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 requires that there is a clear legal basis for collecting and processing personal information. In general CSDTA relies on the individual’s consent in order to collect and process their data. Where there are exceptions such as a legal obligation, contractual agreement or CSDTA’s legitimate interest, they will be noted below.
We obtain information about you when you use our website contact form, fill in our registration form, send us an email, call us on the telephone or send us information through the post.
Dance teachers that are involved with CSDTA:
Dance Teachers will be required to complete an acceptance form which provides details of name, address, email & telephone number, qualifications, DBS clearance, First Aid readiness. This information is kept by CSDTA to enable correspondence and communication and to ensure that teachers are appropriately prepared and qualified o teach.
Dance teachers can at any time request in writing for this information to be deleted from CSDTA records but those doing this would then not automatically be invited to teach at future classes or events.
All students – personal and emergency contact numbers
All students aged 16 and over and the parents of those aged under 16 are required to provide emergency contact telephone numbers and details of any known relevant allergies / medical conditions before taking classes of any kind with CSDTA. This information is not required or included in the BOPA that is passed onto the local authority but is for the purpose of safeguarding whilst in the studio or premises hired by CSDTA for lessons, rehearsals and performances. Parents or students over the age of 16 can at any time request in writing for this information to be deleted from CSDTA records but those doing this would then for safety reasons not be permitted to take part in any future classes or events.
Students over 16 years of age will also be required to complete a registration form which provides details of name, address and email This information is kept by CSDTA to enable correspondence about schedule changes, costume requirements and to inform students of performances and examinations. Telephone numbers collected will be used for communication through WhatsApp which is securely encrypted or by SMS / call. Students or their parents can at any time request in writing for this information to be deleted from CSDTA records but students or parents doing this would then not automatically be informed of changes to class schedules or invited to future events.
Children aged 16yrs and under:
Parents will be required to complete a registration form which provides details of name, address, email & telephone number, school attended, borough to which they pay council tax (for performance licence applications) and emergency contact number. This information is kept by CSDTA to enable correspondence leading up to performances and examinations. Parents’ telephone numbers will be used for communication through WhatsApp which is securely encrypted or by SMS / call. Parents can at any time request in writing for this information to be deleted from CSDTA records but parents doing this would then not automatically be informed of changes to class schedules or invited to future events.
When staging a performance CSDTA is required by law to apply for a Body of Persons Authorisation (BOPA) from the local authority to the venue of the performance under s.37 Children & Young Persons Act 1963. CSDTA has to complete a local authority spreadsheet which requires the following data – child’s name, date of birth, post code, area where child is living and authority to which council tax is paid. This information is securely passed onto the local authority for them to approve whether the performance can take place. CSDTA will always send data to the local authority using their encrypted channels.
CSDTA is also required under the BOPA to retain this information for 6 months from the date of the performance after which CSDTA will securely destroy the information it holds on children under 16yrs.
School Chaperones at performance venues (rehearsal & performance)
Under the BOPA CSDTA has to collect information of licensed chaperones’ name and expiry date of license on the same spreadsheet as the information supplied about all performers. This information held by CSDTA will also be securely destroyed after 6mths from the date of the performance. Any additional DBS holding assistants will be required to provide name, DBS number and issue date. This information held by CSDTA will also be securely destroyed after 6 months from the date of the performance.
HOW IS YOUR DATA USED?
We may use your information to:
- carry out our obligations arising from any contracts or agreements entered into by you and CSDTA
- seek your feedback on the services we provide
- notify you of relevant changes to our services
- send you communications which you have requested and that may be of interest to you for legitimate business purposes
- process an employment application or support an application for a chaperone licence
- enter you / your child for examinations at which time information approved by you will be passed to the National Assciation of Teachers of Dancing (NATD)
- as described above: notify local authorities as required by law that a member or members of CSDTA are participating in a performance and / or apply for Body of Persons Exemption.
At no time will this data be shared or sold to a third party or used for marketing purposes. However, in addition to sharing the above data with the local authority under their BOPA regulations, CSDTA also shares details of students as given on the original registration or show permission form with the officially appointed photographer and official DVD filming company for each show to enable students / parents means of communication with the company in order to view / purchase photographs and DVDs.
We collect and hold information to administer the taking of qualifications and issuing of certificates to successful candidates. We will hold the certificate information until the next annual award evening when certificates are issued and become the responsibility of the parent / guardian. We will hold a record of examinations taken and qualifications achieved until you / your child leaves the school after giving the required notice.
