Privacy Policy

Last reviewed: September 2026

For the purposes of this policy, Kent Academy of Musical Theatre shall be referred to as “KAMT”.

This policy should be read alongside KAMT’s Terms and Conditions and any other relevant safeguarding, health and safety or operational policies.

PART ONE – DATA PROTECTION AND PRIVACY1. PURPOSE AND STATEMENT

KAMT is committed to protecting the privacy, security and confidentiality of the personal information entrusted to us by students, parents, guardians, customers, staff, volunteers and other individuals.

KAMT processes personal information in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy explains what personal information KAMT may collect; why it is collected and processed; how it is stored and protected; who it may be shared with; how long it may be retained; how photographs, videos and online communications are managed; and the rights individuals have in relation to their personal information.

KAMT will only collect and process personal information where there is an appropriate reason and lawful basis for doing so.

2. DATA PROTECTION PRINCIPLES

KAMT aims to ensure that personal information is processed lawfully, fairly and transparently; collected for specified, explicit and legitimate purposes; adequate, relevant and limited to what is necessary; accurate and kept up to date where necessary; retained only for as long as reasonably necessary; stored and processed securely; and protected against unauthorised or unlawful access, accidental loss, destruction or damage.

Access to personal information will be restricted to individuals who reasonably require that information to carry out their role.

3. LAWFUL BASIS FOR PROCESSING

Depending on the circumstances and purpose for which information is being used, KAMT may process personal information on one or more lawful bases, including Contract, Legal Obligation, Legitimate Interests, Consent and Vital Interests.

Where KAMT processes special category personal data, such as relevant health information, an appropriate additional condition for processing will also be identified where required.

Consent will not necessarily be relied upon where another lawful basis is more appropriate, particularly where information must be processed or shared for safeguarding, legal or safety purposes.

4. HOW KAMT COLLECTS PERSONAL INFORMATION

Personal information may be provided to KAMT through Class Manager; enrolment and registration forms; booking forms; KAMT’s website; email; telephone; WhatsApp; social media enquiries; audition or production forms; event bookings; private lesson bookings; competition or examination entries; photography/video consent forms; medical or emergency information; payment and invoicing records; and direct communication with students, parents or guardians.

Information may also be provided to KAMT by schools, venues, teachers, production partners or other organisations where there is an appropriate reason for doing so.

5. INFORMATION KAMT MAY COLLECT

Student/participant information may include full name, date of birth, address, contact information, parent/guardian information, emergency contact details, school or educational establishment, classes and activities attended, attendance records, payment and invoicing information, relevant examination information, relevant performance/casting information, collection permissions, photography/video preferences and other information reasonably required to administer KAMT activities.

KAMT may collect relevant health, medical and additional-needs information including medical conditions, allergies, medication, injuries, disabilities, accessibility requirements, learning difficulties and other information affecting safe participation.

Parent/guardian and customer information may include name, postal address, email address, telephone number, emergency contact information, relationship to the student, booking information, payment and invoice records and correspondence with KAMT.

KAMT will only collect bank details where reasonably necessary, for example to process a refund, and will not retain them longer than reasonably required.

6. WHY KAMT COLLECTS PERSONAL INFORMATION

Personal information may be used to enrol and register students; provide classes, lessons, rehearsals and activities; maintain attendance registers; communicate with students and families; issue invoices and maintain payment records; administer trials and enrolments; organise productions, auditions, rehearsals and performances; enter students for examinations; manage costumes, events and other activities; respond to medical or emergency situations; meet safeguarding responsibilities; provide appropriate support; comply with legal and financial obligations; manage complaints; maintain business records; promote KAMT where appropriate; and protect the safety and legitimate interests of KAMT, its students, staff and families.

7. CHILDREN’S INFORMATION

As KAMT provides services to children and young people, particular care will be taken when handling children’s personal information.

Information collected about children will be limited to information reasonably required to provide services safely and effectively, administer participation and fulfil safeguarding responsibilities.

Parents and guardians are responsible for providing accurate information about their child and informing KAMT of relevant changes. Where appropriate, the views and privacy rights of the child or young person will also be considered, taking account of their age and understanding.

8. STORAGE AND SECURITY

KAMT will take reasonable organisational and technical measures to protect personal information.

Electronic information may be stored within secure systems including Class Manager, password-protected devices, email systems, secure cloud storage and other systems used by KAMT. Access will be restricted to authorised individuals where reasonably practicable.

Paper records containing personal information will be stored securely when not in use and disposed of securely when no longer required. Staff and freelance teachers will only be given access to information reasonably necessary for their role.

