Contract

Staff Special Category Data:

- Criminal Record/DBS Checks - GDPR Article 6(1)(c) Legal Obligation & GDPR Article 10

- Medical/Disability - Article 6(2)(b) Contract & Article 9(2)(b)

- Ethnicity – Further explicit consent sought- Article 9(2)(a & b)

- Sexuality – Further explicit consent sought - Article 9(2)(a & b)

How data is sent internally:

Any transfer of data regarding staff is conducted through encrypted emails and/or stored in our encrypted cloud-based server.

Any unsolicited information is received to an encrypted email server.

Storage/Retention of data:

All Staff personal data is stored on encrypted files in our cloud-based server. It is also stored on encrypted hardware within the office. Any hard copies are stored in a locked cabinet. All of these files have restricted access to authorised staff only.

Most staff data is retained for 6 YEARS (post-employment). Exceptions to our retention policy:

- Pension details are stored for 75 years (post-employment) 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

- First Aid records are kept for a minimum of 21 years due to legal obligation

Unsuccessful applicant data is stored 6-months post campaign, this includes unsolicited data from potential applicants.

Third Parties/Data Processors:

iSDA Theatre School does not actively share data with third parties, however there are certain instances where sharing information is crucial to our business processes.

Bank:

In order to process payments by BACs, staff’s bank details and names must be added to our online banking system. iSDA Theatre School is satisfied that their GDPR process are thorough and any data will be stored in a secure environment, and not unnecessarily retained.

References:

In order to supply references for staff members, some personal data must be divulged. This will only be done with the data subject’s consent, as iSDA Theatre School may not be fully aware of the recipients GDPR policies.

Child Performance Licensing:

In order to process child performance licences, iSDA Theatre School are legally required to provide some staff’s personal data to local councils (including but not limited to: full name and DBS details).

iSDA Theatre School is satisfied that their GDPR process are thorough and any data will be stored in a secure environment, and not unnecessarily retained. For more information: https://www.warwickshire.gov.uk/dataprotection

Child Safeguarding Concerns:

In the unlikely event iSDA Theatre School has a safeguarding concern in relation to one of participants and/or staff members, iSDA Theatre School are legally required to provide data to the safeguarding board at the local council and the Disclosure and Barring service.

iSDA Theatre School is satisfied that their GDPR process are thorough and any data will be stored in a secure environment, and not unnecessarily retained.

Website Biography:

iSDA Theatre School ’s website includes staff biographies, these are available for public viewing. Consent it sought before any/all staff profiles are added to the website.

Rights of the data subject and iSDA Theatre School compliance with responses:

Any data subject with personal data stored within iSDA Theatre School is entitled to the rights of:

- Access

You may contact iSDA Theatre School at any time to access all data held relating to you. iSDA Theatre School will ensure that we respond to a subject access request without undue delay and within one month of receipt. If the information request will also include data regarding others, iSDA Theatre School has the right to refuse the request or take steps in order to obtain consent from other involved parties. The right of access does not apply to iSDA Theatre School ’s legal obligations such as confidential Child Safeguarding records.

- Rectification

You may contact iSDA Theatre School at any time in order to rectify data held relating to you. iSDA Theatre School will ensure that we respond to a rectification request without undue delay and within one month of receipt.

The right to rectification does not apply to iSDA Theatre School ’s legal obligations such as payment record information.

- Erasure

You may contact iSDA Theatre School at any time in order to erase data held relating to you. iSDA Theatre School will ensure that we respond to an erasure request without undue delay and within one month of receipt.

The right to erasure does not apply to iSDA Theatre School ’s legal obligations such as First Aid records.

- Restrict Processing

You may contact iSDA Theatre School at any time in order to restrict the data we process relating to you. iSDA Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt.

However, due to our legitimate interest and legal obligations in most of the data collected- we may not be able to restrict processing.

- Data Portability

You may contact iSDA Theatre School at any time in order to obtain the data we process relating to you and reuse it across different services. iSDA Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt.

Please note, this does not apply to iSDA Theatre School ’s legal obligations.

- Objection

You may contact iSDA Theatre School at any time in order to object to the processing of data relating to you. iSDA Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt.

However, due to our legitimate interest and legal obligations in most of the data collected- we may not be able to accept your objection.

- Rights related to automated decision making including profiling

You may contact iSDA Theatre School at any time in order to object to profiling relating to you). iSDA Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt.

Please note, this does not apply to iSDA Theatre School ’s legal obligations.

iSDA Theatre School has a lawful reason for profiling; Legitimate Interests and consent.

None of iSDA Theatre School ’s decision making is automated. Profiling is only used in circumstances where a staff member has a criminal conviction.

Any and all verbal requests are noted, and then contacted again either via phone or email to verify the request. Verbal requests will be responded to in the time frames mentioned above.

Training and Data Protection in Practise

All members of staff (PAYE, Freelance and Voluntary) must agree to this Data Protection policy prior to accepting a contract of employment.

Training is supplied as part of management and supervision. It is also included in all induction and training periods.

iSDA Theatre School is registered as a Data Controller with the Independent Commissioners Office (ICO). The registered Data Protection Officer (DPO) Complaints and Data Breeches

Complaints:

Complaints in regard to the handling of any personal data can be made directly to iSDA Theatre School ’s DPO: Sophie Cathrine, Principal.

Email: [email protected]

If you feel that your complaint was not handled in the correct manner, or still have concerns, you may escalate the complaint by contacting the Independent Commissioner’s Office (ICO).

ICO Telephone Number: 0303 123 1113

Data Breeches:

If iSDA Theatre School experiences a data breech of any kind, we have a legal obligation to report this to ICO within 72 hours. The data breech will be reported by the DPO. In the instance they are unavailable to report the breech, the next most senior staff member shall do so.

iSDA Theatre School will also inform all the victims of the data breech as soon as possible if there is a high risk of adversely affecting individuals’ rights and freedoms.

iSDA Theatre School will store and record all data breeches.