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 individual data is not processed without their knowledge and are only processed with their ‘explicit’ consent. GDPR covers personal data relating to individuals. SDSD 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.
SDSD is registered with the ICO (Information Commissioners Office)
GDPR includes 7 rights for individuals
1) The right to be informed
SDSD is required to collect and manage certain data, to provide the service that we offer, allowing us to keep the children safe and parents updated. We need to know parent’s names, addresses, telephone numbers, email addresses. We need to know children’s’ full names, addresses and date of birth and any medical needs.
SDSD is required to hold data on its Teachers; names, addresses, email addresses, telephone numbers, date of birth, membership number for dance faculty, bank details.
2) The right of access
At any point an individual can make a request relating to their data and SDSD will need to provide a response (within 1 month). SDSD 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 ICO if they are not happy with the decision.
3) The right of rectification
At any point an individual can make a request to update and alter their data held by SDSD.
4) 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, SDSD has a legal duty to keep children’s and parent’s details for: Data records and information relevant retention period 6 years, 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 teaching member leaves, before they can be erased. This data is archived securely onsite and shredded after the legal retention period if this is the teachers request. Once a student is no longer attending classes any personal data will be deleted and / or shredded within the relevent retention period unless agreed otherwise.
5) The right to restrict processing
Parents, visitors and staff can object to SDSD processing their data. This means that records can be stored but must not be used in any way, for example reports or for communications. This must be submitted in written form to SDSD.
6) The right to data portability
SDSDS requires data to be transferred from one IT system to another; such as from SDSD 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.
7) The right to object
Parents, visitors and staff can object to their data being used for certain activities like marketing or research.
8) The right not to be subject to automated decision-making including profiling.
Automated decisions and profiling are used for marketing based organisations. SDSD 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 in the office at the studio or the home office in Stone. Members of staff can have access to these files but information taken from the files about individual children is confidential and apart from archiving with consent, these records are shredded 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 shredded after the relevant retention period.
SDSD collects a large amount of personal data every year including; names and addresses of those on the waiting list. These records are shredded after 6 months if the child does not attend or added to the archive and stored appropriately with permission.
SDSD stores personal data held visually in photographs or video clips or as sound recordings, No, names are stored with images in photo albums, displays, on the website or on the SDSD website or social media sites.
Access to all electronic data is password protected. When a member of staff stops teaching for the school 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 SDSD 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
Track and Trace
All personal information will be held for 21 days and if SDSD are contacted by Englands NHS Track and Trace the required details will be passed on.