9. CLASS REGISTERS AND EMERGENCY INFORMATION

Teachers may be provided with appropriate class registers and relevant emergency, medical or additional-needs information where necessary for the safe delivery of a class or activity.

Information supplied to teaching staff must be treated confidentially and must not be used for unrelated purposes. Printed registers or emergency information must be stored securely and securely destroyed when no longer required.

10. DATA RETENTION

KAMT will not retain personal information for longer than reasonably necessary for the purpose for which it was collected or where retention is required for legal, safeguarding, insurance, financial or legitimate business reasons.

Different categories of information may have different retention periods. Financial records will normally be retained for the period required by applicable financial and tax legislation. Safeguarding, accident, incident and child protection records may need to be retained for longer periods in accordance with applicable guidance, legal requirements and the circumstances of the individual case.

Information collected solely to complete a particular transaction, such as bank details supplied for a refund, will be deleted or securely destroyed once no longer required. Unsuccessful or general enquiries that do not result in a booking will not be retained indefinitely.

KAMT will periodically review the personal information it holds and securely delete or destroy information that is no longer required.

11. SHARING PERSONAL INFORMATION

KAMT does not sell personal information.

Personal information will only be shared where there is an appropriate reason for doing so. Depending upon the activity, information may be shared with KAMT staff and authorised freelance teachers; Class Manager and other service providers; venues; schools; examination boards; local authorities; child performance licensing teams; professional photographers/videographers where appropriate; payment providers; accountants or professional advisers; insurers; IT or website providers; safeguarding agencies; emergency services; police; and other organisations where legally required or reasonably necessary.

Only information reasonably necessary for the relevant purpose should be shared. Where third-party service providers process information on KAMT’s behalf, KAMT will take reasonable steps to ensure appropriate data protection arrangements are in place.

12. SAFEGUARDING AND INFORMATION SHARING

Protecting a child or vulnerable person may require KAMT to share personal information with appropriate organisations or authorities.

Where KAMT has a safeguarding concern, relevant information may be shared with Children’s Social Care, the relevant local authority, safeguarding partners, police, schools, medical professionals, the NSPCC or other appropriate safeguarding organisations.

KAMT does not require consent where information can or should lawfully be shared in order to protect a child or another person. Information sharing will, wherever reasonably possible, be limited to what is relevant and necessary.

13. CHILD PERFORMANCE LICENSING

Where a child requires a performance licence or other statutory permission, KAMT may need to provide relevant personal information to the appropriate local authority or other authorised organisation. Parents or guardians will be informed where information is required for this purpose.

14. EXAMINATIONS

Where students are entered for examinations, assessments or qualifications, relevant information may need to be provided to the appropriate examination or awarding organisation. Parents/guardians or adult students will be informed as appropriate when an examination entry is made.

15. PHOTOGRAPHY AND VIDEO

Parents, guardians and adult students will be given an opportunity to indicate their photography and video preferences as part of registration or through another appropriate consent process. KAMT will follow the consent/preferences recorded for regular classes wherever reasonably practicable.

KAMT may photograph or film classes, rehearsals, workshops, events, productions, performances, awards, promotional activities and other KAMT activities. Images or recordings may be used for KAMT’s website, social media, advertising, printed promotional material, programmes, newsletters, displays and documenting activities and achievements.

KAMT will not ordinarily publish a child’s full name alongside an image unless appropriate permission has been obtained.

Parents and guardians should be aware that public performances may be photographed or filmed by KAMT, professional photographers/videographers, venues and members of the audience. KAMT cannot guarantee that a student will not appear incidentally in photographs or recordings taken by members of the public at a public event.

16. SOCIAL MEDIA AND ONLINE COMMUNICATION

KAMT may use social media and online platforms to advertise classes and events, celebrate student achievements, communicate news and updates, promote productions, share photographs/video where appropriate and respond to enquiries.

KAMT currently uses platforms that may include Facebook, Instagram, WhatsApp and other appropriate digital services. These platforms operate under their own privacy policies and terms.

Private or sensitive matters should not be discussed publicly on KAMT social media pages or group chats and should instead be communicated privately to KAMT.

17. MARKETING COMMUNICATIONS

KAMT may send relevant information concerning existing classes, bookings, timetables, invoices, rehearsals, productions and other services as part of normal administration.

Where consent is required for separate marketing communications, individuals will be given an appropriate opportunity to opt in or opt out. Individuals may request to stop receiving optional marketing communications at any time.

