GDPR
London College of Performing Arts (LondonCollegePA) is dedicated to complying with the new GDPR rules that came into force on March 25th 2018. The following data protention policy applies to our collection of only necessary data that falls within the remit of a Performing Arts Sixth Form College. We retain the information necessary to administer our programmes and maintain the well-being of our students, many of whom are under 18.
On this basis, therefore, the following stipulations are made:
· LondonCollegePA will maintain and secure accurate contact details for the parents of its students;
· LondonCollegePA will also request a third-party emergency contact for use in the event that we cannot contact a parent – it is assumed that the parent has permission to deliver this third-party information;
· LondonCollegePA will store data securely in hard copy and online data will be secured with services only that are diligently compliant with GDPR regulations, namely Membermeister and GoCardless. These relationships are necessary to administer our programmes – only necessary information will be stored with these bodies;
· LondonCollegePA is required to maintain some information about the health and medical history of our students – this is for their safety and well-being.
· LondonCollegePA will never share with or sell your data to another organisation.
LondonCollegePA collects and uses information about people with whom it communicates.
This personal information must be dealt with properly and securely however it is collected, recorded and used – whether on paper, in a computer, or recorded on other material. LondonCollegePA regards the lawful and correct treatment of personal information as very important to the successful and efficient performance of its functions, and to maintain confidence between those with whom it deals. To this end LondonCollegePA fully endorses and adheres to the Principles of Data Protection, as set out in the The General Data Protection Regulation (GDPR) (EU) 2016/679.
Purpose
The purpose of this policy is to ensure that the staff, volunteers and trustees of LondonCollegePA are clear about the purpose and principles of Data Protection and to ensure that it has guidelines and procedures in place which are consistently followed.
Principles
GDPR policy pertains to the processing of information relating to living and identifiable individuals (data subjects). This includes the obtaining, holding, using or disclosing of such information, and covers computerised records as well as manual filing systems and card indexes.
Data users must comply with the data protection principles of good practice which underpin the Act. To comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully.
To do this LCPA follows the eight Data Protection Principles outlined below:
I. Personal data will be processed fairly and lawfully
II. Data will only be collected and used for specified purposes
III. Data will be adequate, relevant and not excessive
IV. Data will be accurate and up to date
V. Data will not be held any longer than necessary
VI. Data subject’s rights will be respected
VII. Data will be kept safe from unauthorised access, accidental loss or damage
VIII. Data will not be transferred to another country or territory
The principles apply to “personal data” which is information held on computer or in manual filing systems from which they are identifiable. LondonCollegePA’s employees, volunteers and trustees who process or use any personal information in the course of their duties will ensure that these principles are followed at all times.
Procedures
The following procedures have been developed in order to ensure that LondonCollegePA meets it’s responsibilities in terms of Data Protection. For the purposes of these procedures data collected, stored and used by LondonCollegePA falls into 2 broad categories:
1. LondonCollegePA internal data records;
Staff, volunteers.
2. LondonCollegePA external data records;
Members, customers, clients.
LondonCollegePA as a body is a DATA CONTROLLER under the Act, and the Directors are ultimately responsible for the policy’s implementation.
Internal data records
Purposes
LondonCollegePA obtains personal data (names, addresses, phone numbers, email addresses), application forms, and references and in some cases other documents from staff, volunteers. This data is stored and processed for the following purposes:
• Recruitment
• Equal Opportunities monitoring
• Volunteering opportunities
• To distribute relevantmaterial e.g. meeting papers
• Payroll
Access
The contact details of staff, volunteers and trustees will only made available to other staff, volunteers and trustees. Any other information supplied on application will be kept in a secure filing cabinet and is not accessed during the day to day running of LondonCollegePA.
Contact details of staff, volunteers and trustees will not be passed on to anyone outside LondonCollegePA without their explicit consent.
A copy of staff, volunteer, trustee emergency contact details will be kept in the Emergency File for Health and Safety purposes to be used in emergency situations e.g. fire/ bomb evacuations. Staff, volunteers and trustees will be supplied with a copy of their personal data held by LondonCollegePA if a request is made.
All post marked confidential must be opened by the addressee only.
Accuracy
LondonCollegePA will take reasonable steps to keep personal data up to date and accurate. Personal data will be stored for 6 years after an employee, volunteer or trustee has worked for the LondonCollegePA and brief details for longer. Unless LondonCollegePA is specifically asked by an individual to destroy their details it will normally keep them on file for future reference. The Director has responsibility for destroying personnel files.
Storage
Personal data is kept in paper-based systems and on a password-protected computer system. Every effort is made to ensure that paper-based data are stored in organised and secure systems.
LondonCollegePA operates a clear desk policy.
Use of Photographs
Where practicable, LondonCollegePA will seek consent from individuals before displaying photographs in which they appear. If this is not possible (for example, a large group photo), the LondonCollegePA will remove any photograph if a complaint is received. This policy also applies to photographs published on the LondonCollegePA website or in a Newsletter.
Criminal Records Bureau
LondonCollegePA will act in accordance with the CRB’s code of practice.
Responsibilities of staff, volunteers and trustees
During the course of their duties with LondonCollegePA, staff, volunteers and trustees will be dealing with information such as names/addresses/phone numbers/e-mail addresses of members/clients/volunteers. They may be told or overhear sensitive information while working for LondonCollegePA. The Data Protection Act (1988) gives specific guidance on how this information should be dealt with. In short to comply with the law, personal information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. Staff, paid or unpaid must abide by this policy.
Compliance
Compliance with the Act is the responsibility of all staff, paid or unpaid. LondonCollegePA will regard any unlawful breach of any provision of the Act by any staff, paid or unpaid, as a serious matter which will result in disciplinary action. Any employee who breaches this policy statement will be dealt with under the disciplinary procedure which may result in dismissal for gross misconduct. Any such breach could also lead to criminal prosecution.
Any questions or concerns about the interpretation or operation of this policy statement should in the first instance be referred to the line manager.
Retention of Data
No documents will be stored for longer than is necessary. All documents containing personal data will be disposed of in accordance with standard Data Protection principles.