Harmonia Music is committed to protecting your privacy. This Statement of Privacy applies to the Harmonia Music website and governs data collection and usage. By using the Harmonia Music website, you consent to the data practices described in this statement.


Data Protection policy for Kirsty Body, Musical Director at Harmonia Music
Key details ·
Policy prepared by: Kirsty Body trading as Harmonia Music (KB) ·
Next review date: 15/4/2019

Introduction
In order to operate, KB needs to gather, store and use certain forms of information about individuals.
These can include adult pupils, parents of pupils, Harmonia Music group members, audiences and potential audiences, contractors, suppliers, business contacts and other people that KB has a relationship with or regularly needs to contact.
This policy explains how this data is collected, stored and used in order to comply with the General Data Protection Regulations (GDPR).

Why is this policy important?
This policy ensures that KB:
Protects the rights of parents and pupils, and group members
Complies with data protection law and follows good practice
Protects parents and pupils, and group members from the risks of a data breach

Who and what does this policy apply to?
It applies to all data that KB holds relating to individuals, including: Names, Email addresses, Postal addresses, Phone numbers, Any other personal information held (e.g. financial)

Roles and responsibilities

KB is the Data Controller and will determine what data is collected and how it is used. She is responsible for the secure, fair and transparent collection and use of data.
KB uses third party Data Processors (Google Drive) to process data on its behalf. KB will ensure all Data Processors are compliant with GDPR.


DATA PROTECTION PRINCIPLES
a. I fairly and lawfully process personal data in a transparent way
KB will only collect data where lawful and where it is necessary for the legitimate purposes of her teaching business.
A pupil's and parent's/adult's name and essential contact and administrative details will be collected when they first register interest in Harmonia Music activities, and will be used to contact the parent/adult regarding timetabling of lessons/rehearsals and other routine communications.
An individual's name, contact details and other details may be collected at any time, with their consent, in order for KB to communicate with them about and promote extra-curricular activities, events connected with her teaching such as workshops and playing days, and events in which she appears as a performer. See 'How we get consent' below.
A pupil's progress will be recorded in lesson notes which are stored on Google Drive.

b. I only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes.
When collecting data, KB will always provide a clear and specific privacy statement explaining to the subject why the data is required and what it will be used for.

c. I ensure any data collected is relevant and not excessive
KB will not collect or store more data than the minimum information required for her intended purpose.

d. I ensure data is accurate and up-to-date
KB will ask parents/adults to check and update their data on an annual basis. Any individual will be able to update their data at any point by contacting KB.

e. I ensure data is not kept longer than necessary
KB will keep records for no longer than is necessary in order to meet the intended use for which it was gathered (unless there is a legal requirement to keep records).
The storage and intended use of data will be reviewed in line with KB's data retention policy. When the intended use is no longer applicable (e.g. contact details for the parent of a pupil who has stopped having lessons), the data will be deleted within a reasonable period.

f. I keep personal data secure
KB will ensure that data held is kept secure.
Electronically-held data will be held within a password-protected and secure environment
Physically-held data will be stored on a locked cupboard
Access to data will only be given to any third party with the parent's explicit consent, and where it is clearly necessary for the running of KB's music business. KB will keep a master list of who has access to data in this case. Eg exam boards.

g.Transfer to countries outside the EEA
KB will not transfer data to countries outside the European Economic Area (EEA), unless the country has adequate protection for the individual's data privacy rights.


INDIVIDUAL RIGHTS
When KB collects, holds and uses an individual's personal data that individual has the following the rights over that data. KB will ensure her data processes comply with those rights and will make all reasonable efforts to fulfil requests from an individual in relation to those rights.
Individual's rights
Right to be informed: whenever KB collects data she will provide a clear and specific privacy statement explaining why it is being collected and how it will be used.
Right of access: individuals can request to see the data KB holds on them and confirmation of how it is being used. Requests should be made in writing to KB and will be complied with free of charge and within one month. Where requests are complex or numerous this may be extended to two months
Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. KB will request that members of Harmonia Music check and update their data on an annual basis. Any requests for data to be updated will be processed within one month.
Right to object: individuals can object to their data being used for a particular purpose. KB will always provide a way for an individual to withdraw consent in all marketing communications. Where KB receives a request to stop using data she will comply unless she has a lawful reason to use the data for legitimate interests or contractual obligation. Right to erasure: individuals can request for all data held on them to be deleted. KB's data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected.
If a request for deletion is made she will comply with the request unless: There is a lawful reason to keep and use the data for legitimate interests or contractual obligation. There is a legal requirement to keep the data.
Right to restrict processing: individuals can request that their personal data be 'restricted' - that is, retained and stored but not processed further (e.g. if they have contested the accuracy of any of their data, KB will restrict the data while it is verified).

Data retention policy 
Introduction
This policy sets out how KB will approach data retention and establishes processes to ensure data is not held for longer than is necessary. It forms part of KB's Data Protection Policy.

Roles and responsibilities
KB is the Data Controller and will determine what data is collected, retained and how it is used. She is responsible for the secure and fair retention and use of data.

A regular review of all data will take place to establish if KB still has good reason to keep and use the data held at the time of the review.
As a general rule a data review will be held every 2 years and no more than 27 calendar months after the last review. The first review took place on 15th April 2018.

Data to be reviewed
Digital documents (e.g. spreadsheets) stored on personal devices
Data stored on third party online services e.g. Google Drive 

Who the review will be conducted by
The review will be conducted by KB.

How data will be deleted
Physical data will be destroyed safely and securely, including shredding.
All reasonable and practical efforts will be made to remove data stored digitally.
Priority will be given to any instances where data is stored in active lists (e.g. where it could be used) and to sensitive data.
Where deleting the data would mean deleting other data that KB has a valid lawful reason to keep (e.g. on old emails) then the data may be retained safely and securely but not used. 

Criteria
The following criteria will be used to make a decision about what data to keep and what to delete.

 QuestionAction 
  YesNo 
Is the data stored securely?No action necessary 
Update storage protocol in line with Data Protection policy
Does the original reason for having the data still apply?Continue to useDelete or remove data
Is the data being used for its original intention? Continue to useEither delete/remove or record lawful basis for use and get consent if necessary
Is there a statutory requirement to keep the data?Keep the data at least until the statutory minimum no longer applies  Delete or remove the data unless there is reason to keep the data under other criteria
Is the data accurate?Continue to use Ask the subject to confirm/update details
Where appropriate do we have consent to use the data?This consent could be implied by previous use and engagement by the individualContinue to use Get consent
Can the data be anonymisedAnonymise dataContinue to use

Statutory Requirements
Date stored by KB may be retained based in statutory requirements for storing data other than data protection regulations. This might include but is not limited to:
Details of payments made and received (e.g. in bank statements and accounting records)
Contracts and agreements with suppliers/customers 

Member data
When a pupil stops having music lessons with KB, or permanently leaves a Harmonia group, and all administrative tasks relating to their tuition have been completed, any potentially sensitive data held on them will be deleted.
When tuition stops, the sharing link to the pupil's lesson notes on Google Drive will be deactivated. KB will retain the document but in an anonymised form.
Unless consent has been given data will be removed from all email mailing lists.
All other data will be stored safely and securely and reviewed as part of the next two year review.

Mailing list data
If an individual opts out of a mailing list their data will be removed as soon as is practically possible.
All other data will be stored safely and securely and reviewed as part of the next two year review.