This does not prevent KAMT from sending essential administrative communications relating to an existing booking, class, payment, safeguarding matter or other legitimate operational requirement.

18. DATA SUBJECT RIGHTS

Subject to applicable law and any relevant exemptions, individuals may have rights including the right to be informed, access, rectification, erasure, restriction of processing, data portability, objection and rights relating to automated decision-making and profiling.

These rights are not absolute in every circumstance. KAMT may need to retain certain information because of legal, financial, safeguarding, insurance or other legitimate requirements.

Requests concerning personal information should be made directly to KAMT. KAMT will respond within the timescales required by applicable data protection legislation and may need to verify identity before releasing information.

19. DATA BREACHES

Any suspected loss, accidental disclosure, unauthorised access or other personal data breach should be reported to the Principal immediately.

KAMT will investigate suspected breaches and take appropriate action. Where legally required, KAMT will notify the Information Commissioner’s Office (ICO) and/or affected individuals.

20. DATA PROTECTION CONCERNS

Questions or concerns regarding how KAMT processes personal information should initially be raised with the Principal. Individuals also have the right to raise concerns with the Information Commissioner’s Office (ICO) where appropriate.

PART TWO – CHILD PROTECTION AND SAFEGUARDING21. SAFEGUARDING STATEMENT

KAMT recognises that children and young people have the right to participate in performing arts activities in a safe, positive and supportive environment. The welfare and safety of children attending KAMT is of paramount importance.

This policy applies to employees, freelance teachers, visiting practitioners, volunteers, assistants, chaperones where applicable and anyone working on behalf of KAMT who has responsibility for children or young people. For the purposes of this policy, a child means anyone under the age of 18.

22. SAFEGUARDING GUIDANCE

KAMT will have regard to relevant current safeguarding legislation and guidance applicable to its activities, including appropriate consideration of current Department for Education guidance relating to safeguarding children and young people and safeguarding within out-of-school settings.

KAMT recognises that safeguarding is everyone’s responsibility. Anyone working with KAMT who has concerns about a child’s welfare must act on those concerns and follow KAMT’s safeguarding procedures.

23. DESIGNATED SAFEGUARDING RESPONSIBILITY

Overall responsibility for safeguarding within KAMT rests with Joanna Mason – Principal.

The Principal acts as KAMT’s designated safeguarding lead/person and is responsible for receiving safeguarding concerns; maintaining appropriate records; deciding what further action may be required; seeking advice; making referrals where appropriate; ensuring staff understand safeguarding expectations; and reviewing procedures.

The designated safeguarding person is not responsible for deciding whether abuse has occurred. This is the responsibility of the appropriate statutory authorities.

Where the Principal is unavailable, safeguarding concerns should be reported to the senior member of KAMT staff present, who must ensure appropriate action is taken without unnecessary delay. Nothing in this policy prevents any individual from contacting Children’s Social Care, the police or another appropriate safeguarding authority directly.

24. SAFEGUARDING PRINCIPLES

KAMT’s safeguarding approach is based on the welfare of the child being paramount; every child having the right to protection from abuse and harm; children being treated with dignity and respect; concerns being taken seriously and responded to promptly; children being listened to; information being shared appropriately where necessary; professional boundaries being maintained; and discrimination, harassment, bullying and abuse not being tolerated.

KAMT seeks to provide an inclusive environment in which children are treated fairly regardless of age, disability, race, ethnicity, sex, religion or belief, sexual orientation or other relevant characteristic.

25. SAFER RECRUITMENT AND SUITABILITY

KAMT will take reasonable steps to ensure that individuals working with children are suitable for their roles. Depending upon the role and eligibility requirements, this may include application or recruitment checks, references, identity checks, appropriate DBS checks, safeguarding information/training, supervision and consideration of experience and suitability.

DBS checks will be obtained at the appropriate level where the role is eligible for such a check.

26. SUPERVISION

KAMT will make reasonable arrangements for appropriate supervision of children during its activities.

Students are under KAMT’s supervision during their scheduled class, lesson, rehearsal or activity time. Parents and guardians remain responsible before the scheduled start time, following the scheduled finish time and at any other time where KAMT has stated parental supervision is required.

Parents and guardians should ensure children are collected promptly unless an alternative arrangement has been agreed.

27. ONE-TO-ONE LESSONS

KAMT provides one-to-one tuition, including singing lessons. Reasonable safeguarding measures will be maintained during private lessons.

