Privacy Policy

Spiral Dance Studio Privacy Policy

Introduction:

1.      At Spiral Dance Studio (previously The Body Workshop Dance) we value our customers and take your privacy very seriously.

2.      This policy lists how we use (process) and protect the information that is given to us by you via email, enrolment form or enquiry form. This policy has been written in line with the Data Protection Act (2018) and the EU’s General Data Protection Regulation (GDPR).

3.      Spiral Dance Studio (previously The Body Workshop Dance) may change this policy periodically, please check occasionally to familiarise yourself with changes to the policy. If applicable, members will be notified by email of any changes. 

4.      Spiral Dance Studio (previously The Body Workshop Dance) is an inclusive dance school which offers dance classes and workshops for all ages and abilities.

5.      The Data Controller for Spiral Dance Studio (previously The Body Workshop Dance) is Katharine Dudley and the business address is Spiral Dance Studio (previously The Body Workshop Dance), Sycamores, Bishops Walk, Whiteshill, Stroud GL6 6BW but our classes run from The Bingham Hall, King Street, Cirencester GL7 1JT. Contact details are as follows: hello@spiraldancestudio.co.uk or 07885800942, alternatively you can contact us via our ‘Contact Us’ form on the website (www.tbwdance.co.uk).

6.      Our legal basis for processing personal data is ‘legitimate interest’ as our processing of personal information is necessary for the services we provide and ‘consent’ for using your personal information for a specific purpose (photographs in marketing).

7.      Spiral Dance Studio (previously The Body Workshop Dance) do not sell information to third parties.

8.      While Spiral Dance Studio (previously The Body Workshop Dance) avoids sharing data with third parties at most times, some data is shared in accordance with our business practices. This sharing of data will be consensual with the data subject and/or their parent/guardian and if Spiral Dance Studio (previously The Body Workshop Dance) is satisfied their Data Protection policy is GDPR compliant.

 Section 1:

How Spiral Dance Studio (previously The Body Workshop Dance) collect data:

Spiral Dance Studio (previously The Body Workshop Dance) customers provide personal data when signing up for classes through our enrolment form (on Google Forms or Mailchimp) or via a paper enrolment form.

This is completed by a parent/guardian or the dancer themselves.

Personal data may also come to us through our Enquiry Form on our website and to our main email address. 

In some instances, bank details of a parent/guardian may be required in the instance of refunds.

Why do Spiral Dance Studio (previously The Body Workshop Dance) collect data:

Dancers/parents/guardians must agree to some processing of their personal data when signing up for our classes. This is due to Legitimate Interests and Consent and is also in line with our health and safety and child safeguarding policies. 

Our dancers must remain safe at all times and so information must be collected to create registers and to split dancers into year groups.

We ask for special category data in terms of Medical/Disability information at consent from the data subject. It is essential that this consent is given if necessary as this will allow us to ensure dancers are safe in classes.

What personal information do we collect?

For health and safety reasons, there is specific information that we require when you sign up for our classes. Some of this information will be sensitive (Children’s Personal Information, Date of Birth and Medical Information) and we ensure utmost confidentiality.

When you sign up for children’s classes, we collect the following information:

·         Dancer’s Personal Data:

o   Child’s Full Name, School Year, Date of Birth, Home Address, Classes to attend

o   An email address for the dancer may also be given if parent/guardian deems this necessary

·         Dancer’s Special Category Data:

o   Medical Information/History

o   Disability Information

·         Parent/Guardian Personal Data:

o   Name, Address, Email Address, Contact Phone Number

o   An emergency contact name and phone number

When you sign up for adult classes, we collect the following information:

·         Dancer’s Personal Data:

o   Full Name, Date of Birth, Email Address, Telephone Number(s), Address

o   An emergency contact name and phone number

·         Dancer’s Special Category Data:

o   Medical Information/History

o    Disability Information

If you attend a trial class, workshop or a Cheeky Feet special event, we collect the following information:

·         For children’s classes:

o   Dancer’s Personal Data:

o   Child’s Name, Age or School Year Group

o   Permission for photographs to be taken and used on our online sites (Website, Facebook, Instagram)

o   Dancer’s Special Category Data:

