At Perform For Life we are committed to safeguarding and preserving the privacy of our students and their parents / guardians. We understand that families will wish to feel safe in the knowledge that their data is kept secure.
This Policy explains what happens to any personal data that you provide us with, how we use it and how we keep it secure.
By providing your personal data to us, you agree to the transfer, storing and processing of your data.
Parents/Guardians are informed about and strongly advised to read our Safeguarding, Behaviour and Privacy Policies in our Terms & Conditions, which must be accepted at the time of registration with PFL.
This Policy is reviewed annually or in instances of legislative change. Monitoring is part of Management and Supervision. We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. This policy was last updated in October 2019.
We ask that you read this Policy carefully, and contact Katrina with any questions or concerns on email@example.com.
What legal basis do we have for processing your personal data?
(1998) and the EU’s General Data Protection Regulation (GDPR).
PFL has determined the lawful reasons with which it processes personal data, in line with Article 6 of the GDPR:
- Consent (a)
- Contract (b)
- Legal obligation (c)
- Legitimate interest (f)
What data do we collect?
Basic contact details: We ask you to provide us with details such as your name, your child’s name, email address, school name, together with postal address, telephone number and any medical conditions your child may have. This will help us understand your child’s needs and enable us to contact you regarding the service being provided.
Photos / Videos: Data we hold covers images (photographic and video) taken during classes / workshops / performances. Consent for the creation and marketing use of these images is given by parents / guardians on signing and agreeing to our Terms and Conditions when submitting a Registration Form. These will never be shared with any identifying information (full names, age, location etc.). There may be times where we will share first names, but only with the explicit consent of Parents/Guardians. Students / Parents/Guardians may choose if they do not wish their child to be depicted – please contact us on firstname.lastname@example.org.
Students under 16: In some circumstances we will request your consent to use certain information for specified purposes. In such circumstances you will have the free choice to give, refuse or withdraw consent. In the case of personal data relating to a child under the age of 16, we will require the consent of a parent or legal guardian. Individuals aged 16 or over may give, refuse or withdraw consent (whether the consent was originally given by themselves or on their behalf) themselves.
Marketing: We will store your consent to receive updates / for marketing purposes.
General: We will also store information that you provide when you communicate with us by any means, so long as it is relevant to the service we provide.
Income: Income information is only collected in instances where a participant applies to attend our classes at a concessionary price, or on a bursary.
Legal requirements: While it is unlikely, PFL may be required to disclose your user data by a court order or to comply with other legal requirements. We will endeavour to inform you of this requirement wherever possible, unless we are legally restricted from doing so.
Why do we collect data?
We use the information that we collect from you to:
- provide our services to you
- provide the particular service you’ve requested
- offer you a personalised experience and understand your needs better
- analyse and continually improve the services we offer, including our website and our other products
- keep you informed in the event that a member of PFL staff or anyone they have had direct contact with has tested positive for Covid-19
We do not request anything that is not absolutely required.
Access to data is restricted to members of PFL staff only, in order to provide our services to you, as listed above.
To attend any of PFL’s activities, students / parents/guardians must agree to some processing of their personal data. This is due to Article 6, part (c) of the aforementioned lawful reasons for processing data. Should PFL be unable to process the data of a student, we would be ignoring best practice for working with children and young people. 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 tuition, including dividing students into age groups, and to confirm that your child/children wish to participate in the services we provide.
How and when do we collect data?
Generally, we collect your information when you decide to interact with us. This could include you sending us your details online, over the phone or in person. We also collect personal data from you when you register your son / daughter for tuition with us, or when you receive emails for the purpose of marketing.
Where is data stored?
PFL transports data with all due diligence, and will, at all times, keep data in secure locations (including, but not limited to, encrypted, password-protected and access-restricted files).
In operating our website it may become necessary to transfer data that we collect from you to locations outside of the European Union for processing and storing. By providing your personal data to us, you agree to this transferring, processing and storing.
We do our utmost to ensure that all reasonable steps are taken to make sure that your data is stored securely. Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically, sending such information is entirely at your own risk.
Registration forms are sent to PFL through an encrypted email server directly from our website, which has controlled access. Received enrolment forms are stored on an encrypted email server.
How is the data used?
PFL will use data given by you to provide our services to you. This can include aspects such as to contact students and parents / guardians, to plan lessons and lesson timetables, and to contact you about other services we feel may be of interest to you (by submitting an Registration form to PFL, you are deemed to consent to the use of such data for this purpose). Please also refer to ‘What data do we collect?’ and ‘Why do we collect data?’.
How long is the data stored?
The following records are retained for the following times:
- Parental Consent forms and Incident Reports are kept indefinitely for the protection of our organisation
- Financial records are kept for 6 years due to legal obligation
- First Aid records are kept for 21 years due to legal obligation
- 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.
