Introduction

• General Data Protection Regulation (GDPR) replaces existing UK Data Protection legislation. It was approved by the EU Parliament in 2016 and came into effect from 25^th May 2018.  Specifically, GDPR requires that any personal data held on individuals must be processed fairly and lawfully and collected only for specified, explicit and legitimate purposes and that individuals data is not processed without their knowledge and with consent.
• Dancescene is committed to protecting the rights and freedoms of individuals connected with the school.  GDPR sets out 7 rights for individuals so the purpose of this communication is to set out Dancescene’s position with each of these rights.  In shaping these, we have liaised with other local dance schools and referenced other authoritative bodies such as the Department for Education and industry bodies such as the International Dance Teachers Association (IDTA).

1. The right to be informed

• Our performers - full name, address, date of birth, school attended and details of any medical conditions. We collect this data via the Enrolment Form contained within the Welcome Pack that is provided at the outset.  We use this information for reasons like classes planning, providing updates and dealing with any emergencies that may arise.  In addition, as a registered Performing Arts provider with various industry bodies (e.g. ISTD) it is sometimes necessary to provide some of this data in order to enter examinations, gradings and competitions.  We also provide data to Northamptonshire County Council for performance licensing reasons of for our shows and presentations.
• Our teachers and other staff – names, addresses, telephone numbers, email addresses, bank account details and identity proofs.  This data is necessary to comply with various legal requirements such as the right to live and work in the UK.  For performances, we are required to ensure we have allocated Licensed Chaperones, so we collect names, email addresses, telephone numbers, DBS certificate numbers and Chaperone Licence numbers which we store electronically and are also requested to pass some of this information to local authorities as required (e.g. Northamptonshire County Council) for licensing and compliance reasons.

2. The right of access

• An individual can ask to see the data held on record and Dancescene must provide a response within 1 month of the request.
• Dancescene can refuse this request if it is felt there are lawful reasons not to and these reasons will be explained.
• The individual will then have the right to refer to the Information Commissioners Office (ICO) if they are not happy with the explanation.

3. The right to erasure

• Individuals have the right to request the deletion of data where there is no legal or necessary reason for its continued retention and use, but otherwise Dancescene…
  • Parents and children – there is a legal duty to keep children’s and parents data for a reasonable time.  Dancescene retains records for 3 years after the child left the school but keeps children’s accident and injury data for 19 years (or until the child reaches 21 years of age), and 22 years (or until the child reaches 24 years of age) for Child Protection reasons.
  • Adult performers – data is kept until the end of the school year that the individual left the school.
  • Teachers and staff – data must be kept for 6 years after the individual leaves.
• Data records are archived securely offsite and when the relevant legal retention periods have been reached:
  • Paper – are shredded.
  • Electronic devices -  protected with security passwords and suitable protection software for the duration and are then erased.

4. The right to restrict processing

• Individuals can object to Dancescene processing their data. This means that records can be stored but must not be used I any way – e.g. for communications.

5. The right to data portability

• As outlined in 1 above, Dancescene occasionally needs to transfer data from one media to another (e.g. paper to electronic) and from one system to another (e.g. data extracts to Northamptonshire County Council or to an industry association body).  These third-party recipients use secure file transfer systems and have their own policies and procedures in place in relation to GDPR.

6. The right to object

• Following on from 4 above, individuals can object to their data being used for certain activities – e.g. communications.

7. The right not to be subject to automated decision-making and profiling

• Dancescene does conduct automated decision-making and profiling activities.

 torage and use of personal information

• In summary, GDPR means that Dancescene must:
  • Manage and process individual personal data properly.
  • Protect the individual’s right to privacy.
  • Provide an individual with access to all personal data held on them.
• As our studios are based within Moulton College (so used by other students, teachers, staff and the general public), individual’s information is held securely offsite at the home office of Dancescene’s school principal.
• Dancescene also stores personal data in the forms of photographs, video clips, sound & visual recordings (e.g. DVDs of shows and presentations) and social media sites such as Dancescene’s Facebook page.  Permission for this is requested on the Enrolment form.  No full names are stored with these images.
• Dancescene does not collect or store any information from online purchases of school uniform made via its website.  The site merely showcases the uniform range and facilitates an introduction through to Elite Custom Clothing who supply it.  Any uniform orders are processed directly with them.
• Sophie Carter undertakes the role of Dancescene’s Data Protection Officer.

 f you have any questions, please contact me directly.

 Sophie Carter

Principal