Data Protection Policy
Flying High Expressive Arts CIC – Data Protection Policy
Flying High Expressive Arts CIC collects, processes, stores information and shares information with regard to its students, parents/guardians, teachers and contacts in order to operate.
From 25th May 2018 the EU General Data Protection Regulation (GDPR) replaces the previous Data Protection Act to better protect individuals’ personal information and to bring legislation in line with the significant digital developments.
Flying High Expressive Arts CIC Data protection procedures have been reviewed and we take seriously our responsibility to meet the requirements of the GDPR. The aim of this policy is to protect the rights of individuals by ensuring that all personal information held is used appropriately and lawfully.
Flying High Expressive Arts CIC is registered with the ICO (Information Commissioner’s Office)
Personal data comes via
Website / Email / social media / telephone / in person.
The Flying High Expressive Arts CIC application form is completed by a parent/guardian in September, at the start of a new academic year, or on becoming a new member of the company at various times throughout the year. Completion of the booking forms signals a parent / guardian's consent for the Company to store information about the member and use it for purposes described below, with notification to parent / guardian via email should they wish to object in any instance. Consent for this storage and usage may be withdrawn at any time.
Information collected on the application form includes:
- Date of Birth
- School and School Year
- Two emergency contact names and numbers
- Email address
- Workshop(s) applied for
- Medical conditions / physical or learning disabilities (if appropriate)
- Permission for photographs to be taken and used for marketing purposes
- Permission to keep information stored until the end of the academic year or when a member leaves
This Information is shared with the members’ workshop leader(s) as or when necessary e.g. in an emergency. Details are also shared with Lamda for exam entry. Parents are contacted for permission to share this information with Lamda prior to their child’s first Lamda exam. (Lamda issue a candidate ID number which remains the same for future exams, we also record this number on our database).
Full names only may be shared on programmes, group lists and registers within the Company with the consent of the parents through the booking form. On social media or other forms of advertising / promotion, first names only will be used and parents may withdraw their consent at any time. .
References, when requested are provided with consent of parent and are made available whenever possible to the student and parent. Child performance licence, chaperone licence, participation in outside events, all require the sharing of personal information with the appropriate authority / organisation and parents are contacted and can withdraw permission at any time.
Information shared on social media is done so in accordance with Flying High Expressive Arts CIC’s safeguarding policy and photography and filming policy.
- Paperwork containing personal information is not left at the centre and is stored in a locked secure location. When transported to/from venues, it is done so securely.
- Computers are password protected and encrypted, as are phones and USB memory sticks. Paperwork is carefully destroyed as soon as appropriate to do so.
- Personal information is deleted from the current school data base a term after a member leaves the company unless it is requested to be kept on file.
- Fee data bases and bank statements are kept as required for accounts for taxation purposes, so kept in an electronic and paper form, for at least 6 years. Only name and fee payment information is retained for this period.
- Secure payments made through the Flying High Expressive Arts CIC’s website (World Pay) result in details of the transaction (name and amount paid only) being held on the website and details of address & email being stored on email. These emails are erased at the end of the payment period (i.e. the end of the term)
- Candidate IDs supplied by Lamda are stored until a member leaves the company or decides not to enter exams and are then deleted and Lamda informed.
- DBS numbers are stored electronically and deleted as soon as appropriate to do so.
- Exam Results are stored in paper and electronic form and kept indefinitely to monitor standards.
- Personal data for contacts such as teachers, artists. performers are stored securely and destroyed as soon as appropriate to do so.
Rights of individuals under GDPR.
- Right to be informed/transparency
Flying High Expressive Arts CIC will endeavour to include notice on all forms explaining how this policy can be accessed to understand how the data will be used.
- Right to object
Individuals may object to using data for marketing purposes or research, on social media, websites, posters. Flying High Expressive Arts CIC has a media consent form with photography and filming policy which allows parents to give and to withdraw consent. Flying High Expressive Arts CIC does not use personal data for marketing or research purposes.
- Right to erasure
Individuals have the right to have personal data erased. This must be requested in writing or via email, and data will, if no longer necessary, be deleted/destroyed.
- Right to restrict processing
Individuals have the right to restrict processing. Data will be stored but not shared or processed any further. Individuals can minimise use of their data, so stored and only processed where really necessary.
- Right to access personal data
This may be to confirm information that is processed, or so they are aware of and can verify the lawfulness of the processing.
- Right to portability
Individual may request their data to use for their own purposes.
Consent (lawful basis for processing data)
As we collect information of a sensitive nature (medical history) consent is the lawful basis by which we process data.
A privacy notice is to be included on all forms used within the company.
All school policies and procedures are reviewed annually, and parents made aware of this.
Policies and procedures are in place for safeguarding.
From age 13 children in the UK are able to give their consent. Therefore we are aware of the need for particular protection for the collecting and processing of children’s data as they may be less aware of the risks involved.
Carrie Bird – Artistic Director / Manager
Policy created - September 2018
Policy to be reviewed annually