Section 1 Client/Parental Consent for Images
Websites can be viewed worldwide and not just in the United Kingdom where UK law applies.
The press are exempt from the GDPR and may want to include the names and personal details of children and adults in the media.
Parent/guardian will discuss the use of images with your child/ren to obtain their views, if appropriate.
As the child’s parents/guardians, you agree that if we/I take photographs or video recordings of our child/ren which include other children, then we will only use these for our personal use.
You agree that if your child uses social media platforms to upload photos/videos taken at Impresario Theatre School they will seek consent from the parents of the people who appear in the photograph/video prior to uploading online. Impresario Theatre School will accept no responsibility for private images/videos posted to social media.
You agree Impresario Theatre School may use you or your child’s photograph/image in displays around the school/setting and offsite.
Impresario Theatre School may use you or your child’s photograph/image in our prospectus and other printed publications that we produce for publicity and promotional purposes (Leaflets, newspapers, magazines, Show programmes,)
Impresario Theatre School may use videos and images of you or your child on our website, social media platforms and other electronic communications (Impresario Theatre School Facebook pages, Instagram, YouTube channel, online features, articles and write ups about Impresario Theatre School).
You are happy for you or your child to appear in the media e.g. if a newspaper photographer or television film crew attend an event organised by the setting.
Image Use Policy
Impresario Theatre School Data Controller: Amy Rackliff (Principal)
Impresario Theatre School Designated Safeguarding Officer: Amy Rackliff (Principal)
Administrator with lead responsibility: Amy Rackliff
Official use of Images/Videos of Children and clients by the School/Setting
Scope and aims of the policy
Safety of Images and Videos
Publication and sharing of images and videos
Usage of apps/systems to share images with parents
Safe Practice when taking images and videos
Use of Images/Videos of Children by Others
Use of Photos/Videos by Parents/Carers
Use of Photos/Videos by Children
Use of Images of Clients/Children by the Media
Where a press photographer is to be invited to celebrate an event, every effort will be made to ensure that the newspaper’s (or other relevant media) requirements can be met.
A written agreement will be sought between clients/parents and carers and the press which will request that a preagreed and accepted amount of personal information (e.g. first names only) will be published along with images and videos.
The identity of any press representative will be verified and access will only be permitted where the event is planned, and where press are to be specifically invited to attend. No authorisation will be given to unscheduled visits by the press under any circumstances. Every effort will be made to ensure the press abide by any specific guidelines should they be requested. No responsibility or liability however can be claimed for situations beyond reasonable control, and where the setting is to be considered to have acted in good faith.
Use of Professional Photographers
Impresario Theatre SchoolGuide to the Use of Images Online
Using Images Safely and Responsibly
We all enjoy and treasure images of our family and friends; family events, holidays and events are moments we all like to capture in photos or on video. We now have the exciting dimension of adding our images and videos to our online social networks, such as Facebook, YouTube and many other websites. This means that we can easily share our photos and video with family and friends. Whilst this can be very useful to all of us, we must ensure we protect and safeguard all clients children and staff, including those who do not want to have their images stored online.
What should we all think about before posting any images or video online and are there any risks?
At Impresario Theatre School we are happy for parents and carers to take photos and video of events (as agreed by Impresario Theatre School) for personal use but request that these images are not distributed or put online. This is to protect all members of the community.
We thank you for your support!
Further Information on the Use of Images and video:
Section 2 GDPR
The General Data Protection Regulation (GDPR) comes into effect on 25th May 2018. It has been agreed that Amy Rackliff, will be appointed as Data Protection Officer (DPO) and is therefore responsible for the safe storage of information relating to our students and parents. This Notice will provide information on how we, Impresario Theatre School are complying with this Regulation.
Purpose and Statement:
Impresario Theatre School is committed to ensuring the data processed by our charity remains safe and secure.
This policy has been written in line with legislative change, including both the Data Protection Act (1998) and the EU’s General Data Protection Regulation (GDPR).
