Date Adopted: 2008 (DPA).

Updated: 2023.

Date of last review: 01.09.2023

To be reviewed next/before/on: 01.09.2024
 

Purpose and Statement:

The Jill Stew School of Dance (JSSOD) 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).

JSSOD 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 (Student, Parent and/or Guardian); Consent – Article 6(1)(a)

Main Aims for the policy:

• Specify the data JSSOD collect, how it is store/protected and the reason for collecting it
   
• State how JSSOD use personal data in processing
   
• Disclose who has access to the data and how long we retain information for
   
• Explain Data Subject’s right with JSSOD data including access, rectification and erasure

Distribution:

• To be distributed to all staff (self-employed/freelance)
   
• To be displayed on the JSSOD 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 of policy:

• Reviewed annually or in instances of legislative change

Introduction

The Jill Stew School of Dance (JSSOD) is committed to ensuring that any personal data we hold about you and your child is protected in accordance with data protection and is used in line with your expectations. JSSOD will keep data in secure locations (including but not limited to, password protected PC and/or in lockable storage) and will not retain data unnecessarily or past the retention length as set out in this policy. In the instance of a data processor being used, that is not a member of staff at JSSOD , the data subject (Student, Parent and/or Guardian) will be asked for consent pre to supplying the data or be notified and have the right to object to processing.

This privacy notice explains what personal data we collect, why we collect it, how we use it, how we protect it and how we dispose of it.

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

Why we collect data and the legal basis for handling it:

JSSOD customers and students supply their personal data directly when signing up for classes through our paper enrolment form. This is either completed by a parent/guardian or the student themselves if they are deemed able to do so. Should JSSOD be unable to process student’s data we would be contravening both our Health and Safety and Child Protection policies. We would also be ignoring best practice regarding working with children/vulnerable adults.

Our students must remain safe at all times, therefore information about students 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.

Special category data is only collected with the consent of the Student/Parent and/or Guardian including Medical/Disability information, Ethnicity and Nationality.

As physical activity providers it is essential that the consent is given should a student have any medical/disability needs. This allows us to assess if we are able to incorporate students safely into classes. It is the obligation of the Student/Parent and/or Guardian to inform JSSOD of any known medical details and to agree that they are aware of the element of risk involved in dancing and understand that JSSOD may not be held responsible for any injury.

We use personal data about JSSOD customers and students in order to provide recreational services. This includes using your data to:

• Contact parent/guardian in case of an emergency
   
• To keep you updated with information about our school/services/offers/performances/successes
   
• To fill in an accident book if applicable
   
• To register students with examination bodies in order to take examinations if applicable (see third parties)
   
• Track and Trace COVID-19 service

What data is collected:

Personal data and some special category data is collected.

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

Student Personal Data: Full name, Date of Birth, Address, Sex, Exam Results (taken through JSSOD only), Classes attended/Price Paid

Student Special Category Data: Medical Information/History, Disability Information, Ethnicity (optional) and Nationality (optional)

Parent/Guardian Personal Data: Name, Address (if different from student), Email Address, Mobile Telephone Number, Work/Home Telephone Number, Emergency Contact Number

Who we share data with – Third Parties:

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

• Examination Entry: The Royal Academy of Dance (RAD), The Imperial Society of Teachers of Dancing (ISTD), The London Academy of Dramatic Arts (LAMDA) all require JSSOD to provide some student’s personal data in order to register them for examinations within their organisation.  JSSOD are satisfied that each establishment has a GDPR process in place and that any data supplied will be stored in a secure environment and not unnecessarily retained. The sharing of data is to be consented to by the student and/or parent/guardian upon being entered for the exam
   
• Child Performing Licensing: JSSOD are sometimes required to process child performance licences and on these occasions are legally required to provide personal data to local councils (including but not limited to full name, date of birth, address) JSSOD are satisfied that their GDPR process is thorough and that any data supplied will be stored in a secure environment and not unnecessarily retained
   
• Track and Trace COVID-19 service
   
• Festival/Competition Organisers: Any students participating in an external dance festival/competition will be required to provide personal data (including but not limited to full name, date of birth, address) JSSOD are satisfied that their GDPR process is thorough and that any data supplied will be stored in a secure environment and not unnecessarily retained
   
• Event Programmes: JSSOD may occasionally produce programmes for events. The name of the student and sometimes their class may be included. Students/their Parent and/or Guardian may choose if they don’t want to be included in the programme when they agree to take part at an event
   
• Publicity, Social Media, Website: Following new changes in legislation it is advised that the full name of a student doesn’t feature alongside a photograph of the data subject in question. Please notify JSSOD in writing if any Student/Parent and/or Guardian does not wish for an image to feature on any of our social media platforms or noticeboard alongside the name of the data subject. Please note our website uses cookies, this can be disabled in your browser should you not wish to browse with it
   
• School Noticeboard: JSSOD use their school noticeboard in the lobby of their premises (only accessible by keypad entry by staff, students, Parents and/or Guardians to display examination results, recent successes, and general school admin and policies. Any students/their Parent and/or Guardian may choose if they don’t want their name, examination marks or successes to be placed on the noticeboard when they enrol into the school
   
• References: When a student applies for additional and/or vocational training JSSOD may be asked to supply a reference confirming their suitability and dance history. In order to do so some personal data may need to be divulged with the student, Parent and/or Guardians consent as JSSOD may not be fully aware of the recipients GDPR policies
   
• Child Safeguarding Concerns: In the unlikely event JSSOD has a safeguarding concern in relation to one of its students, JSSOD are legally required to provide data to the safeguarding board at the local council. JSSOD are satisfied that their GDPR processes are thorough and any data will be stored in a secure environment and not unnecessarily retained

Rights of the data subject and JSSOD compliance with response:

Any data subject with personal data stored within JSSOD is entitled to the rights of:

• Access – The right of access does not apply to JSSOD’s legal obligations such as confidential Child Safeguarding records
   
• Rectification – JSSOD will respond to a rectification without undue delay and within one month of receipt. The right of rectification does not apply to JSSOD’s legal obligations such as payment record information
   
• Erasure – JSSOD will ensure that we respond to an erasure request without delay and within one month of receipt. The right to erasure does not apply to JSSOD’s legal obligations such as payment record information and First Aid records
   
• Restrict Processing - JSSOD will ensure that we respond to an erasure request without delay and within one month of receipt. Due to our legitimate interest and legal obligations in most of the data collected we may not be able to restrict processing
   
• Data Portability – JSSOD 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 JSSOD’s legal obligations
   
• Objection - JSSOD 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

How long we retain your data:

Data is retained for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal and financial requirements. All personal data except accountancy and first aid records will be securely deleted/destroyed/shredded according to Government Guidelines after the student leaves the school or after 6 years.

Complaints and Data Breeches:

Complaints: In regard to the handling of any personal data can be made directly to JSSOD Principals: Miss Amy Churchill and Miss Anna Henry 

Email: info@jillstewdance.co.uk

Telephone: 01993 706352

Address: The Jill Stew School of Dance, Stonesteps, Bridge Street Mill, Witney, Oxon, OX28 1YH

Data Breeches: If JSSOD experiences a data breech of any kind, we have a legal obligation to report this to the Independent Commissioner’s Office (ICO) within 72 hours. JSSOD will inform all the victims of the data breech as soon as possible if there is a high risk of adversely affecting individuals’ rights and freedom. JSSOD will store and record all data breeches.