Emma Louise Dance Club (ELDC) is fully committed to comply with the General Data Protection Regulation (GDPR). The GDPR applies to all organisations and sole traders that process data relating to their employees, as well as to others including customers, contractors and clients. It sets out principles which should be followed by those who process data; it gives new and extended rights to those whose data is being processed.
To this end, ELDC endorse fully and adhere to the six principles of data protection, as set out in the Article 5 of the GDPR. 1. Data must be processed lawfully, fairly and in a transparent manner in relation to individuals. 2. Data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. 3. Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 4. Data must be 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. Data must be 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. 6. Data must be 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.
These principles must be followed at all times when processing or using personal information. Therefore, through appropriate management and application of processes and controls ELDC will: • observe the conditions regarding the collection and use of information including the giving of consent • meet the legal obligations to specify the purposes for which information is used • collect and process appropriate information only to the extent that it is needed to fulfil my operational needs • ensure the quality of information used • ensure that the information is held for no longer than is necessary • ensure that the rights of people about whom information is held can be fully exercised under the GDPR (i.e. the right to be informed that processing is being undertaken, to access one’s personal information; to prevent processing in certain circumstances, and to correct, rectify, block or erase information that is regarded as incorrect) • take appropriate security measures to safeguard personal information • publicise and abide by individuals' right to appeal or complain to the supervisory authority (the Information Commissioner's Office (ICO)) in the event that agreement cannot be reached in a dispute regarding data protection • ensure that personal information is not shared or transferred abroad without prior written consent
Data Security ELDC will ensure that: • personal data is kept securely • personal information is not disclosed either orally or in writing or via Web pages or by any other means, accidentally or otherwise, to any unauthorised third party.
Subject Consent The GDPR sets a high standard for consent and requires a positive opt-in. Neither pre-ticked boxes nor any other method of default consent are allowed. As required by the GDPR, ELDC take a "granular" approach i.e. we ask for separate consent for separate items and will not use vague or blanket requests for consent. As well as keeping evidence of any consent, ELDC ensure that people can easily withdraw consent (and tell them how this can be done).
Note that the GDPR provides for special protection for children’s personal data and ELDC comply with the requirement to obtain parental or guardian consent for any data processing activity involving anyone under the age of 13.
This policy sets out ELDC's commitment to protecting personal data and how that commitment is implemented in respect of the collection and use of personal data.
GDPR Data Processing Outline - Data subject: Participant (13 and over)
Lawful basis for collecting, storing and processing data: Individual Consent
Special category data: Disability/Health
Lawful basis detail: The individual has consented to receiving updates about a class/es and for their personal data to be stored so that as a teacher I can stay informed about any health or wider needs that participants have that I need to consider whilst delivering the class/es.
Action taken to inform data subjects: Individuals are provided with a ‘Participants privacy notice’
Data management: Contact ceased 6 months after individual has stopped attending the class/es. All personal data not linked to financial records deleted/destroyed at this point.
GDPR Data Processing Outline - Data subject: Participant (12 and under)
Lawful basis for collecting, storing and processing data: Parental/guardian consent
Special Category Data: Disability/Health
Data Lawful basis detail: The individual’s parent or guardian has consented to receiving updates about a class/es and for their child’s personal data to be stored so that as a teacher I can stay informed about any health or wider needs that participants have that I need to consider whilst delivering the class/es.
Action taken to inform data subjects: Parent/guardian provided with a ‘Participants privacy notice’
Data Management: Contact ceased 6 months after individual has stopped attending the class/es. All personal data not linked to financial records deleted/destroyed at this point.
Your personal data and your membership As an attendee of ELDC classes, we collect, store and use the personal data that you provide us. ELDC does this so that we can effectively manage our classes and ensure that as a participant you are kept informed and safe. ELDC may use your data to contact you with class updates and wider dance related opportunities we think you may be interested in. ELDC will use your data to keep us informed about any health or wider needs you have that ELDC needs to consider whilst delivering your class/es. If you have provided ELDC with emergency contact details we will use this data when required. Some of the data that we collect from you is ‘specialist category’. This includes (not exhaustively) any data relating to disabilities and health. ELDC collects and uses this data to enable us to tailor activities to your needs.
Unless you have given us separate written consent, ELDC will cease to contact you 6 months after your stop attending ELDC class/es. At this point ELDC will also delete/destroy all personal data that is not linked to financial records. ELDC will store any personal data linked to financial records for a 6-year period. HM Revenue and Customs (HMRC) have the right to inspect financial information relating to the previous 6 years and require all trading entities to keep financial records for this length of time.
ELDC will not share your personal data. All data you provide to ELDC is stored on a password protected device and/or locked away. The only exception to this rule is when ELDC teachers carry paper copies of your personal data to the class/es that you attend. We must do this so that we have your health needs and emergency contact details to hand should they be required.
You may request details of personal data which ELDC holds about you or withdraw your consent at any time. You can contact ELDC on 07977 447215 or firstname.lastname@example.org. If you have any concerns about ELDC information rights practices you can raise them here www.ico.org.uk/concerns or by calling 03031231113.
Mrs Emma Louise Abel (Principal) [Updated 12th August 2018]
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