Impresario Theatre School has determined the lawful reasons with which it processes personal data:
Legal obligation – GDPR Article 6(1)(c)
Legitimate interest – GDPR Article 6(1)(f)
Contract – GDPR Article 6(1)(b)
There is also some limited data we process with consent from the Data Subject; Consent – GDPR Article 6(1)(a).
While Impresario Theatre School avoids sharing data with third parties at most times, some data is shared in accordance with our business practices. The sharing of data with third parties will always be consensual with the data subject and/or their parent/guardian, and only if Impresario Theatre School is satisfied that their Data Protection policy is GDPR compliant.
How we use your personal data
We are committed to protecting your personal data. The only data we collect from you is as submitted by you on the registration form. We will use your sensitive personal data for the purposes of providing our services to you or if we need to comply with a legal obligation. We will use your non-sensitive personal data to (i) register you as a new client, (ii) manage payment, (iii) collect and recover monies owed to us (iv) to manage our relationship with you, (v) send you details of our goods and services (vi) for performance licenses and showcase BOPA applications.
Our legal grounds for processing your data are in relation to points (i) to (iv) above are for performance of a contract with you and in relation to (v) above, necessary for our legitimate interests to developour products/services and grow our business. We will not share your details with third parties for marketing purposes except with your express consent.
In certain circumstances you can ask us to delete your data. See the section entitled ‘your rights’ below for more information. We may anonymise your personal data (so that you can no longer be identified from such data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, or reporting requirements so for example we need to keep certain information about you for 6 years after you cease to be a client for tax purposes. You have the right to ask us to delete the personal data we hold about you in certain circumstances. See section ‘Your rights’ below.
You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at
Disclosure of your personal data
We may have to share your personal data with (i) service providers who provide IT and system administration support, (ii) professional advisors including lawyers, bankers, auditors and insurers (iii) HMRC and other regulatory authorities (iv) third parties to whom we sell, transfer or merge parts of our business or our assets and/or (v) [to other professionals for the purposes of discussing your treatment]/[to my supervisory teachers as part of my teaching training]
We require all of these third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on our instructions. In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless your requestis clearly unfounded, repetitive or excessive in which case we maycharge a reasonable fee or decline to respond.We will, in most cases, reply within one month of the date of therequest unless your request is complex or you have made a largenumber of requests in which case we will notify you of any delay andwill in any event reply within 3 months.
If you wish to make a Subject Access Request, please send the request to email@example.com marked for the attention of the Data Compliance Officer.
Some of our third party providers are businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within Europe. If we are not able to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.
Keeping your data up to date
We have a duty to keep your personal data up to date and accurate so from time to time we will contact you to ask you to confirm that your personal data is still accurate and up to date. If there are any changes to your personal data (such as a change of address) please let us know as soon as possible by signing in to our online portal and updating this information.
Protecting your data is important to us and we have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. 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 breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
We may change this Privacy Notice from time to time and shall notify you of any changes.
Impresario Theatre School is committed to providing fair and understandable privacy policies in relation to personal data.
Impresario Theatre School will, at all times, keep data in secure locations (including, but not limited to, encrypted and access restricted files) and not retain data unnecessarily or past the retention length as set out in this policy.
In the rare instance a data processor that is not Impresario Theatre School employee is used, such as a third party, the data subject will either be asked for consent pre to supplying the data or be notified and have the right to object to processing.
Impresario Theatre School customers and participants supply their personal data when signing up for classes through our registration form either via the website, or via our online portal.
This is either completed by a parent/guardian or the child themselves if they deemed able to do so.
Personal data may also come to us unsolicited via enquiries through our website and to our generic email account.
To attend any of Impresario Theatre Schools activities participants/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).
Should Impresario Theatre School be unable to process participant’s data, we would be contravening both our Health & Safety and Child Safeguarding policies. We would also be ignoring best practice regarding working with children/vulnerable adults.
Our participants must remain safe at all times, therefore information about participants must be collected in order to create registers and accurate student records. This information is also used to provide students with appropriate classes, including dividing students into age groups.
