A Mind Apart Theatre Company Limited (A Mind Apart) takes the privacy of our customers very seriously and aims to communicate our policies in the easiest and most transparent way. We are registered with the Information Commissioner Office under Registration Number Z3313945, and have been since 31st August 2012.
This Privacy Notice sets out to sum up our ‘Data Protection: GDPR Policy’, for those using our services, in a customer friendly manner. You can read our full detailed A Mind Apart Data Protection Policy GDPR by clicking here.
Why do we need a Privacy Notice?
From 25th May 2018 there is a new piece of legislation called GDPR that all organisations and companies will have to follow by law. The GDPR aims to make the processing of personal data more secure and enables individuals to understand and control how their information is used and what is being held by companies in a world of technology.
The purpose of the GDPR is to ensure that you have the ‘rights and freedoms’ around your personal information and to make sure that it is never processed without your knowledge and consent.
What information do we collect?
We will never ask for information from you unnecessarily. We may collect the following information from you when you register for any of our services:
- Contact Number(s)
- Email Address
- Contact methods you would like us to use when we contact you in regards to the service you register for
- Consent for us to send you information on other services that we deliver
- Name of any children or students you register for our services
- Address of any children or students you register (if different to the parents address registering them)
- Date of Birth of your child or students (including children where parents are registering them)
- Medical conditions and special educational needs (SEN) of your child or students
- The school your child or the student is attending (this is for After School clubs and Alternative Education only)
- Consent for using photos for marketing (includes use for online marketing)
- Consent for using videos for marketing purposes (includes use for online marketing)
- How you heard about our services
- The relationship you have to any children you are registering for our services
- Whether your child is registered with the Sheffield Children’s University or not.
This list may vary from service to service. For example we do not require to know about Children’s University if you are registering for an adult service, or we may request less information when you are registering or buying a ticket for one of our events. We will always work hard to make sure we only ask for what we absolutely need to be able to run that service safely and efficiently.
Other information we might collect
We may hold information we receive when you send use emails or text messages. We may also hold;
- Photographs and videos of your child (where we have your written permission for this)
- Children’s University records
- Records from Safeguarding and Health and Safety Incident Reports
Registering for our sessions
Students under sixteen must always be registered for our sessions or events by a parent or carer. Where you are registering a child over sixteen, but under eighteen, for our services, you must make sure you have full consent to provide their details. You must never register an individual over eighteen on their behalf for our services unless you are able to prove that they are physically unable to do so themselves.
Who is responsible for safeguarding the personal data we hold?
A Mind Apart Theatre Company Limited is a Data Controller, which means that we decide how your personal information is processed. The person responsible for Data Protection is our Data Protection Officer, currently, Jodie Marshall. Should you have any concerns or questions about your data and how we process it you can contact her on the details below:
A Mind Apart Theatre Company Limited, 57 Burton Street, Hillsborough, Sheffield S6 2HH
We only process data where we can demonstrate a very clear lawful basis according to the new GDPR legislation. These can vary according to the services that you are accessing, but we will always make sure we can demonstrate one of the eight lawful basis below for processing your data:
- Legal Obligation
- Vital Interests
- Public Task
- Legitimate Interest
- Special Category data
- Criminal Offence data
We do not use automated decision making in any of our services.
Why do we need the information we hold for you?
There are a range of reasons we need your personal information at A Mind Apart, and this can often vary depending on the service that is being accessed by the individual. If you are not willing to share the information we require from you above, we may not be able to provide you with the service you or your child wish to access. This is because the information is used for our day to day administration of your account and to safeguard your child and yourself whilst you are accessing our services.
Below are some of the ways we use your information:
- To manage your payment of out fees
- To keep an up to date summary of your account
- To answer your questions
- To make our registration process as fast and efficient as possible
- To market and promote our service effectively
- To make sure we are providing services in line with the needs of our students and parents
- To keep you up to date about classes and sessions (for example, we may text you to tell you a class or session has been cancelled)
- To tell you about other products and services we think you may be interested in by A Mind Apart (we only do this is you give us your consent on registration or via the customer portal)
- To ensure that you or your child is enrolled in the correct class or session with us.
- To make sure you or your child is safe in our sessions whilst our teachers are teaching you.
We do not collect any information unnecessarily and we will never pass your information on to third parties for marketing purposes. We do, however, need to share some of your information with third parties in order to efficiently manage your account.
Who do we share your information with and why?
We work hard to limit who we share your information with and only share it where we have a very clear lawful and legitimate reason to do so.
We work with a UK based technology company called ThinkSmart Software, who have developed the Customer CRM system that we use to maintain customer information and the online registration and customer portal. The system we use is called DanceBiz. We have made sure that all your personal information is safe in their hands; encrypted and secure to the highest levels. They do not transfer any of your personal data outside of the EU, and we maintain a data agreement and contract with them.
Below is a list of who we share your personal data with and why they need it shared with them.
- The Children’s Unviversity – If your child is registered with them and you have informed us on your registration or via the customer portal (attendance to our sessions, name of student, Date of Birth and school may be shared in this case).
- Your Local Authority – This may be the case if a student has been referred to us for our Alternative Education Programme through contracts we hold with Local Authorities.
- Local Schools – This may be the case if a student has been referred to us for our Alternative Education Programme by the school, or for students attending our after school clubs (For example: register, attendances incidents or health and safety concerns are shared with the relevant school where we deliver after school clubs).
