Privacy and GDRP Policy

INTRODUCTION

LWTS is committed to protecting your (including any dependents’) personal information.  We are dedicated to providing a safe environment for all our customers, casual and freelance workers and everybody who comes into contact with us, both physically and virtually (online).  This Privacy Statement relates to the use of any personal information provided to us online or via application forms, telephone, email exchange, letters or correspondence.

Whenever you provide such information, we are legally obliged to use your information in line with current legislation concerning the protection of personal information, including the General Data Protection Regulations (GDPR) and UK Data Protection Act 2018.

The LWTS website contains hyperlinks to websites owned and operated by third parties, such as Crazy Aunt and Dancers World.  These third-party websites have their privacy policies and are also likely to use cookies, and we therefore urge you to review them.  We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.

DATA PROTECTION PRINCIPLES

The legislation sets out various data protection principles. These include personal and that information is:

 YOUR RIGHTS

The legislation conveys various individual rights. These include the following:

WHAT INFORMATION DOES LWTS HAVE ABOUT ME?

The legislation requires that there is a clear legal basis for processing personal information. In general, LWTS relies on the individual’s consent to process their data.

When you participate in or sign up for any of LWTS classes, activities, workshops, or performances, we may collect and store personal information about you. Depending on how you are engaging with us, this can consist of information such as:

Your Name; Email address; Postal address; Telephone or mobile number; Date of birth; Medical conditions (within reason); Contact preferences; Emergency contact details; Your child’s details – name, age, dob, address, medical/health needs, school attended and emergency contact details.

By submitting your details, you enable us to provide you with the information regarding the services that you have selected and provide a safe teaching environment.

When taking pictures or filming classes, performances, workshops etc, LWTS asks for permission from those present and asks for parental consent for children. LWTS may use the images or footage resulting from the photography/video filming, and any reproductions or adaptions of the images for publicity, marketing, promotion, fundraising or other purposes to help achieve the group’s aims. This might include (but is not limited to) the right to use them in printed and online publicity, show programmes, social media forums and press releases.

WHAT ARE COOKIES?

Cookies are text files that websites place on your computer to store information specific to you. Our website uses cookies, please refer to our Cookie Scan Report for further information on our cookies. Appendix A (in full parent handbook)

HOW WILL WE USE YOUR INFORMATION?

We will use your information for several purposes including: 

• To provide you with information about our products, services and activities and to deal with your requests and enquiries, including complaints.
• For “service administration purposes”, which means that we may contact you for reasons related to the service or activity you signed up for (e.g. invoices, or change of details regarding a class your child attends)
• To contact you about an application you have made, to process your application and where applicable the implementation of the application, for example becoming a teacher of LWTS.
• To complete, send or post any relevant examination documents.
• Weekly registers, medication and health forms.

All documents are shredded after the relevant retention period.

LWTS stores personal data held visually in photographs or video clips or as sound recordings. Consent is obtained upon registration via Class Manager and parents are always asked to give written consent via our ‘Registration and Consent Form’ if performing. No names are stored with images in photo albums or displays on the website or LWTS social media platforms. A child’s name will only be mentioned with parental consent and in the instance of exam results, school achievements and performance literature i.e. programmes.

Access to the LWTS computer and Class Manager database is password protected. When a teacher leaves LWTS their access to such databases is removed, in line with our Safeguarding Policy.

Any portable data storage used to store personal data e.g., a memory stick is password protected and stored in a locked filing cabinet.

As and when we need to use your personal information for reasons other than the ones specified above, we will ensure that we notify you first. You will be allowed to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above. LWTS does not share your personal information with any third parties for marketing purposes. We do not sell your data, and neither do we buy data from third parties.

USE OF DATA PROCESSORS

Data processors are third parties who provide services for us and we have contracts in place with ours. This means they cannot do anything with your personal information. They will not share your personal information with any organisation apart from us. They hold it securely and retain it for the period we instruct. All data processors must comply with current GDPR regulations and legislation. We do not transfer any personal data to countries outside of the European Economic Area (EEA).

