Affinity Dance South Hams is committed to ensuring the data processed by our company remains safe and secure.
This policy has been written in line with legislative change, including both the Data Protection Act (1998) and the EU’s General Data Protection Regulation (GDPR).
The GDPR includes the following rights for individuals:
• the right to be informed
• the right of access
• the right to rectification
• the right to erasure
• the right to restrict processing
• the right to data portability
• the right to object
• the right not to be subject to automated decision-making including profiling
General Principles
Affinity Dance South Hams is committed to providing fair and understandable privacy policies in relation to personal data.
Affinity Dance South Hams is registered as a Data Controller with the Independent Commissioners Office (ICO). The registered Data Protection Officer (DPO) is Faye Preston (faye@affinitydancesouthhams.co.uk).
Affinity Dance South Hams will, at all times, keep data in secure locations (including, but not limited to, encrypted and access restricted files) and not retain data unnecessarily or past the retention length as set out in this policy.
How we collect personal data
Affinity Dance South Hams customers and participants supply their personal data when signing up for classes through our registration form via an online form. This is completed by a parent/guardian or the young person themselves if they are deemed able to do so.
Personal data may also come to us unsolicited via enquiries through our website and to our generic email account.
What data we collect
It is essential to our primary function (providing classes to participants) that we are provided and allowed to process and store the following:
- Participant's Full Name
- Date of Birth
- Home Address
- School/Educational Institution They Attend
- Classes Attended/Price Paid
- Photography/Filming Consent
- Medical Information/History
- Disability Information
- First Aid Consent
- Parent/Guardian Name
- Parent/Guardian Email Address
- Parent/Guardian Emergency Contact Number
In rare circumstances and with further consent we may ask for bank details in order to issue a refund.
Storage/Retention of data
Registers are kept in paper form and on the teacher’s person whilst travelling to and from classes. They are kept safely in organised files and are only taken if absolutely necessary to ensure the safety of the child. Emergency contact telephone numbers are also stored on the teachers work mobile in case of an emergency, which requires password authorisation to obtain. The above paper documents are locked away when not in use. When they are no longer needed or out-dated, they are destroyed thoroughly.
Our standard retention policy (without the data subject’s right to access, rectification and erasure etc.) is 6 months post final attendance.
Exceptions to our retention policy:
• Financial records are kept for 6 years due to legal obligation
• First Aid records are kept for 21 years due to legal obligation
• Photo consent may be kept indefinitely
• Child Safeguarding records are kept indefinitely on a case-by-case basis, the minimum these will stored for is 6 years due to legal obligation
• Bank details are deleted after the action concerning them is complete
• Enquiries that do not turn into bookings with current classes are deleted after they have been dealt with
Third Parties/Data Processors
Affinity Dance South Hams uses a UK registered company, 'Class Manager' for class registers, student information, invoicing and emails.
Data Subjects can opt-out and erase/rectify their record stored with MailChimp at any time.
Affinity Dance South Hams is satisfied that their GDPR regulations are thorough, and the information stored in Class Manager is secure. You can read more about their GDPR compliance here: https://classmanager.com/gdpr/.
Affinity Dance South Hams also uses 'Google Forms' for online documents, including enrolment forms and terms and conditions. Affinity Dance South Hams is satisfied that their GDPR regulations are thorough, and the information stored on Google Forms is secure. You can read more about their GDPR compliance here: https://policies.google.com/privacy?hl=en-GB.
We, Affinity Dance South Hams are taking part in the NHS 'Test and Trace'. If you would prefer to opt out of 'Test and Trace', please notify us in advance of the new term starting, (13th September 2021). We will acknowledge and keep a record of your request.
Child Safeguarding Concerns
In the unlikely event Affinity Dance South Hams has a safeguarding concern in relation to one of our participants, we are legally required to provide data to the safeguarding board at the local council.
Affinity Dance South Hams is satisfied that their GDPR processes are thorough and any data will be stored in a secure environment, and not unnecessarily retained.
Your Rights
Any data subject with personal data stored within Affinity Dance South Hams is entitled to the rights of:
• Access
• Rectification
• Erasure (this does not apply to legal obligations such as First Aid records)
• Restrict Processing
• Data Portability
• Objection
• Rights related to automated decision making including profiling
You may contact us at any time in writing in order to make any of these requests. Affinity Dance South Hams will ensure that we respond to a request without undue delay and within one month of receipt. However, due to our legitimate interest in the data collected, we may have to revoke the participant from our classes depending on the information you wish to restrict/object to us holding. This is due to Health and Safety and Child Safeguarding.
Photos and Videos of Participants
Affinity Dance South Hams often use footage/photos used from performances, classes and workshops for marketing purposes both on our dance website, emails to parents/guardians, social media platforms including Facebook and Instagram and in print media. These will never be shared with any identifying information (age, D.OB etc.). There may be times where we will share first names, but only with the explicit consent of the parent/guardian beforehand.
As part of our registration form, all parents/guardians of the participants are asked for their consent for the participant to be included within this material. Participants/their parent and/or guardians may choose if they do not wish themselves/their child to be depicted.
Some attendees at events may film/take photos for their own personal use (e.g. parents of other participants). We will always verbally remind the audience whether this is possible or not and always ask that where content is allowed, it is not shared on any social media platform. Participants/their parent and/or guardians may choose if they do not wish themselves/their child to be depicted beforehand by contacting Affinity Dance South Hams via email: faye@affinitydancesouthhams.co.uk.
