Data Protection Policy
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. KD Dance Ltd 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
KD Dance Ltd is a registered Performing Arts provider with the ISTD and Acrobatic Arts Associations 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 medical or SEN requirements.
We are required to collect certain details of visitors to our Performing Arts School. We need to know Visitors names, telephone numbers, and where appropriate company name. This is in respect of our Health and Safety and Safeguarding Policies.
As an employer KD Dance Ltd is required to hold data on its Teachers; names, addresses, email addresses, telephone numbers, date of birth, Social Security and Income Tax 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 island.
2) The right of access
At any point an individual can make a request relating to their data and KD Dance will need to provide a response (within 1 month). KD Dance Ltd 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 Guernsey Data Protection Office, 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, KD Dance Ltd has a legal duty to keep children’s and parents details for a reasonable time, KD Dance Ltd retain 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 staff 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 KD Dance Ltd 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
KD Dance Ltd requires data to be transferred from one IT system to another; such as from KD Dance 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. KD Dance Ltd 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 filing cabinet at KD Dance Ltd, Pernera, Maladerie Road, St. Sampsons. 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. All information is transported from KD Dance Ltd at Capelles Community Centre to the Office at Pernera, Maladerie Road, St. Sampson in a locked bag.
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 shredded after the relevant retention period.
KD Dance Ltd collects a large amount of personal data every year including; names and addresses of those on the waiting list. These records are shredded if the child does not attend or added to the child’s file and stored appropriately.
KD Dance Ltd stores personal data held visually in photographs or video clips or as sound recordings. Unless prior consent has been obtained, no full names are stored with images in photo albums, displays, on the website or on KD Dance Ltd 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 filing cabinet.
GDPR means that KD Dance Ltd 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 document was updated at meeting at KD Dance Ltd on 20th May 2018.
Policy Review Date: May 2019