GDPR: DATA PRIVACY NOTICE FOR CLIENTS

Introduction

Spotlights Academy LLP – trading as Spotlights Theatre School, (“We”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

Definitions

Data controller – A controller determines the purposes and means of processing personal data.

Data processor – A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Who are we?

Spotlights Theatre School is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:

Email: info@spotlightstheatre.co.uk

Telephone Number: 020 8460 5711

Postal Address: 38 Croydon Road, Beckenham, Kent, BR3 4BJ

Registered Office: Swatton Barn, Badbury, Swindon, SN4 0EU

For all data matters contact Data Representative using the details above.

The purpose(s) of processing your personal data

We use your personal data for the following purposes:

To enrol a student into a free trial class;

To register you as a new customer;

To enrol a student into our programme of performing arts classes and workshops;

To process and deliver your order including:

• Managing payments, fees and charges
• Collect and recover money owed to us

To manage our relationship with you which will include:

• Notifying you about changes to our terms or privacy policy
• Asking you to leave a review or take a survey

To maintain our own accounts and records;

To inform individuals of news, events or activities.

You may give us information about you by filling in forms on our site www.spotlightstheatre.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site.

The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

Personal data.  The personal data that you give us may include parent or guardian’s name; contact and address details; relationship to the student; emergency contact numbers; name, age, gender and date of birth of student; and any medical conditions the student has. If the student is over 16 years of age, please ensure that you have their permission to share these details with us.

What is our legal basis for processing your personal data?

(a) Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

Sharing your personal data

Your personal data will be treated as strictly confidential.

How long do we keep your personal data?

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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.

Providing us with your personal data

We require your personal data as it is a requirement necessary to enter into a contract.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

Transfer of Data Abroad

We do not transfer your personal data outside the European Economic Area (EEA)

Automated Decision Making

We do not use any form of automated decision making in our business.

Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Representative on 020 8460 5711 or email info@spotlightstheatre.co.uk

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.