Special category data is only collected with the consent of the data subject. Special category data Impresario Theatre School collects includes but is not limited to: Medical/Disability information, Income information, Ethnicity, Gender and Sexuality.
As physical activity providers it is essential that this consent is given should a participant have any medical/disability needs. This allows us to incorporate participants safely into classes. It is also used in assessing if we can incorporate participants safely into classes.
Income information is only collected in instances where a participant applies to attend our classes at a concessionary price, or on a bursary. This financial support is means tested, and therefore is subject to documented proof. Proofs of entitlement to concession are shredded after the entitlement has been noted.
Ethnicity and other sensitive data is to provide information to funding bodies for statistical purposes. This data is always provided to third-parties as quantified data (i.e. cumulative numerical data only with no identifying information relating to any data subject).
Personal data and some special category is collected.
It is essential to our primary function (providing classes to participants) that we are provided, and allowed to process and store the following:
Participant Personal Data:
Full Name – GDPR Article 6(1)(f)
Date of Birth – GDPR Article 6(1)(f)
Home Address – GDPR Article 6(1)(f)
Sex – GDPR Article 6(1)(f)
Permission to go home alone – GDPR Article 6(1)(f)
School/Educational Institution – GDPR Article 6(1)(f)
Exam results (vocational exams taken through Impresario Theatre School only) – GDPR Article 6(1)(f)
Classes attended/Price paid – GDPR Article 6(1)(f)
Participant Special Category Data:
Medical Information/History – GDPR Article 9 (a)
Disability Information – GDPR Article 9 (a)
Ethnicity – GDPR Article 9 (a& j) – further explicate consent sought
Gender/Sex – GDPR Article 9 (a& j) – further explicate consent sought
Sexuality – GDPR Article 9 (a& j) – further explicate consent sought
Parent/Guardian Personal Data:
Name – GDPR Article 6(1)(f)
Address – GDPR Article 6(1)(f)
Email Address – GDPR Article 6(1)(f)
Mobile Telephone Number – GDPR Article 6(1)(f)
Work/Home Number – GDPR Article 6(1)(f)
Emergency Contact Number – GDPR Article 6(1)(f)
Parent/Guardian Special Category Data:
Concession Type – further explicate consent sought
Documented proof of financial need – further explicate consent sought
Bank Details – further explicate consent sought in the instance of refunds etc.
Impresario Theatre School transports data with all due diligence. Enrolment forms are sent to Impresario Theatre School through an encrypted email server directly from our website which has controlled access. Received enrolment forms are stored on an encrypted email server for no more than 6 months. Received paper enrolment forms are destroyed after no more than 4 weeks.
Data received through enrolment forms is uploaded manually into our database software. Our database is stored both in encrypted files on office-based hardware and backed up regularly in our encrypted cloud-based server. Access to these files is restricted through password protection and only available to authorized staff members.
Hard copies of registers and emergency contacts are carried by authorized staff members. They are locked away while not in use. When they are no longer in use or out-dated, they are destroyed thoroughly.
Waiting lists are stored on an encrypted cloud-based server.
Our standard retention policy (without the data subject’s right to access, rectification and erasure etc.) is THREE YEARS post final attendance.
Exceptions to our retention policy:
Third Parties/Data Processors:
Impresario Theatre School does not actively share data with third parties, however there are certain instances where sharing information is crucial to our business processes.
Freelance Teachers: As many of Impresario Theatre School teachers are freelance staff, we have confidentiality and data processor agreements in place. Teachers will never be provided with personal details aside from participant’s names and any medical information that is pertinent to the running of a class.
NHS Track and trace:
Responding to the Coronavirus advice from the Government is an obligation on all schools in England. The development of the NHS ‘Track and Trace’ scheme is a key part of the government plan to manage Coronavirus. As we respond to Government guidance and the wider opening of leisure facility’s/dance schools, the safety and well-being of pupils, staff, visitors and their families is a priority. Plans to manage a safe return are in place, however our responsibility extends beyond the school gates. We hold a lot of data and, as part of our statutory duty, it may be necessary for us to share that data on request by Public Health with NHS Track and Trace workers, so that we play our part in making the programme as effective as possible. It is likely that we will be asked to provide contact details if a case of Coronavirus or a suspected case arises in our school. There is an obligation to support the Government and we will provide details if requested to do so. We will be sharing data on the basis that this is a Public Duty (see below) and that, in the case of any health data, it is necessary for the public interest, as set out.
