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Privacy Policy


Blackheath Conservatoire

Privacy Policy

May 2018

INTRODUCTION

The Blackheath Conservatoire respects your privacy and is committed to protecting your personal data. This Privacy Policy will tell you how we look after your personal data as a customer, Tutor, member of staff or supplier and inform you of your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how the Conservatoire collects and processes your personal data, including any data you may provide through the application process to become a learner, payee for a learner, employee, Tutor or contractor/supplier.

It is important that you read this Privacy Policy together with any other privacy notice on our website from time to time so that you are fully aware of how and why we are using your data.

1.2 CONTROLLER

The Blackheath Conservatoire is the controller and responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this Privacy Policy).

We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via email via info@conservatoire.org.uk and state that your query is for the attention of the DPL. The DPL is John Keeley, the Conservatoire Principal.

1.3 CONTACT DETAILS

Our full details are:

Blackheath Conservatoire of Music and the Art Limited, 19-21 Lee Road, London SE3 9RQ. You can also contact us via the contact methods on our website.

We are a company and a registered charity. Our charity registration number is 1072627.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). Please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.4 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may need to update this Policy at any time and without notice and where we do this we will notify you by email. This Policy was last updated on 17 May 2018.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

1.5 THIRD-PARTY LINKS

We never share your information with third parties without your consent.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name and last name.
  • Contact Data means the data we use to contact you including your billing address, contact address (if different), email address and telephone number/s.
  • Financial Data means the data we use to process your payments for our services, or to pay you as a Tutor, contractor or employee including your payment card details if you choose to pay for services in this way.
  • We also keep transaction data, which are details about transactions you have made including the payments to and from you along with other details of services you have purchased from us. For the purposes of Conservatoire learners and their families, this means courses of study whether as a group, individual or holiday provision
  • Marketing and Communications Data includes your preferences in receiving information from us relating to Conservatoire courses and other news, your communication preferences and your permission to have photographs or other electronic media taken, stored and used that features you, or in the case of a child, your permission on their behalf.

We also collect and use aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific course or type of tuition. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data, Contact Data, Transaction Data, Profile Data, Financial Data and Marketing and Communications Data by using our website, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • purchase a service (a course of tuition or group course);
  • request marketing to be sent to you; or
  • give us some feedback.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time.

4.1 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity

To register you as a learner or parent of a learner, a Tutor, contractor or employee.

Type of data

(a) Identity
(b) Contact
(c) Profile

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you.

Purpose/Activity

To deliver the services you request by becoming a learner, Tutor, contractor or employee, including:

  1. managing payments, fees and charges; and
  2. managing your queries through our tuition, Front of House or other teams

Type of data

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you. We may also use some of the data related to your queries for our legitimate interests of ensuring our customer service quality standards are met.

Purpose/Activity

To collect and recover money owed to us in respect of your contract with us

Type of data

(a) Identity
(b) Contact
(c) Financial
(d) Transaction

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to recover debts due to us).

Purpose/Activity

To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy

Type of data

(a) Identity
(b) Contact
(c) Profile

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests of ensuring our customers are updated on these changes.

Purpose/Activity

To help us improve our offering to our learnesr, including asking you to leave a review or take a survey, or provide customer insights

Type of data

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how learners use our services, to improve our offering to our learners, to develop and grow our business).

Purpose/Activity

To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

(a) Identity
(b) Contact
(c) Profile
(d) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

Purpose/Activity

To use data analytics to improve our services, marketing, customer relationships and experiences

Type of data

(a) Technical
(b) Usage

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity

To make suggestions and recommendations to you about courses or tuition and events that may be of interest to you

Type of data

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our programme and grow our business, and to improve our offering to you).

We do not conduct any automated decision-making. We may on occasion profile our customers for the purposes of targeting marketing at them and where this is done, this is undertaken for our legitimate interests of ensuring our marketing is relevant to its audience.

4.2 MARKETING

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and general updates may be relevant for you. We only use the data you provide to us directly for this purpose.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We generally only send electronic marketing - such as email marketing - to people who have previously or currently are using similar services from us and this is in our legitimate interests. We will always offer a way out of receiving this marketing when you first become a contractor with us and in every marketing communication afterwards. We may on occasion send out postal marketing for the purpose of growing our sales which is in our legitimate interests and in this scenario we will rely on you to let us know if you do not want to receive this by opting out of marketing (see Opting out below).

Where you have not previously bought a service from us but have registered your details with us or have identified yourself as an interested person, donor or supporter, we will only send you marketing communications if you opted into receiving marketing at the time and so given us your express consent (which you may withdraw at any time – see Opting out below).

4.3 OPTING OUT

You can ask us to stop sending you marketing messages at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and only ever as permitted by law.

4.4 CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, Tutors and contractors who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, details of your transactions with us will be kept for as long as we need to retain that data to comply with our legal and regulatory requirements. This is generally 7 years unless the law prescribes a longer period.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it for example where you consider that we do not need it any longer for the purposes for which we originally collected it as explained to you in this Privacy Policy, where you have withdrawn your consent to our using it and we had relied on that consent according to this Policy, where you consider that we cannot show a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest to process it as explained to you in this Polic . You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), or where we may have processed your information unlawfully. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please contact us marking your query for the attention of the DPL.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Blackheath Conservatoire Privacy Notice

Why do we collect data?

We collect data to enable us to process transactions with our customers, students, suppliers, tutors and employees in accordance with their contract with us and in compliance with the law.

What data do we collect?

We only collect data that is:

  • needed to enable us to provide our services; or
  • needed to enable you to access our services; or
  • required to keep our learners safe and give them the best possible learning experience while they are taking courses or tuition with us

The data we collect is that which is requested on our application forms for individual tuition or group courses or otherwise on your contract with us.

We also ask for your specific permission to use photographs, films and other media which might be used for marketing or publicity purposes.

How do we store the data?

We store the data on industry standard software and systems to ensure that the data we collect from you is processed fairly and securely and in line with the provisions of GDPR.

Where our data is managed and stored on proprietary databases held on systems outside our physical control we request confirmation from the database supplier that the systems used are secure and are compliant with the GDPR regulations.

Who else sees the data we collect?

We do not share the data we collect with anyone outside of the Conservatoire unless there is a legal requirement to share the data.

Who oversees the data at the Conservatoire?

To ensure we process your data fairly, we have a Data Protection Lead, who is John Keeley, the Conservatoire Principal.

What are your rights?

You have the following rights under GDPR:

  • The right to request the personal data held and to rectify errors
  • The right to request the deletion of the personal data
  • The right to complain to the Information Commissioner’s Office if you feel your data has not been processed in line with the regulations