The following is a list of our main data processors.Website Hosting

We use a third-party service WordPress to host our website. WordPress is contractually obliged to treat any information on our private website as confidential and only use the information to provide LWTS with web hosting. For more information, please visit https://automattic.com/privacy/ Web designer http://www.jpink.co.uk/

PARENTS

We use a third-party service, Class Manager software to store your and your child’s information and use it for administrative purposes such as new registrations, class registers, emailing and invoicing customers. All payments are via BACS. For further information please visit https://classmanager.com/privacy/  https://classmanager.com/gdpr/

LWTS may contact you about any service or activity you have signed up for to ensure that we can deliver the services to you, to remind you of important deadlines, deal with any correspondence we receive from you and any comment or complaint you make about our services, and to occasionally market products or services that we think may be of interest to you. We will not hold more information than is required and will ensure all personal data is kept up to date and used only for its specific purpose(s).

WHAT IF I DO NOT WANT DATA STORED OR TO BE CONTACTED REGARDING PRODUCTS, SERVICES OR EVENTS?

You have the right to ask us not to hold or use personal data however this would mean we may not be able to provide you with the full range of services available. You may opt out of any personal data being stored and must give consent to any correspondence you wish to receive from LWTS. Should you decide to opt out of any data storage you must:

• Stay on the premises during all classes in case of an emergency. Your child will not be able to be entered for any examinations or participate in any productions as we will not be able to process the appropriate candidate information and safeguarding procedures.

Please note consent is not required for us to email regarding the class you are enrolled in (invoices, updates, cancellations etc) or regarding any enquiries you may have contacted the school about as these fall under legitimate interest (please see next point).

LEGITIMATE INTEREST

We may hold or use personal data on the grounds of ‘legitimate interest’. In simple terms, this means we can process personal information if we have a genuine and legitimate reason, and we are not harming any of your rights and interests. This includes information we are legally required to store even after a request to be forgotten. Names and postal addresses related to invoices (MUST be kept as it is required for HMRC legal tax purposes). Medical information is sensitive data and held on the grounds of legitimate interest. This data will only be processed and stored by LWTS when completely relevant to ensure your or your child’s safety whilst participating in our services or activities. This data will be erased after a request to be forgotten, or at any time if it becomes irrelevant.

 YOUNG PEOPLE

If you are under 18 and you provide us with information on an application form (online or printed), your parent(s)/guardian(s) permission will be required.

TAKING, STORING AND USING IMAGES OF STUDENTS

Certain uses of images are necessary for publicising and updating other parents of LWTS services and activities. Parental consent is always required before any photograph can be taken, stored or used and all are given the option to give consent for the school to take still or moving images and to use them in terms of marketing the school on:

Our website; Facebook; Instagram; Flyers and Posters; Twitter; TikTok; LinkedIn; Or internally for progress tracking.

If consent is given for a still or moving image of your child to be used for any of the external marketing purposes, please be informed that these are public domains and can be viewed by anyone. Should an image be used in any marketing publication, website, or social media site there will be no use of names alongside images other than in special circumstances (such as further dance studies, or other achievements). In these very special cases, parental consent will be asked. Any images are only taken on devices belonging to the school and stored by LWTS electronically on a secure computer system and phone. Any folder containing stored images has restricted access and is held in password-protected folders. At any time, consent can be withdrawn to the taking, storing or use of images by contacting info@lwtheatreschool.co.uk

HOW LONG WILL LWTS KEEP MY PERSONAL INFORMATION?

We use secure technologies to help protect your personal information from unauthorised access, and use of disclosure. As advised, we store the personal information you provide on computer systems, which have carefully controlled access, and which are located in secure facilities.

We keep the information we hold about our customers and students for as long as is necessary to deliver the services we are providing you with. If your child has completed any National Association of Teachers of Dancing examinations or LAMDA whilst at the school, we will store all exam results. This will include your child’s name, ID number (as appointed by the NATD and LAMDA examinations board), date of any exam(s) and your child’s result. This data will also be stored securely.

The security measures described above ensure that all reasonable steps are taken to protect your personal information. However, the nature of the Internet means that a guarantee of security cannot be offered and as with all Internet transactions, you should be aware that there may be a small security risk when disclosing information online.

WHERE IS THE INFORMATION STORED? AND HOW IS IT PROTECTED?

LWTS uses a variety of procedures and secure technologies to help protect your personal information from unauthorised access, use or disclosure. We store the personal information you provide to us on a secure, password-protected database, only accessed on our secure computer system, and by app on secured mobile devices all of which have controlled access. Data is stored on services provided by trusted third-party providers, as outlined above, which we have entered into data processing agreements. Your information will not be shared with any other service providers or organisations apart from us. All data will only be used for the agreed purpose relating to the service that they are providing.