Class Manager (‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
Class Manager are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
Child Performance Licensing:
In order to process child performance licences, Impresario Theatre School are legally required to provide some personal data to local councils (including but not limited to: full name, date of birth and school details). This is an optional consent, which will be sought at the time of sending participation consent forms. Impresario Theatre School is satisfied that their GDPR process is thorough and any data will be stored in a secure environment, and not unnecessarily retained.
Child Safeguarding Concerns:
In the unlikely event Impresario Theatre School has a safeguarding concern in relation to one of our participants, Impresario Theatre School are legally required to provide data to the safeguarding board at the local council. Impresario Theatre School is satisfied that their GDPR process is thorough and any data will be stored in a secure environment, and not unnecessarily retained.
Impresario Theatre School may occasionally produce programmes for events. These will only ever contain the first name and first initial of a child’s last name (unless otherwise consented to). The name of a child’s class may also be included. Participants/their Parent and/or Guardians may choose if they want to be included in the programme when they agree to participate at an event.
In order to enter examinations, Impresario Theatre School must provide some personal data to examination boards (currently Impresario Theatre School work with: LAMDA. This sharing of data is to be consented to by the data subject and/or parent/guardian upon being entered for the exam.
Impresario Theatre School must sometimes share personal data with schools (names, DOB and payment information) when taking part in an internal class in order for them to check persons attending. This also helps the school work out Impresario Theatre School’s payment in terms of renting space. Impresario Theatre School is satisfied that their GDPR process is thorough and any data will be stored in a secure environment, and not unnecessarily retained.
Any data subject with personal data stored within Impresario Theatre School is entitled to the rights of:
You may contact Impresario Theatre School at any time to access all data held relating to you and/or your children. Impresario Theatre School will ensure that we respond to a subject access request without undue delay and within one month of receipt. If the information request will also include data regarding others, Impresario Theatre School has the right to refuse the request or take steps in order to obtain consent from other involved parties. The right of access does not apply to Impresario Theatre School’s legal obligations such as Child Safeguarding records.
You may contact Impresario Theatre School at any time in order to rectify data held relating to you and/or your child(ren). Impresario Theatre School will ensure that we respond to a rectification request without undue delay and within one month of receipt. The right to rectification does not apply to Impresario Theatre School’s legal obligations such as payment record information.
You may contact Impresario Theatre School at any time in order to erase data held relating to you and/or your child(ren). Impresario Theatre School will ensure that we respond to an erasure request without undue delay and within one month of receipt. The right to erasure does not apply to Impresario Theatre School’s legal obligations such as First Aid records.
You may contact Impresario Theatre School at any time in order to restrict the data we process relating to you and/or your child(ren). Impresario Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt. However, due to our legitimate interest in most of the data collected- we may have to revoke your membership with Impresario Theatre School until the restriction is lifted. This is due to Health and Safety and Child Safeguarding.
You may contact Impresario Theatre School at any time in order to obtain the data we process relating to you and/or your child(ren) and reuse it across different services. Impresario Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt. Please note, this does not apply to Impresario Theatre School’s legal obligations.
You may contact Impresario Theatre School at any time in order to object to the processing of data relating to you and/or your child(ren). Impresario Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt.
However, due to our legitimate interest in most of the data collected- we may have to revoke your membership Impresario Theatre School until the restriction is lifted. This is due to Health and Safety and Child Safeguarding.
