Conductive Music CIC ( or CM) is committed to protecting your personal information and being transparent about what information we hold about you.
This privacy notice is intended for:
• Partners and Funders of CM;
• Schools, including teachers and headteachers, in which we deliver tuition;
• Pupils participating in online activities, as well as out-of-school workshops;
• Tutors operating as self-employed contractors on behalf of CM;
• Donors, benefactors and supporters of CM.
The purpose of this policy is to give a clear explanation as to how CM uses the information we collect from the above parties. CM is a ‘data controller’.
The lawful basis for obtaining and using personal data
CM needs data in order to fulfil its contractual obligations with parents and schools in order to provide them with the education for which they or their children have applied. Parents or guardians with children under the age of 16 will act on behalf of their children. Children over 16 years of age are deemed competent to understand this privacy statement.
We will only process personal data where we have one of six ‘lawful bases’ to do so under Article 6 of the EU General Data Protection Regulations.
• To fulfil a contract with the individual, or when the individual has asked CM to take specific steps before entering into a contract;
• For the legitimate interests of CM (provided the individual’s rights and freedoms are not overridden);
• Where the individual (or their parent/carer if under the age of 16) has freely given consent.
• To comply with a legal obligation;
• To ensure the vital interests of the individual e.g. to protect someone’s life;
• To perform a task in the public interest.
The personal data we hold
CM will use the information you provided in your initial application and may supplement this with additional information which you provide following this.
Personal data that we may collect, use, store and share (see Data Sharing below) about individuals includes, but is not restricted to:
• Your full name, title;
• Email address and phone number;
• Attendance information;
• Photographs and video recording (see below);
Why we use this data
We use this data to:
• Administer, organise and deliver workshops, both in and out of school;
• Manage students’ registration, participation in, and progression through CM programmes including school based music activities;
• Support student learning;
• Monitor and report on student progress;
• Provide appropriate pastoral care and ensure welfare of children while in our custody, particularly when on tours and residential courses;
• Protect student welfare and meet our legal obligations relating to child protection and safeguarding;
• Assess the quality of our services;
• Administer applicants waiting lists;
• Carry out research;
• Comply with contractual / regulatory obligations e.g. reporting to the Arts Council or other funders;
• Share with partners for joint activities;
• Keep you updated with CM activities that are relevant to you;
• Offer you opportunities to engage further with our activities;
• Keep in touch with our alumni;
• Generate publicity and advertise CM’s services;
• Celebrate the success of our students and raise awareness of their achievements;
Photographs and Video Recording
As part of CM’s activities, we will take photographs and record videos of groups and performers at events for which CM is an organiser or contributor. Such material will be used solely by CM for publicity e.g. prospectuses and other similar information about our company, displayed on our premises, on banners at concerts and on our website, assessment, educational and social media purposes, fundraising or other purposes to help achieve the our company’s aims.
When using photographs and videos for publicity, display or website purposes, we will not accompany them with any other personal information about the child, to ensure they cannot be identified. Although we will carefully use images on the basis of our ‘legitimate interests’ (see above), we understand there may be occasions where individuals give good reason why we should withdraw certain images.
If you ask us to withdraw an image with good cause, we will delete the photograph or video and not distribute it further. Images that might cause embarrassment or distress will not be used.
Where it is legally required, or necessary for the reasonable undertaking of our business activities (and it complies with data protection law) we may share personal information with:
• Schools – where we provide workshops for your child in partnership with their school;
• Central government (e.g. Arts Council England);
• Tutors operating as self-employed contractors on behalf of CM – to enable them to contact you directly regarding a child’s tuition or ensemble membership;
• Examination boards (e.g. Arts Awards) – to enter pupils for graded music examinations;
• Professional advisers and consultants;
• Police forces, courts, tribunals.
Security of your personal data
We will put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information confidential and as secure as possible. Your data will only be accessible to authorised staff and volunteers. We will ensure that any third parties we use for processing your personal information do the same.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Information will be stored for only as long as it is needed or required by statute and will be disposed of appropriately.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
We undertake to report any data breaches in accordance with Data Protection Act and General Data Protection Regulations guidelines.
Your rights to your personal information
You have the right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected. Please use the contact details at the end of this policy if you would like to exercise this right. As joint data controllers with schools, we will co-operate with valid requests from schools to supply them with information we hold about children who are joint students.
Contact details and further information
Please get in touch with us if you have any questions about any aspect of this privacy notice, and in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.
All enquiries relating to this policy and/or the storage of your personal information by CM should be addressed to:
Dr. Enrico Bertelli (Founding Director)
Conductive Music CIC