General Data Protection Regulation 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 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. Campbell School of Dance & Drama 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
The Campbell School of Dance & Drama is registered with the Imperial Society of Teachers in Dance (ISTD) and as so, is required to collect and manage certain data. The school collects parent's and or guardian's names, addresses, emergency telephone numbers and email addresses. We also collect children's' full names, addresses, date of birth along with any SEN requirements and are stored via in a secure electronic system and paper registration forms are stored in a secured cabinet at the Principal's home address.
This is in respect of our Health and Safety and Safeguarding Policies.
As an Employer of self employed practitioners, The Campbell School of Dance & Drama is required to hold data on its Teachers such as names, addresses, email addresses, telephone numbers and bank details. Information such as Disclosure and Barring Service checks (DBS), personal Public Liability insurance, First Aid Certificate's, Membership details and any qualification's. This information stored via a secure electronic system and paper forms are stored in a secured cabinet at the Principal's home address.
2) The right of access
At any point an individual can make a request relating to their data and Campbell School of Dance & Drama will need to provide a response (within 1 month). Campbell School of Dance & Drama 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.
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 Campbell School of Dance & Drama has a legal duty to keep children’s and parents details for a reasonable time*, Campbell School of Dance & Drama may retain these records for 6 years. Staff records must be kept for 6 years after the member 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 Campbell School of Dance & Drama processing their data. This means that records can be stored but must not be used in any way, for example reports or for communications.
5) The right to data portability
Campbell School of Dance & Drama requires data to be transferred from one IT system to another; such as from Campbell School of Dance & Drama to the Local Authority, for performance 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. Campbell School of Dance & Drama does not use personal data for such purposes.
Storage and use of personal information
All electronic copies of children’s and staff records are kept on a password protected Laptop on Campbell School of Dance & Drama password protected system. 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 Campbell School of Dance & Drama password protected Laptop at all times. These records are deleted after the retention period.
Information about individual children is used in certain documents, such as, a weekly register, medication forms, referrals to external agencies and disclosure forms. These documents include data such as children’s names, date of birth and sometimes address. These records are deleted after the relevant retention period.
Campbell School of Dance & Drama collects a large amount of personal data every year including; names and addresses of those on the trial list. These records are deleted if the child does not attend or added to the child’s file and stored appropriately.
Campbell School of Dance & Drama stores personal data held visually in photographs or video clips or as sound recordings, unless written consent has been obtained via the Registration Form. No full names are stored with images in photo albums, displays, on the website or on Campbell School of Dance & Drama's social media sites.
Access to all Office computers/laptops 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 filing cabinet.
GDPR means that Campbell School of Dance & Drama 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 issued by the Principal Claire Cain, of Campbell School of Dance & Drama in May 2018.
Policy review date: September 2018