§  Medical Information/History

§   Disability Information

o   Parent/Guardian Personal Data:

§  Name, Email Address and Telephone Number

§  An emergency contact name and phone number

§  Consent to receive marketing emails from us in the future

If you enquire about our classes via our online form, we collect the following information:

·         Personal Data:

o   Your Name, Email Address and Telephone Number

o   Any information you choose to give us such as your child’s name

·         Consent to receive marketing emails from us in the future

If you enquire about our classes via direct email, we collect the following information:

·         Personal Data:

o   Your Name, Email Address and Telephone Number

o   Any information you choose to give us such as your child’s name

How data collected is sent internally:

·         Enquiry forms are sent to Spiral Dance Studio (previously The Body Workshop Dance) through an encrypted email server from our website (via Squarespace)

·         Received paper enrolment forms are destroyed after no more than 4 weeks

·         Online Enrolment forms are stored for the academic year on secure Google Forms

Storage/Retention of data:

·         Data received via enrolment forms are uploaded manually into our CRM (Membermeister). Access to the original enrolment forms and the CRM is password protected and only available to authorised staff members.

·         Registers and emergency contact lists are created through the CRM – which are password protected.

·         A copy of registers are given to staff with first name of dancer and year group or age only. In some instances, where there are children of the same name in the dance school we will use the first initial of their surname (sometimes this will also be the second initial). When these are out-dated, we destroy them thoroughly.

·         Waiting lists are stored on an encrypted cloud-based server.

·         Any data recorded on paper (e.g. accident forms, paper enrolment forms, printed invoices) will be stored in a locked bag or cabinet.

·         We will retain your information for as long as we have a legal or business reason to do so. This means:

We will keep all of your personal information as long as you or your child dances with us at Spiral Dance Studio (previously The Body Workshop Dance).

We will keep names only for 7 years after you leave us for accounting purposes.

Personal information including child’s name, DOB, medical information, address and telephone number will be destroyed within 60 days of you leaving us.

We will retain photograph permission as long as Spiral Dance Studio (previously The Body Workshop Dance) (as this name or any new name) is in business or for 100 years; whichever is longer.

If you have enquired about our classes, we will keep your name and email address for 12 months. We will make sure you only receive emails relevant to your enquiry.

If you are a parent of a past pupil, we will keep your name and email address for marketing purposes for 12 months after you leave to send you information about classes under our legitimate interests. However, if you request for us not to contact you for marketing purposes we will adhere to this – you can also unsubscribe from any emails.

If you have attended a trial, workshop or Cheeky Feet special, we will keep your name and email address for marketing purposes for Cheeky Feet specials for 12 months. You can unsubscribe from these at any time.

Your data may be turned into anonymous, statistical data to enable us to create reports about our classes.

Accident forms will be retained for 3 years after the accident occurs.

Registers will be destroyed on a termly basis.

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 are deleted after the action concerning them is complete

Section 2: How we use this information:

Third Parties/Data Processors:

Freelance Teachers:

All of our teachers are freelance staff and we have data processor agreements in place. Teachers receive registers which include the dancer’s first name, photograph permissions and year group/age. They will also receive any medical information which is necessary for the safe running of a class/event (including the show). This will be with consent from the dancer or dancer’s parent.

Mailchimp:

Spiral Dance Studio (previously The Body Workshop Dance) uses Mailchimp, a USA based company, to send newsletters and any marketing via email. We are happy they are GDPR compliant.

All those involved in Spiral Dance Studio (previously The Body Workshop Dance), will receive newsletters via Mailchimp.

Marketing emails will be sent to enquiries and past pupils via Mailchimp – these can be unsubscribed from and all records will be erased.

Membermeister:

Spiral Dance Studio (previously The Body Workshop Dance) uses Membermeister as a CRM which stores all the information provided in Section 1. We are satisfied that their GDPR regulations are thorough and information stored is secure.

All invoices will be sent to current parent/guardians and adult dancers via membermeister as will important emails. These emails can not be unsubscribed from as they are sent under our legitimate interests. If you do wish to unsubscribe, you must email Spiral Dance Studio (previously The Body Workshop Dance) and inform us why you wish to unsubscribe.

