General Data Protection Regulation Policy
Statement – GDPR stands for General Data Protection Regulation and replaces the previous Data Protection.
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. Footlight Performance Academy and Born 2 Perform 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.
GDPR includes 7 rights for individuals
1) The right to be informed
Footlight Performance Academy is a registered Performing Arts provider with Imperial Society of Teacher of Dancing and Royal Academy of Dance and as so, is required to collect and manage certain data. We need to know parent’s names, addresses, telephone numbers, email addresses. We need to know children’s’ full names, addresses, date of birth and Education school, along with any SEN requirements. We are requested to provide this data to Poole County Council, Bournemouth Council & East Dorset Council, and Hampshire County Council and any other performing council areas within our catchments; this information is sent to the Local Authority via a secure
electronic file transfer system.
We are required to collect certain details of visitors to our Stage 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.
As an employer Footlight Performance Academy is required to hold data on its Teachers; names, addresses, email addresses, telephone numbers, date of birth, National Insurance numbers, photographic ID such as passport and driver’s license, bank details. This information is also required for Disclosure and Barring Service checks (DBS) and proof of eligibility to work in the UKThis is required for processing of DBS checks. DBS Numbers and date of issue are also held on a central staffing record.
2) The right of access
At any point an individual can make a request relating to their data and Footlight Performance Academy will need to provide a response (within 1 month). Footlight Performance 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 Footlight Performance Academy has a legal duty to keep children’s and parents details for a reasonable time*, Footlight Performance Academy retain these records for 1 year after leaving 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. Staff records must be kept for 6 years after the member of leaves employment, before they can be erased. 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 Footlight Performance Academy processing their data. This means that records can be stored but must not be used in any way, for example examination applications, reports or for communications.
5) The right to data portability
Footlight Performance Academy requires data to be transferred from one IT system to another; such as from Footlight Performance 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. Footlight Performance 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 office and in a locked filing cabinet in Principals home address. 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. These documents include data such as children’s names, date of birth and an emergency contact number but no addresses. These records are shredded after the relevant retention period.
Footlight Performance Academy collects a large amount of personal data every year including; names and addresses of those on the waiting list. These records are shredded or deleted if the child does not attend or added to the child’s file and stored appropriately.
Footlight Performance Academy stores personal data held visually in photographs or video clips or as sound recordings, No names are stored with images in photo albums, displays, on the website or on Footlight Performance Academy’s social media sites.
Access to all Office computers is password protected. When a member of staff leaves the company these passwords are changed in line with this policy and our Safeguarding policy. Any portable data storage used to store personal data, e.g. USB memory stick, are password protected and/or stored in a locked office and within this office a locked filing cabinet.
GDPR means that Footlight Performance 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.
This Policy was adapted at a meeting at Footlight Performance Academy in April 2018 Signed on behalf of Footlight Performance Academy.
Policy review date: April 2019