- Google Drive – We use 2 way password verification with google drive and may store health and safety and safeguarding information on here. In such cases, all individual documents are also password protected. Google Drive is encrypted.
- Stripe – Our online payment processor (for their full policy and how they use your data visit https://stripe.com/gb/privacy ).
Your data may also be shared with other third parties when we are legally obliged to do so. We will only do this is the law requires it of us.
How long do we keep your data?
A Mind Apart only keeps your personal information and data for as long as is absolutely necessary. Sometimes we have to retain data to comply with company or HMRC laws and regulations, in these cases we follow their guidelines and retain it for as long as the law states.
If you no longer attend classes or use our other services with us, we will keep your account open for 1 academic year, if you have not given photo consent. If you have given photo consent the account will remain open for 2 academic years. This is to allow you to access your account if you or your child wishes to access any of our other classes, sessions or services, or for you to register a sibling. It also allows us to retain any consent for photos that we published during the time that your child was with us (see below for full details on our policy around photos and videos).
Where you are registered for our customer portal, access will be revoked after 1 year, and your account made inactive. We will delete any student and child information we hold, but will retain customer information for 7 years and in line with HMRC regulations. After this time all you information will be deleted and any paper records we hold shredded (this also includes customer data we hold from services such as Children’s Parties).
You can also contact us at any time and ask us to make your account inactive. We are only able to do this if you or your child is not enrolled in any classes or services with us at that time. Although the account will be made inactive and we are able to delete any student details upon request, customer details will still need to be retained for the purposes of complying with HMRC and Companies House.
Where you are accessing any of our events, we work hard to minimise the data we need from you, and focus on a ticket service that enables you to buy a ticket for our events in order to limit the personal information we need from you. On rare occasions where we do retain any basic personal information (such as emails in order to be able to contact you if there are any changes to the event), these are deleted and securely destroyed as soon as the event is finished. If you have ticked that you would like to receive further marketing information from us when registering for the event, we will retain your details and use them to keep you updated with events until you tell us to no longer do so.
Communicating with you
In A Mind Apart we use emails and text messages to communicate important information to you. This includes telling you about changes to class times, teachers, class cancellations, your fees, and further opportunities and information in relation to the service you or your child are accessing.
We will only contact you about others services unrelated to your class if you have ticked yes to receiving information about other services we have. Such services would include other sessions we think your child, or you, might be interested in (such as holiday clubs or adult workshops). If you did not tick yes, you can still access all the information on other services we are delivering via the website or customer portal.
We never pass your information on to third parties for marketing purposes. Our marketing emails and any other emails or text messages sent to you are managed via our customer system with Thinksmart Software.
What do we do with photos and videos of you or your child?
We love to take photos and videos of what we do and share them in our marketing and social media. However, we are aware that this is not appropriate for all individuals and that some parents are not happy with this. We completely understand this and are very careful about making sure we have consent for videos and photos across all of our services.
We will only take and retain photos or videos of you or your child if you have given us permission when you registered. Consent for photos and videos can be changed at any time on your account via the customer portal or by speaking with your teacher (who will change them on the system in front of you). Where the individual is a child or vulnerable adult, consent must be given by the parent or carer.
It is sometimes difficult to monitor who are in our photos at events such as performances. Because of this, we check all of our photos and videos before we publish them anywhere, making double sure we have consent or that consent hasn’t been changed since the photo or video was taken. Where consent is not given, the photo or video with the individual is deleted. This is sometimes difficult to do on videos, so on rare occasions we fuzz the individual our, making sure they are not recognisable.
We never publish names with photos or videos and require extra written permission on occasion where we want to celebrate a student or individual for their achievement or successes with us.
At A Mind Apart events, we will let you know whether or not photos and videos are allowed. Where we do allow them, you must not publish any with children other than your own onto social media. We regularly publish photos where we have consent onto our social media channels so that you can share and like them.
Requesting your personal information to be deleted
Under the new regulations, you have a ‘right to be forgotten’. This means that we will delete or deactivate it upon your request. We will not do this if your child is still enrolled in classes, because we need to retain the personal information we request from you in order to safeguard your child and administer your account effectively. We will also be unable to delete your personal information if you have outstanding fees with A Mind Apart, as we reserve the right to take civil action against anyone who has not paid fees that are owing to us.
Accessing the data we hold for you
Individuals have a right to access any personal data relating to them which is held by A Mind Apart. As much as possible we work to make any data we hold for you or your child readily available to you through our customer portal. However, there may be data that is not easily accessible to individuals such as qualification achievements, incident reports, photos and videos or personal data received by A Mind Apart from third-parties. Where an individual wishes to request access to all personal data they should apply in writing to the Data Protection Officer via the details given in this notice.
A Mind Apart reserves the right to charge a ‘reasonable fee’ for administrative costs of complying with data access requests that are manifestly, unfounded or excessive.
Under the terms of the legislation, any such requests must be complied with within one (1) calendar month.
Cookies and how we use them
The following is strictly necessary in the operation of our website.
Our Website will remember when you are logged in and that your session is secure.
The following are not Strictly Necessary, but are required to provide you with the best user experience and also to tell us which pages you find most interesting (anonymously).
Our website will use Functional Cookies to track the pages you visit via Google Analytics. It will use Targeting Cookies to allow you to share with social media networks such as Facebook or Twitter.
Our website will not share any personal information with third parties.
For further information on GDPR and data protection, or to make a complaint to them, you can visit the Information Commsioners Office (ICO) website at https://ico.org.uk/