The General Data Protection Regulation (GDPR) 25th May 2018.
This notice will provide information on how we, Hack Ballet are complying with this Regulation.
Hack Ballet is committed to ensuring the data processed by our organisation remains safe and secure.
The main aims for this policy is to specify the data Hack Ballet collects, how it is stored/protected and the reason for collecting it, state how the personal data is used in processing, to disclose who has access to the data and how long we retain information for, and to explain data subject’s rights.
The General Data Protection Regulation (GDPR) ensures a balance between an individual’s rights to privacy and the lawful processing of personal data undertaken by organisations to protect the rights of individuals about whom data is obtained, stored, processed or supplied and requires that organisations take appropriate security measures against unauthorised access, alteration, disclosure or destruction of personal data.
Data protection principles
The legislation sets out various data protection principles. These include that personal information is:
- used fairly and lawfully
- used for limited, specifically stated purposes
- used in a way that is adequate, relevant and not excessive
- kept for no longer than is absolutely necessary
- kept safe and secure not transferred outside the European Economic Area without adequate protection
The legislation conveys various individual rights. These include the following:
- The right to be informed
- The right of access
- The right to rectification
- The right to erase
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
The sections towards the end of this Privacy Notice let you know how you can exercise your rights.
You can read more about your rights at https://ico.org.uk/for-the-public/ .
Information Hack Ballet processes
The following sections describe the information that Hack Ballet collects and how it is processed. The sections are split according to the type of information.
Legal basis for processing
The legislation requires that there is a clear legal basis for processing personal information. In general Hack Ballet relies on the individual’s consent in order to process their data. Where there are exceptions such as a legal obligation, contractual agreement or Hack Ballet legitimate interest, they will be noted below.
Please note that if consent is withdrawn the level of service that we can offer might be severely curtailed.
We do process members data for the best practice of the Health & Safety and Child Safeguarding policies. Students/members must remain safe at all times, therefore information must be collected in order to create registers, student records and to provide students with appropriate classes according to age, skill level, past experience, any medical or physical issues or other appropriate considerations to ensure the student or member gets the best service.
Special category data is only collected with the consent of the data subject. Special category data we collect includes but is not limited to: Medical/Disability information and Gender. As physical activity providers it is crucial that this consent is given should a participant have any medical/disability needs as it will allow us to incorporate participants safely into classes.
How We Obtain Personal Data
Information provided by student/member or parent/ guardian:
You may be providing us with personal data in the following ways:
- Via email
- Via forms on our website
- Via our social media profiles
- Via written enrolment forms, feedback forms, or questionnaires
- Over the phone and via sms text services or other messaging platforms and services
- By using a credit card for payments
What data is collected
Examples of the kind of data that could be collected include:
- Full Name
- Date of Birth
- Home Address
- Gender or gender identity
- Classes attended/Price paid
- Medical Information/History
- Disability Information
- Email Address
- Mobile Telephone Number
- Work/Home phone Number
- Emergency Contact Number
- Bank Details
To participate in Hack Ballet activities, participants/members/parents/guardians must agree to some processing of their personal data. This is due to Legitimate Interests : GDPR Article 6(1)(f), Legal Obligation GDPR Article 6(1)(c), Contract – Article 6(1)(b) and/or Consent – Article 6(1)(a).
This means that the legal basis of our holding your personal data is for a legitimate interest.
What is done with the data collected
Enrolment and personal information of students and members is stored on an encrypted server with controlled access to only designated members of management staff.
Storage/Retention of data
Data received is stored in our database, access is restricted though password protection and only available to designated authorised staff members.
Once a student/member lapses, we retain sufficient information to identify the previous member. This allows the previous membership to be used again if the member re-joins. HackBallet relies on legitimate interest as the legal basis for retaining this information.
Information on how long we store the data: financial records are kept for at least 6 years due to legal obligation, First Aid records are kept for at least 21 years due to legal obligation, Child Safeguarding records are kept indefinitely on a case-by-case basis (the minimum these will stored for is 6 years due to legal obligation) Bank details collected for the purpose of fulfilling customer purchases, via our online store or other payment processing services, are deleted after the action concerning them is complete.
If an email address is provided we assume consent to use it for administrative purposes of membership (e.g. notification of membership renewal, notification of class and performances information, etc.).
We will obtain your consent to send you e-news and marketing items.
Third Parties/Data Processors
Use of data processors
Data processors are third parties who provide services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. The following is a list of our main data processors. There may be others from time to time.