PFL ensures you’re in control of your data. You may contact us at any time to:
- provide you with full details of any personal data we hold about you. The right of access does not apply to PFL’s legal obligations such as Child Safeguarding records. The providing of any personal data we hold about you will be subject to the supply of appropriate evidence of your identity. If the information requested will also include data regarding others, PFL has the right to refuse the request or to take steps to obtain consent from other involved parties.
- rectify data held relating to you and/or your child(ren). The right to rectification does not apply to PFL’s legal obligations such as payment record information.
- to restrict the data we process relating to you and/or your child(ren). However, due to our legitimate interest in most of the data collected – we may have to place a hold on a student’s tuition until the restriction is lifted for PFL’s legal obligations such as Health and Safety and Child Safeguarding.
- withdraw your consent for the processing of your data for a specific purpose (please refer to ‘Introduction’ and ‘Why do we collect data?’ for details on the processing of your data for general purposes). The right to withdrawing your consent for specific purposes does not apply to PFL’s legal obligations such as Child Safeguarding records.
- withdraw your consent for the use of images (please contact us on email@example.com to request a Use of Images Refusal form).
- request the removal of any or all of your details. The right to erasure does not apply to PFL’s legal obligations such as First Aid records.
- change your communications’ preferences or unsubscribe from future communications.
Please note, we reserve the right to charge a fee of £10 to cover costs incurred by us in providing you with this information.
Please email a description of your request or the data you would like to see, together with proof of your identity, to firstname.lastname@example.org. The request will be completed within 5 working days of your request.
When dealing with a request from a child relating to any of the above rights, we will need to make a decision on whether the information should be provided to them or to their parents / guardian, and will be guided by the individual’s age at the time of request and their level of understanding about what they are requesting and why. For these purposes, we take the view that most children will reach this level of understanding at around age 16.
PFL does not sell, rent or distribute any personally identifying data from our students / parents/guardians to third parties for commercial purposes.
There are instances when sharing information with a third party is crucial to the provision of our services, such as sharing necessary information with:
- exam boards such as LAMDA, ABRSM, Trinity College London and RSL (to be consented to by the data subject and/or parent/guardian upon being entered for the exam)
- your child(dren)’s school (when they are taking part in an internal lesson and their PFL teacher is required to check persons attending, as well as the School being aware of the whereabouts of that child)
In the rare instance a data processor is not a PFL staff member, such as a third party, the data subject will either be asked for consent previous to supplying the data or will be notified and have the right to object to processing. Examples are the above, as well as competition organisers, photographers and survey providers. If you choose to take part in activities that require administration by third parties, you choose to opt in for contact from and the sharing of data with those organisations. Having given your consent for the sharing of your data with these organisations, PFL is no longer responsible for that data and how it is stored with these organisations. Please ensure you check their Privacy Policies.
Third parties on our website:
Please see more in our ‘Our Website, Cookie Use and External Links / Social Media’ section later on in this policy.
Child Safeguarding Concerns:
In the unlikely event PFL has a safeguarding concern in relation to one of our participants, we are legally required to provide data to the safeguarding board at the local council.
PFL 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. Students / Parents/Guardians may choose if they want to be included in the programme when they agree to participate at an event.
Our Website, Cookie Use and External Links / Social Media
Our website and cookies
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience.
A cookie is a piece of information in the form of a very small text file. The information the cookie contains is set by the server and it can be used by that server whenever the user visits the site. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website. It will not store, save or collect personal or confidential information.
This usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We may process this usage data using Google Analytics. This information is important to help us continually improve our services and the experience of users of the website. For more information, visit the Google Analytics privacy page.
Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
You can adjust the settings on your computer to decline any cookies if you wish. This can be done within the “settings” section of your computer. For more information please read the advice at aboutcookies.org.
Our website aims to include quality, safe and relevant external links only. However, users should always adopt a policy of caution before clicking any external web links mentioned throughout our website. The owners of our website cannot guarantee or verify the contents of any externally linked website, despite their best efforts. Users should therefore note that they click on external links at their own risk, and our website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that our website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively. Users are advised to use social media platforms wisely and communicate / engage on them with due care and caution with regard to their own privacy and personal details. Our website nor its owners will ever ask for personal or sensitive information through social media platforms, and encourage users wishing to discuss sensitive details to contact them on email@example.com.
Our website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Our website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy url’s (website addresses – for example: http://bit.ly/zyVUBo). Users are advised to take caution and good judgement before clicking any shortened url’s published on social media platforms by our website website and its owners. Despite the best efforts to ensure only genuine URLs are published, many social media platforms are prone to spam and hacking and therefore our website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Our Communications to you
By registering your son/daughter for tuition with PFL, you give us consent to place you on our mailing list, through which you’ll receive information about other services we offer which may be of interest to you. Please write to us via email if you’d rather not receive these emails and we’d be happy to remove you from our mailing list.