Google Drive:

Spiral Dance Studio (previously The Body Workshop Dance) uses Google Drive (GSuite) to store all of our data. This includes (but is not limited to): enrolment forms, trial booking forms, registers, medical information, photograph permission forms, show information.

Google Drive is a secure cloud-based server which is GDPR compliant and password protected.

Child Performance Licences:

In order to apply for child performance licences, Spiral Dance Studio (previously The Body Workshop Dance) is legally required to provide personal data to Gloucestershire County Council. This includes (but not limited to): Full name, Date of Birth, School Details, Parental information and any medical information. Consent to send this information will be sought if a child needs a child performance licence.

Child Safeguarding Concerns:

In the unlikely event, Spiral Dance Studio (previously The Body Workshop Dance) has a safeguarding concern in relation to one of our dancers, we are legally required to provide data to the safeguarding board at the local council.

Section 3: Photographs/Videos of Dancers

Spiral Dance Studio (previously The Body Workshop Dance) uses videos and photographs from classes and shows for marketing purposes on social media platforms, our website and in print (e.g. leaflets).

Permission to take photographs of dancers and permission for these photographs to be used online was received via enrolment forms, email and trial forms between November 2016 – May 2019. If this dancer has since left the dance school, this information will be stored for as long as Spiral Dance Studio (previously The Body Workshop Dance) (as this name or any new name) is in business.

From May 2019, a new thorough photo permission form will be sent out to parent/guardians and adult dancers at Spiral Dance Studio (previously The Body Workshop Dance). This form will only be required to be completed once and will be kept for as long as Spiral Dance Studio (previously The Body Workshop Dance) (as this name or any new name) is in business or up to 100 years; whichever is longer.

Photographs and videos of all dance students are used in a number of ways at Spiral Dance Studio (previously The Body Workshop Dance):

Internal use -

• On care plans or allergy lists to identify students to all teachers

• At the end of the year / term, as part of a celebration

• Displays in the changing room such as show photographs

The lawful basis for use of images in this way is legitimate interest.

External use -

For use in marketing:

• On Spiral Dance Studio (previously The Body Workshop Dance) website- videos and photographs of events, shows and example dance styles that we teach

• In Spiral Dance Studio (previously The Body Workshop Dance) prospectus or other documents to show how the dance school functions

• In local press

•On social media (Facebook and Instagram) for marketing purposes and promoting our dance school

On sharing evenings, in house, other parents may take photographs/videos of you / your child and will agree that these will not be shared on social media. For this use of images we require consent. When using photographs and videos for marketing purposes we will not accompany them with any other personal information about you / your child, to ensure that you / your child cannot be identified.

Any photo or video will be stored on the Principal's, Katharine Dudley, computer or work phone, and then uploaded onto Google Drive, it will then be securely deleted from the computer or phone.

Conditions of Use -

1. This permission form lasts for 100 years and will be updated in the year that children turn 13 and, then, when they turn 18.  You have the right to withdraw your consent at any time.

2. If we use photographs of individual pupils or small groups of children or young people, we will avoid using their name (which means first name and surname) of that child in the accompanying text or photo caption. Please note that the external media profession are likely to use first names and surnames in their publications/broadcasts.

3. We will not include personal e-mail or postal addresses, or telephone or fax numbers on video, on our website, or in other printed publications.

4. We may use group photographs or footage with very general labels (for example, the name of the dance style or class).

5. We will only use images of children who are suitably dressed, to reduce the risk of such images being used inappropriately.

6. At public events, shows and open afternoons, we have no control over who takes photographs but every visitor will be prepped on the necessity for discretion and respect of all of our students.

7. We will not re-use any photographs or recordings for more than one year after you/ your child leaves Spiral Dance Studio (previously The Body Workshop Dance) (except in historical displays). (N.B. Photographs already used for marketing online and offline will remain in the public domain).

Who gives the consent?

• In terms of data protection, there is no set age limit as to when a child should give their consent to be in photographs and/or used online.

•  We recognise the need to take the safety and welfare of all children and we take the use of photographs seriously so we encourage you to discuss the use of photographs with your child and the risks involved. The NSPCC advises that children should understand how their photographs are used and to give consent for this.