Hack Ballet has confidentiality and data processor agreements in place. Teachers are provided with class registers containing students/members names, emergency contact numbers and any medical information that is pertinent to the running of a class (subject to consent from the data subject).
Child Performance Licensing
To process Child Performance licenses or chaperone licenses, Hack Ballet is legally required to provide some information to local council and this will be done with consent from the student/member/parent/guardian.
Child Safeguarding Concerns
Hack Ballet is legally required to provide data to the safeguarding board at the local council if requested and we are satisfied that their GDPR process is thorough and if any data is stored it will be in a secure environment.
Show programmes are printed and will contain the student/member/performer name and sometimes photograph (headshot, performance image, studio image). Student/Member/ Parent/guardian will be asked for consent for this.
Photos/Videos of Students/Members
Hack Ballet may use footage/photos used from classes, performances, workshops, events and shows for marketing purposes both in print media, website, social media platforms and other marketing platforms that may become available from time to time. Any identifying information will not be shared without the consent of the performer/student/member. Practice videos are regularly used for our online dance practice groups and it is a very important tool to help the students/performers progress in class.
Participants/their Parent and/or Guardians may choose if they do not wish themselves/their child to be depicted. Upon application parents/guardians/performers are asked to opt in or opt out of photographic consent for their child.
Some attendees at events may film/take photos for their own personal use (e.g. parents of other participants). If an individual chooses not to have their image depcited/identified Hack Ballet reserves the right to change or alter their mode or level of participation in any public event or event designated as a filming or content creation event. It is usually possible for those who do not wish to be filmed/depticted/identified to make adaptations to their participation to allow for this (i.e choose a space in the performance venue where they are not in shot of the cameras) but this is not always possible so performers/students/members/participants should make their own adaptations or withdraw from an event if necessary if their depiction or identification would be unavoidable.
Website technical details
We do use electronic forms on our website and aim to use secure forms where appropriate. Web forms and other parts of our website are served via secure https: Data received through these enrolment forms is stored in our database, access is restricted though password protection and only available to designated authorised staff members.
In compliance with EU legislation, cookies are only used for essential web functions . We use Google Analytics to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
HackBallet maintains a number of social media platforms and may engage in new social media platforms that may become available from time to time. HackBallet gives serious consideration to privacy concerns when choosing what information to post or share on social media platforms.
In general we will contact participants/members/students using the mode they used to contact us.
We may use social media to contact participants/members/students if the participant/member/student has shared their profile with HackBallet or otherwise used that platform to connect with us. We will not share your data from one platform to other platforms or share your social media profiles or other identifying information without your explicit consent (this could be verbal i.e. a teacher asking if it’s ok to tag your profile on a social media post).
If you are wrongly tagged or would like a tag to be removed please contact us through the channel in question or if this is not possible send us an email to email@example.com with full details of the post/content and what you would like removed or changed.
Posts you make to our public profiles may be visible to others. Please exercise your own control over privacy settings for your own/your child’s profile to ensure your privacy is maintained. If in doubt please communicate via private message/email to firstname.lastname@example.org to ensure your communication remains confidential. Do not tag or post images or identifying data about other participants/members/artists without that person’s or person’s guardian’s explicit consent.
We will not share your individual social media profile or contact details with other members/participants/artists without your explicit consent. Members/participants/artists should seek consent before sharing/connecting with you on social media.
Any concerns can be raised confidentially with the HackBallet Data Controller via email at email@example.com
Complaints or queries
Hack Ballet strives to meet the highest standards when collecting and using personal information. Please contact us by writing to the Data Controller to firstname.lastname@example.org if for any reason you think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
Confidentiality will be preserved during the investigation of a complaint to safeguard the interests of everyone concerned unless disclosure is necessary to progress the complaint.This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the school via our email email@example.com
Access to personal information
Hack Ballet tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by asking. This is formally known as a subject access request under the Data Protection Act 1998. If we do hold information about you we will:
- give you a description of it
- tell you why we are holding it.
- tell you who it could be disclosed to.
- let you have a copy of the information in an intelligible form.
To make a request to Hack Ballet for any personal information we may hold you need to put the request in writing to firstname.lastname@example.org
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes.
Disclosure of personal information
Except as described in this Privacy Notice we will not disclose personal data without consent.
We may disclose your information to governmental agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request.
Please do not hesitate in contact us at email@example.com if you have any question, concern, advice or complaint.
Artist Director of Hack Ballet