General Data Protection Regulation Policy
Statement
GDPR stands for General Data Protection Regulation & replaces the previous Data Protection Act Directives that were in place. It was approved by the EU Parliament in 2016 & comes into effect on 25th May 2018.
GDPR states that personal data should be ‘processed fairly & lawfully’ & ‘collected for specified, explicit & legitimate purposes’ & that individuals data is not processed without their knowledge & are only processed with their ‘explicit’ consent. GDPR covers personal data relating to individuals. Attitude Theatre Arts is committed to protecting the rights & freedoms of individuals with respect to the processing of children's, parents, visitors & staff personal data.
The GDPR gives individuals the right to know what information is held about them. It provides a framework to ensure that personal information is handled properly.
GDPR includes 7 rights for individuals
1) The right to be informed
Attitude Theatre Arts is a registered Performing Arts provider with IDTA & as such, is required to collect & manage certain data. We need to know parent’s / legal guardians names, addresses, telephone numbers, email addresses. We need to know children’s’ full names, addresses & date of birth, along with any SEN requirements. We are requested to provide this data to the local County Council & other performing council areas; this information is sent to the Local Authority via a secure electronic file transfer system.
We are required to collect certain details of visitors to our Schools. We need to know visits names, telephone numbers, & where appropriate company name. This is in respect of our Health & Safety & Safeguarding Policies.
As an employer Attitude Theatre Arts is required to hold data on its Teachers; names, addresses, email addresses, telephone numbers, date of birth, National Insurance numbers, photographic ID such as passport & driver’s license, bank details. This information is also required for Disclosure & Barring Service checks (DBS) & proof of eligibility to work in the UK. This information is sent securely to Due Diligence Checking Limited / DDC ltd. for the processing of DBS checks. DBS Numbers & date of issue are also held on a central staffing record.
All employees, Subcontractor, Trainee Teachers & Class Assistants over the age of 16 years are also required to submit to DBS checks 7 again the appropriate data collected & handled in the same way as employees.
Attitude Theatre Arts uses Cookies on its website to collect data for Google Analytics, this data is anonymous.
2) The right of access
At any point an individual can make a request relating to their data & Attitude Theatre Arts will need to provide a response (within 1 month). Attitude Theatre Arts 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 to erasure
You have the right to request the deletion of your data where there is no compelling reason for its continued use. However, Attitude Theatre Arts has a legal duty to keep children’s & parents details for a reasonable time*, Attitude Theatre Arts retain these records for 3 years after leaving, children's accident & injury records for 19 years (or until the child reaches 21 years), & 22 years (or until the child reaches 24 years) for Child Protection records. Staff records must be kept for 6 years after the member leaves employment, before they can be erased. This data is archived securely & shredded after the legal retention period.
4) The right to restrict processing
Parents, visitors & staff can object to Attitude Theatre Arts processing their data. This means that records can be stored but must not be used in any way, for example reports or for communications.
5) The right to data portability
Attitude Theatre Arts requires data to be transferred from one IT system to another; such as from Attitude Theatre Arts to the Local Authority, for performance licences, & Dance Associations for examinations. These recipients use secure file transfer systems & have their own policies & procedures in place in relation to GDPR.
6) The right to object
Parents, visitors & staff can object to their data being used for certain activities like marketing or research.
7) The right not to be subject to automated decision-making including profiling.
Automated decisions & profiling are used for marketing-based organisations. Attitude Theatre Arts does not use personal data for such purposes.
Storage & use of personal information
All paper copies of children's & staff records are kept in a locked filing cabinet or Lockable Metal Box. Members of staff can have access to these files, but information taken from the files about individual children is confidential. 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 & disclosure forms. These documents include data such as children's names, date of birth & sometimes address. These records are shredded after the relevant retention period. If being transported from one location to another they are transported in a lockable Metal Box.
Attitude Theatre Arts collects a large amount of personal data every year including; names & addresses of those on the waiting list. These records are shredded if the child does not attend or added to the child’s file & stored appropriately.
Information regarding families’ involvement with other agencies is stored both electronically on a Password protected memory stick & in paper format, this information is kept in a locked filing cabinet on Tip Toe Ockendon. These records are shredded after the relevant retention period.
Attitude Theatre Arts stores personal data held visually in photographs or video clips or as sound recordings, unless written consent has been obtained via the `Consent Form`. No names are stored with images in photo albums, displays, on the website or on Attitude Theatre Arts’ social media sites.
Access to all Office computers is password protected & iPads. When a member of staff leaves the School, these passwords are changed in line with this policy & our Safeguarding policy. Any portable data storage used to store personal data, e.g. USB memory stick, are password protected &/or stored in a locked Metal Box.
GDPR means that Attitude Theatre Arts must;
• Manage & process personal data properly
• Protect the individual’s rights to privacy
• Provide an individual with access to all personal information held on them
This Policy was adapted at a meeting at Attitude Theatre Arts in April 2018