YOUR RIGHTS

When asked to submit personal data for enrolment purposes there are several details expected for you to register with Class Manager to provide you with services from LWTS. You have the right to change your preferences or opt out of consent at any time by contacting info@lwtheatreschool.co.uk.  The accuracy of your data is important to us, and you hold the right to update any information held by us. Please help us keep our data records up to date by notifying us of any changes.  Under the General Data Protection Regulation, you have the right to request full access to any personal information held about you, if you wish to make a Data Access Request or if you would like to request the right for LWTS to delete any personal data stored about you, please contact the email above. You must describe what information you wish to see alongside proof of identity. If you ask for data to be removed, please note we may have a lawful reason to hold or use personal data which does not require consent, such as on the grounds of legitimate interest. In this case, we will keep the minimum amount of information required to ensure we adhere to your request.

LEGAL OBLIGATION

We may disclose your personal information to government agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court orders or official request.

This policy was updated March 2024, the next review will occur in March 2025.

Louise Wright; LWTS Owner and Principle         Tel: 07900992803     Email: info@lwtheatreschool.co.uk

GDRP Policy

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 came into effect on 25^th May 2018.

GDPR states that personal data should be ‘processed fairly and lawfully’ and ‘collected for specific, explicit, and legitimate purposes and that individual’s data is not processed without their knowledge and is only processed with their explicit consent. GDRP covers personal data relating to individuals.

LWTS is committed to protecting the rights and freedoms of individuals with respect to the processing of children’s, parents, clients, visitors and staff personal data.

The Data Protection Act gives individuals the right to know what information is held about them. It provides the framework to ensure that personal information is handled properly.

LWTS is registered with the Information Commissioners Office Company Number: 12787019

GDPR INCLUDES 7 RIGHTS FOR INDIVIDUALS

The Right to be Informed

LWTS is required to collect and manage certain data. We need to know the parent’s names, addresses, telephone numbers, email addresses and emergency contact details. We need to know the children’s full names, addresses, and date of birth along with any SEN or medical requirements.

We are required to collect certain details of visitors and chaperones to our school. We need to know visitors’ names, telephone numbers, and where appropriate company names. This is in respect of our Health and Safety and Safeguarding Policies.

Although our teachers are freelance/self-employed, LWTS is required to hold data on its teacher’s names, addresses, email addresses, telephone numbers, date of birth, national insurance numbers, bank details and in some cases photographic ID such as passport and driver’s licence. Copies of teacher’s Disclosure and Barring Service (DBS) certificates are stored securely in a locked cabinet.

 The Right of Access

At any point, an individual can make a request relating to their data and LWTS will need to respond within 1 month. LWTS can refuse a request, or if we have a lawful obligation to retain data, we will inform the individual of the reasons for the rejection. The individual will have the right to complain to the Information Commissioners Office if they are not happy with the decision.

The Right to Erasure

You have the right to request deletion of your data where there is no compelling reason for its continued use. However, LWTS has a legal duty to keep children’s and parent’s details for a reasonable time of up to 3 years after leaving the 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.

Teachers’ records must be kept for 6 years after the teacher leaves before they can be erased. This data is archived securely and shredded after the legal retention period.

The Right to Restrict Processing

Parents, visitors, clients, and staff can object to LWTS processing their data. This means that records can be stored but must not be used in any way, for example reports or communications.

The Right to Data Portability

LWTS requires data to be transferred from one IT system to another, such as child licence applications to the local authority for performances. These recipients use secure file transfer systems and have their policies and procedures in place concerning GDPR.

The Right to Object

Parents, visitors and clients can object to their data being used for certain activities like marketing or research.

The Right Not to be subject to Automated Decision-Making Including Profiling

Automated decisions and profiling are used for marketing-based organisations. LWTS does not use personal data for such purposes.

This policy was updated in March 2024 on behalf of LWTS by:

Louise Wright

LW Theatre School Owner and Principle

Tel: 07900992803

Email: info@lwtheatreschool.co.uk

This document’s next review is due March 2025

If any substantial changes are updated that affect your rights will be communicated directly to you as far as reasonably practical.