• At Spiral Dance Studio (previously The Body Workshop Dance) we have decided the following:

·         For dancers aged under 13, we ask for a parent/guardian to complete the form below for them. We ask for you discuss this choice with your child.

·         For dancers aged 13 and over, we ask for the child involved to complete the form below with their parent/guardian.

·         For dancers aged 18 and over, the form must be completed by the individual

We have a strict no social media policy so any photographs taken by students and/or parents of our dancers must not be used on any social media site.

Photographs may also be uploaded onto Canva but these will be removed as soon as the design or photo have been created and downloaded to a password protected laptop.

Short videos may be uploaded to Imovie or Vimeo to use on social media platforms or in the newsletter.

Section 4: Show and Performance Permissions

We will ask for certain consent for your child/you to perform in our annual show such as:

·         Consent for a dancer to be photographed and filmed by our official videographer

·         Consent for the dancer’s name to be listed in the show programme (first name only – in some instances we may also put the first letter of the surname too).

Section 5: Your rights

1.      The Data Protection Act gives you the right to access the information we have about you.

2.      You have a right to rectify any incorrect data we have for you (so please keep us updated with any changes to your personal information!).

3.      You have a right to request the erasure of your personal data although there are some exclusions which include: if you owe us fees, if you are a current customer. There will be a small amount of data (names) we need to keep due to our legal obligations.

4.      You have a right to object to consent to marketing emails and can unsubscribe from these via clicking unsubscribe at the bottom of emails or emailing us at hello@spiraldancestudio.co.uk

5.      You have a right to withdraw consent of the use of photographs and videos.

Section 5: CCTV at The Bingham Hall, Cirencester

·         One of our venues, The Bingham Hall, has installed closed circuit television (CCTV) to ensure the venue stays a safe and secure place for us to use.

·         There are 8 fixed cameras and their location is identified by clear signage. The system is owned and monitored by Bingham Hall. Only authorised personnel will have access to the recordings which will be stored securely.

·         The cameras are located so they only capture images for the purposes they are installed to ensure privacy to hall hirers and users. Cameras will not be installed in toilets or changing rooms.

·         The monitoring may include: protection of Bingham Hall building and property, monitoring of access control systems, verification of security alarms and criminal investigations (by police).

·         We are confident that Bingham Hall are GDPR compliant in terms of the use of CCTV. Individuals have the right to request access to CCTV footage related to themselves and a copy of Bingham Hall’s CCTV policy can be requested from the Bingham Hall Manager (Sharon King: info@binghamhall.co.uk, 01285 656631)

Section 6: Complaints and Data Breeches:

·         Complaints in regards to the handling of personal data can be made directly to Spiral Dance Studio (previously The Body Workshop Dance)’s DPO: Katharine Dudley

o   hello@spiraldancestudio.co.uk

o   07885800942

o   Spiral Dance Studio (previously The Body Workshop Dance), Sycamores, Bishops Walk, Whiteshill, Stroud Glos GL6 6BW

·         If you feel Spiral Dance Studio (previously The Body Workshop Dance) have violated data protection laws, you have the right to complain to the Information Commissioner's Office (ICO) at Wycliffe House, Water Lane, Wilmslow, Cheshire
SK9 5AF or by phone 0303 123 1113 or via their website: https://ico.org.uk

·         If Spiral Dance Studio (previously The Body Workshop Dance) experiences a data breech, we have legal obligation to report this to the ICO within 72 hours. All victims of the data breech will be informed as soon as possible if there is a high risk of impacting the individual. All data breeches will be stored.

Section 7: Cookies

Cookies on our website (www.spiraldancestudio.co.uk) do not store any personal information and are only used to make our website easier to use. Please see our separate Cookie Policy for more information.  

If you have any queries about our privacy policy please contact us:

By post:

Katharine Dudley - Spiral Dance Studio (previously The Body Workshop Dance),

Sycamores

Bishops Walk

Whiteshill

Stroud

Gloucestershire

GL6 6BW

By email: hello@spiraldancestudio.co.uk               By phone: 07885800942

Updated August 2019