Unique Learner Numbers
Where a candidate supplies their unique learner number (ULN) we will pass this on to the NATD, AQA or other awarding body to enable details of their qualification to be communicated to the Learning Records Service to form part of the candidate’s Personal Learning Record. See
We will pass to the NATD personal information supplied for Reasonable Adjustment of an examination. This information will be passed to an examiner for use at the examination. The records will be kept for 12 months and then deleted. For more details see the NATD website.
HOW WE PROTECT YOUR DATA
When you give us personal information we take steps to ensure that it’s treated securely. All electronic information you provide CSDTA is kept confidential on encrypted and/or password protected hard drives and is only accessible by relevant members of CSDTA who require access to undertake their role. All confidential paperwork is kept in a lockable filing cabinet. The cabinet is located in an office which is locked overnight and to which only the CSDTA team have access.
Non – sensitive data may be communicated over the internet which can never be guaranteed to be 100% secure. As a result we cannot guarantee the security of any information you transmit to us and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
Going forward, all personal data exchanged between CSDTA and students / parents will be sent securely in one of the following ways:
- WhatsApp is a free end – to end encrypted form of social media. New members telephone numbers are added, with consent, to the appropriate groups for all their selected activities so that they can be notified of relevant events, changes to class schedules, uniform requirements etc.
- Email – if an email address is provided we assume consent to use it for administrative purposes (e.g. notification of fees, relevant events, examination sessions, etc.). We may use it to notify you of forthcoming events which will be of interest to you / your child. CSDTA will take particular care over email addresses which in addition to the GDPR are subject to the Privacy and Electronic Communication Regulations (PECR).
- Via a pass-worded document (password provided by CSDTA)
- Via postal service (where a physical signature is required)
We will not contact you for marketing purposes by email, phone, WhatsApp or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted.
USE OF DATA PROCESSORS
Third Party Service Providers work on our behalf. We may pass your information to our third-party service providers, agents subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties beyond the CSDTA network for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime. 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 data processors:
When sending letters we will share your postal address with the delivery service (normally Royal Mail).
We use a third party service, One.Com to host our website. One.Com are contractually obliged to treat any information on our private website as confidential and only use such information for the purpose of providing CSDTA with web hosting.
We use a third part service, Dance Studio Pro, to host our electronic registers. Dance Studio Pro are contractually obliged to treat any information on our private registration area as confidential and only use such information for the purpose of providing CSDTA with electronic registers and records.
LINKS TO OTHER WEBSITES
TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy. Currently our servers are located within the European Union and the United States (covered under the EU-U.S Privacy Shield Framework).
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
CSDTA will use images taken by official photographers and by the teacher in class for its advertising either in programmes, flyers, in social media or on the CSDTA website. Permission for this is given by students / parents in the registration form.
Video footage of new work or dance pieces will be shared with other parents / students via the appropriate WhatsApp group for the purpose of informing and enabling students to rehearse at home. . Permission for this is given by students / parents in the registration form.
The annual show and other performances will be video – recorded and will be available to all students and their parents. . Permission for this is given by students / parents in the registration form.
The legislation conveys various individual rights. These include the following:
- The right to be informed
- The right of access
- The right to rectification
- 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.
You therefore have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about CSDTA classes, event and services, then you can select your choices by ticking the relevant boxes on our website contact form / registration form on which we collect your information.
You can change your preferences at any time by contacting us by email: email@example.com or telephone on 07956 296376.
COMPLAINTS OR QUERIES
CSDTA tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
If you want to make a complaint about the way we have processed your personal information, please contact us in writing to the address provided below.
ACCESS TO INFORMATION ABOUT YOU
The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or any of the other information we hold is inaccurate or out of date, please let us know and we will correct our records.
You have the right to ask for a copy of the information CSDTA holds about you. This is formally known as a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:
- give you a description of it.
- tell you why we are holding it.
- tell you who it could be disclosed to.
- let you have a copy of the information in an intelligible form.
To make a request to CSDTA for any personal information we may hold you need to put the request in writing to the address provided below.
DISCLOSURE OF PERSONAL INFORMATION
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. In this case CSDTA will rely on consent and/or legal and/or legitimate interest as the legal basis for holding and sharing this information
HOW TO CONTACT US
Contact us in writing at: Data Protection, Frances Cooper Ltd trading as CSDTA, 24 Cherry Orchard Road, Bromley, Kent BR2 8NE
Or by email at: firstname.lastname@example.org
Or by telephone at: 07956 296376
Review of these policies: CSDTA keep this policy under regular review. This Policy was last updated in May 2018.