Parents and guardians should be informed of the location and scheduled time of lessons involving children. Teaching should take place in an appropriate environment and professional boundaries must be maintained at all times.

Any concerns arising during a private lesson must be reported in accordance with this policy.

28. PHYSICAL CONTACT

Performing arts training may occasionally require appropriate physical contact for purposes such as correcting posture or alignment, demonstrating dance technique, positioning, choreography, acting exercises, breathing or vocal technique where appropriate, preventing injury or responding to an emergency.

Physical contact must always be appropriate to the activity, proportionate and undertaken professionally. Where possible, the reason for contact should be explained to the student. A student’s discomfort or request to stop should be respected unless immediate contact is necessary to prevent injury or protect safety.

29. TYPES OF ABUSE AND HARM

Safeguarding concerns may include physical abuse, emotional abuse, sexual abuse and neglect.

KAMT also recognises concerns including child-on-child abuse, bullying including online bullying, domestic abuse, coercive or controlling behaviour, sexual harassment, sexual violence, child sexual exploitation, child criminal exploitation, online abuse, grooming, radicalisation, honour-based abuse, forced marriage, female genital mutilation (FGM), discrimination and exploitation.

Staff are not expected to diagnose abuse. Their responsibility is to recognise concerns, respond appropriately and report them.

30. POSSIBLE INDICATORS OF ABUSE OR NEGLECT

Possible indicators may include unexplained or unusual injuries; injuries inconsistent with explanations; significant or unexplained changes in behaviour; becoming unusually withdrawn, anxious or aggressive; fear of a particular person; inappropriate sexual knowledge or behaviour; unexplained deterioration in attendance or participation; persistent hunger or poor hygiene; inappropriate clothing; unexplained weight loss; repeated untreated medical concerns; significant changes in relationships; disclosure of abuse or harm; self-harm; substance misuse; unexplained money or possessions; signs of exploitation or grooming; or a child indicating that they feel unsafe.

The presence of one or more indicators does not necessarily mean abuse has occurred. Equally, abuse may occur without obvious signs. Any genuine concern should be reported rather than investigated personally.

31. RESPONDING TO A DISCLOSURE

If a child tells a member of staff or volunteer that they have been harmed or abused, the adult should remain calm; listen carefully; take the child seriously; allow the child to speak in their own words; avoid leading or unnecessary questions; not promise confidentiality; explain that information may need to be shared with someone who can help keep them safe; reassure the child that they have done the right thing by speaking; make an accurate written record as soon as possible; and report the matter promptly to the designated safeguarding person.

The adult must not attempt to investigate the allegation themselves or confront the person alleged to have caused harm.

32. REPORTING A SAFEGUARDING CONCERN

Any member of staff, volunteer or other person working with KAMT who has a safeguarding concern must report it promptly to Joanna Mason – Principal and Designated Safeguarding Person.

The report should include, where known, the child’s name; nature of the concern; what was seen, heard or disclosed; relevant dates and times; names of other people present; and any immediate action already taken.

Records should distinguish clearly between factual information, observations, information reported by another person and professional opinion or concern.

33. IMMEDIATE DANGER

Where a child is believed to be in immediate danger or at immediate risk of serious harm, emergency action should not be delayed while attempting to contact KAMT management.

Call 999 where there is an immediate risk of harm or an emergency. Appropriate safeguarding services should also be contacted where necessary.

34. REFERRALS AND EXTERNAL SAFEGUARDING SUPPORT

Where appropriate, KAMT may seek advice or make a referral to the relevant local authority Children’s Social Care service, local safeguarding partnership, police, NSPCC, a child’s school or safeguarding lead, medical services or another appropriate statutory/safeguarding organisation.

Parents or guardians will normally be informed where appropriate, unless doing so could increase risk to the child, interfere with an investigation or otherwise be contrary to safeguarding advice.

35. FEMALE GENITAL MUTILATION (FGM)

FGM is a serious form of abuse and is illegal in the UK. Any concern that a child may be at risk of FGM must be reported immediately through KAMT’s safeguarding procedures.

Where a legal mandatory reporting duty applies to an individual professional, that person must comply with their statutory reporting obligations. Where a child is in immediate danger, the police should be contacted.

36. ALLEGATIONS OR CONCERNS ABOUT STAFF OR VOLUNTEERS

Any allegation or safeguarding concern involving a KAMT employee, teacher, volunteer, assistant or other adult working on behalf of KAMT must be taken seriously.

The concern should be reported immediately to the Principal unless the allegation concerns the Principal. Where an allegation concerns the Principal, the person receiving the concern should seek advice directly from the appropriate local authority safeguarding service and/or other relevant statutory authority.

