Data Protection

More information on the rights of individuals under the General Data Protection Regulation (GDPR) is available form the Information Commissioner’s Office at https://ico.org.uk/your-data-matters/

 

Renton Dance Studio is registrered with the ICO (Reference ZA473830)

Data Protection Policy - 9 November 2018

 

Definitions

Studio

means Renton Dance Studio.

GDPR

means the General Data Protection Regulation.

Responsible Person

means Mrs Senta Renton.

Register of Systems

means a register of all systems or contexts in which personal data is processed by the Studio.

 

1. Data protection principles

The Studio is committed to processing data in accordance with its responsibilities under the GDPR. 

 

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions

  1. This policy applies to all personal data relating to dancers, parents and guardians, teachers and adminitration staff and visitors to the Studio.
  2. Information collected may include full name, date of birth, home address, telephone numbers, email addresses, photographic ID (in the case of staff), medical conditions and General Practitioner contact details.
  3. Data is processed by the Studio for the purposes of maintaining a register of classes, entry for examination, competition or performances, payroll and invoicing.
  4. The Responsible Person shall take responsibility for the Studio’s ongoing compliance with this policy. 
  5. This policy shall be reviewed at least annually. 
  6. The Studio shall register with the Information Commissioner’s Office as an organisation that processes personal data. 

3. Lawful, fair and transparent processing 

  1. To ensure its processing of data is lawful, fair and transparent, the Studio shall maintain a Register of Systems. 
  2. The Register of Systems shall be reviewed at least annually. 
  3. Individuals have the right to access their personal data and any such requests made to the Studio shall be dealt with in a timely manner. 

4. Lawful purposes

  1. All data processed by the Studio shall be done on one or more of the following bases: consent, contract, legal obligation, vital interests, or legitimate interests. 
  2. The Studio shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Studio’s systems.  

5. Data minimisation

  1. The Studio shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 
  2. The Studio shall ensure that personal data is retained no longer than is reasonably required for archiving purposes.

6. Accuracy

  1. The Studio shall take reasonable steps to ensure personal data is accurate. 
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date. 
  3. The Studio shall take reasonable steps to enable requests for data to be updated or removed from registeres systems.

7. Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, the Studio shall conduct a review of data to be removed at the point when an individual ceases thir association with the Studio.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

  1. The Studio shall ensure that personal data is stored securely using modern software that is kept-up-to-date.  
  2. Computer systems holding personal data shall be password protected.
  3. Paper records shall be kept in a locked filing cabinet.
  4. The use of USB memory sticks shall be minimised and all devices shall be encrypted.
  5. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  6. When personal data is deleted this should be done safely such that the data is irrecoverable.
  7. Appropriate back-up and disaster recovery solutions shall be in place. 

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Studio shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO. 

 

10. Futher information

More information on the rights of individuals is available form the Information Commissionaer’s Office or at https://ico.org.uk/your-data-matters/

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