Rights related to automated decision making including profiling
You may contact Impresario Theatre School at any time in order to object to profiling relating to you and/or your child(ren). Impresario Theatre School will ensure that we respond to a request to restrict processing without undue delay and within one month of receipt. However, due to our legitimate interest in most of the data collected- we may have to revoke your membership with Impresario Theatre School until the profiling restriction is lifted. This is due to Health and Safety and Child Safeguarding. Impresario Theatre School has a lawful reason for profiling; Legitimate Interests and consent. None of Impresario Theatre School’s decision making is automated. Profiling is only used in circumstances where a participant may have certain health/disability needs which may prevent them from taking part in classes (as it would be unsafe to do so).
Any and all verbal requests are noted, and then contacted again either via phone or email to verify the request. Verbal requests will be responded to in the time frames mentioned above.
Impresario Theatre School often use footage/photos used from shows, performances and classes for marketing purposes both in print media and the website. Participants/their Parent and/or Guardians may choose if they do not wish themselves/their child to be depicted.
Some attendees at events may film/take photos for their own personal use (e.g. parents of other participants). Participants/their Parent and/or Guardians may choose if they do not wish themselves/their child to be depicted.
Impresario Theatre School regularly share photos/videos of students in class, workshops, events and performances through social media platforms including; Instagram, Facebook, Email. These will never be shared with any identifying information (age, location etc.). There may be times where we will share first names, but only with the explicit consent of the parents. All members of staff (PAYE, Freelance and Voluntary) must agree to this Data Protection policy prior to accepting a contract of employment.
Complaints in regard to the handling of any personal data can be made directly to Impresario Theatre School’s DPO: (Amy Rackliff Principal).
If you feel that your complaint was not handled in the correct manner, or still have concerns, you may escalate the complaint by contacting the Independent Commissioner’s Office (ICO).
ICO Telephone Number: 0303 123 1113
If Impresario Theatre School experiences a data breech of any kind, we have a legal obligation to report this to ICO within 72 hours. The data breech will be reported by the DPO. In the instance they are unavailable to report the breech, the next most senior staff member shall do so. Impresario Theatre School will also inform all the victims of the data breech as soon as possible if there is a high risk of adversely affecting individuals’ rights and freedoms. Impresario Theatre School will store and record all data breeches.
Facebook Page (for users) GDPR Policy
Purpose and Statement:
Impresario Theatre School uses a Facebook page to advertise its services and connect/share with its’ (and a wider) audience. The web address for our Facebook page is: www.facebook.com/impresariotheatreschool
Impresario Theatre School is able to process some personal data from interactions with our Facebook page, which is described below, however how Impresario Theatre School processes this data is very limited.
Review and monitoring of policy:
Types of Facebook Posts:
If you communicate with impresario theatre school via the page we will respond to your communications & make information available to you that is relevant to those communications. If you choose to ‘like’ the page, you can ‘unlike’ at any time.
As a public Facebook page all communication you share to the page can be seen by anyone. If you need to discuss anything privately with impresario theatre school please contact the office.
Administrators of Facebook Pages can obtain anonymous statistical data on visitors to the page, and those who ‘like’ the page via a function called ‘Facebook Insights’ which Facebook makes available to them free of charge under non-negotiable conditions of use.
The data is collected by ‘cookies’, each containing a unique user code, which are active for two years and are stored by Facebook on the device used by visitors to the page. This user code, which can be matched with the connection data of users registered on Facebook, is collected and processed by the Facebook Insight programme.
Anonymous Data our Facebook Page collects:
How impresario theatre school may use this data:
How Impresario Theatre School retain/archive this information:
Impresario Theatre School do not remove any of this anonymous data from Facebook (a GDPR compliant company), except in the instance of reporting the effectiveness of advertising campaigns.
Administrators of Facebook Pages can obtain limited personal data about people who choose to ‘like’ and/or ‘follow’ the page and/or communicate with the page.
A Facebook user’s Name is actively sent by Facebook to the page administrator as a notification.
The Facebook page contains a list of all users who ‘like’ or ‘follow’ the page.
Administrators are also able to access the profile of those who choose to ‘like’ and/or ‘follow’ the page and/or communicate with the page.
How Impresario Theatre School retain/archive this information:
No record of names are removed from Facebook or used for any purpose.
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