KAMT will not conduct an internal investigation in a way that could compromise a statutory safeguarding investigation.

37. CHILD-ON-CHILD CONCERNS

Safeguarding concerns can arise between children as well as between an adult and a child. KAMT will take child-on-child abuse seriously.

This may include bullying, physical abuse, sexual harassment, sexual violence, inappropriate sexual behaviour, online abuse, coercion, intimidation and discriminatory abuse. Such behaviour will not be dismissed as ordinary banter or simply part of growing up.

38. ONLINE SAFETY AND COMMUNICATION

Staff and volunteers must maintain appropriate professional boundaries when communicating electronically with students.

Where possible and appropriate, communication concerning children should involve or be visible to their parent/guardian. Staff should not use private online communication with children in a manner that could compromise professional boundaries or safeguarding.

Any inappropriate online contact, content or communication involving a student should be reported as a safeguarding concern where appropriate.

39. PHOTOGRAPHY AND SAFEGUARDING

Photography and filming must be carried out in accordance with KAMT’s photography/video arrangements and recorded permissions.

Images of children must not be used in an inappropriate, exploitative or unsafe manner. KAMT staff must not take or retain photographs or recordings of students for inappropriate personal purposes. Any concern regarding inappropriate photography, filming or sharing must be reported.

40. ACCIDENTS, INJURIES AND FIRST AID

Where a student is injured during a KAMT activity, appropriate first aid and emergency action will be taken. Relevant accidents or injuries will be recorded and parents/guardians informed where appropriate.

Where an injury raises a safeguarding concern, the matter will also be considered under KAMT’s safeguarding procedures. If a child arrives with a significant visible injury or an injury gives rise to concern, appropriate details may be recorded and clarification sought where appropriate.

41. CONFIDENTIALITY

Safeguarding information is confidential but is not secret. Information should only be shared with people who reasonably need it for safeguarding purposes.

Staff and volunteers must not discuss safeguarding concerns casually or with individuals who have no legitimate reason to know. Concerns about confidentiality must never prevent appropriate information sharing where a child may be at risk.

42. RECORD KEEPING

Safeguarding concerns, disclosures, decisions and referrals should be recorded clearly and securely. Records should include dates and times, factual details, the child’s own words where relevant, actions taken, advice received, referrals made and relevant decisions and reasons.

Safeguarding records must be stored securely with access restricted appropriately.

43. WHISTLEBLOWING AND RAISING CONCERNS

Anyone working with KAMT who has concerns about unsafe practice, inappropriate conduct or KAMT’s response to a safeguarding matter should raise those concerns promptly.

No member of staff or volunteer should be prevented from contacting an appropriate safeguarding authority directly where they genuinely believe that doing so is necessary to protect a child.

44. STAFF AND VOLUNTEER RESPONSIBILITIES

Everyone working on behalf of KAMT is expected to understand their safeguarding responsibilities; maintain appropriate professional boundaries; report concerns promptly; treat children with dignity and respect; avoid inappropriate behaviour; follow KAMT policies and reasonable instructions; maintain confidentiality appropriately; cooperate with safeguarding procedures; and undertake relevant safeguarding training or updates where required.

45. PARENT/GUARDIAN RESPONSIBILITIES

Parents and guardians are expected to provide accurate and up-to-date emergency and medical information; notify KAMT of relevant safeguarding or welfare information where appropriate; ensure children arrive and are collected appropriately; comply with collection arrangements; communicate concerns directly to KAMT; respect safeguarding and privacy requirements relating to other children; and comply with KAMT’s Terms and Conditions and behavioural expectations.

46. POLICY REVIEW

This Data Protection, Privacy and Safeguarding Policy will be reviewed periodically and may be updated where legislation changes, safeguarding or data protection guidance changes, KAMT’s systems or services change, new risks are identified or KAMT considers an amendment necessary to improve its procedures.

The current version of the policy will be made available through KAMT’s usual platforms and/or upon request.

47. ACCEPTANCE AND APPLICATION

Participation in KAMT activities is subject to KAMT’s Terms and Conditions and relevant policies.

Parents, guardians and adult students are responsible for providing accurate information and informing KAMT where relevant circumstances change.

KAMT staff, freelancers and volunteers are required to follow this policy when carrying out work on behalf of KAMT.

KAMT is committed to protecting the privacy, welfare and safety of every student and to responding appropriately whenever a data protection or safeguarding concern arises.