General Data Protection Regulation Policy
Statement
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. Victoria’s Dance Academy 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.
Miss Victoria Louise Keast is registered with the ICO (Information Commissioners Office) under registration reference: ZA371998. Her certificate can be viewed upon request.
GDPR includes 7 rights for individuals
- The right to be informed
Victoria’s Dance Academy is a registered dance school with the Royal Academy of Dance and the Imperial Society of Teachers of Dancing and as so, is required to collect and manage certain data. We need to know parent’s names and telephone numbers. We need to know children’s’ full names, date of birth and Education school, along with any SEN requirements or relevant illnesses/allergies. When organising performances we are requested to provide this data to Cornwall County Council. This information is sent to the Local Authority via email.
We are required to collect certain details of visitors to our dance schools. We need to know visits names, telephone numbers, and where appropriate company name. This is in respect of our Health and Safety and Safeguarding Policies.
Victoria’s Dance Academy uses basic Cookies on its website for the basic running of the site, but nothing that uses personal data of any kind or that is sent elsewhere.
2) The right of access
At any point an individual can make a request relating to their data and Victoria’s Dance Academy will need to provide a response (within 1 month). Victoria’s Dance Academy 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 Victoria’s Dance Academy has a legal duty to keep children’s and parents details for a reasonable time, Victoria’s Dance Academy retain these records for 3 years after leaving pre-school, children’s accident and injury records for 19 years (or until the child reaches 21 years), and 22 years (or until the child reaches 24 years) for Child Protection records. 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 Victoria’s Dance Academy 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
Victoria’s Dance Academy requires data to be transferred from one IT system to another; such as from Victoria’s Dance Academy to the Local Authority, for performance BOPA licences, and dance associations for examinations. 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. Victoria’s Dance Academy 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 cupboard in Victoria’s Dance Academy studio at Falmouth School. Members of staff can have access to these files but information taken from the files about individual children is confidential and apart from archiving, these records remain on site at all times. 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 and sometimes education school. These records are shredded after the relevant retention period.
Victoria’s Dance Academy collects a large amount of personal data every year including; names and phone numbers 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.
Information regarding families’ involvement with other agencies is stored in paper format, this information is kept in a locked filing cabinet on Victoria’s Dance Academy, Falmouth School. These records are shredded after the relevant retention period.
Victoria’s Dance Academy doesn’t store personal data held visually in photographs or video clips or as sound recordings, unless written consent has been obtained via the Model Release form/fit to Perform agreement form. No names are stored with images in photo albums, displays, on the website or on Victoria’s Dance Academy social media sites.
Access to Victoria’s Dance Academy’s computers is password protected, only Victoria Keast has access to this. 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.
GDPR means that Victoria’s Dance Academy must;
* 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
Policy composed by Victoria Keast, Principal of Victoria’s Dance Academy, May 2018
Policy review date: September 2018