CAMBRIDGE SAXOPHONE GENERAL PRIVACY NOTICE
Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the Data Protection Act 2018, the General Data Protection Regulation 2016/679 (the “GDPR”) and other legislation relating to personal data and rights such as the Human Rights Act 1998.
Who are we?
This Privacy Notice describes the way that we, Cambridge Saxophone (“CS”), as a controller use your data. The legal entity governing our church is Daniel Charles Forshaw trading as ‘Cambridge Saxophone’. The legal entity is accountable for the finances of the organisation our Safeguarding and other legal matters.
What data do the controllers listed above process? They will process some or all of the following where necessary to perform their tasks:
- Names, titles, and aliases, photographs;
- Contact details such as telephone numbers, addresses, and email addresses;
- Where they are relevant to our mission, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications, hobbies, family composition, and dependants;
- Where you make pay for lessons and concerts, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
How do we process your personal data?
The controllers will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of personal data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical and organisational measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
- To enable us to meet all legal and statutory obligations.
- To carry out comprehensive Safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments;
- To provide you with lessons on the saxophone and or other instruments / music theory.
- To deliver music within a community of learners.
- To administer the business activities of CS
- To maintain our own accounts and records;
- To seek your views or comments;
- To notify you of changes to our services, events and role holders;
- To send you communications which you have requested (such as Wednesday 3 Bullet Email and the New Lesson Mailshot) and that may be of interest to you. These may include information about campaigns, events, appeals, other fundraising activities;
- To process a grant or application for a role; and
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as exam boards, ABRSM, Trinity etc). An example of this would be entering you or your child for a music exam.
We may also process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. Where your information is used other than in accordance with one of these legal bases, we will usually obtain your consent to that use unless there Is another substantial public interest that we can rely on to use your personal data.
Sharing your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks where we are legally required to share your personal data, where we share your personal data to protect CS or another individual, or where you first give us your prior consent. It is likely that we will need to share your personal data with some or all of the following (but only where necessary):
- Exam boards such as the ABRSM.
- The Musicians Union and its insurance partners.
- Our agents, servants and contractors. For example, we may ask a commercial provider to maintain our database software e.g. MailChimp, the Cambridge Saxophone website.
How long do we keep your personal data?
We will retain some records according to certain regulatory and statutory responsibilities. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years after the date of the transaction to support HMRC audits. In general, we will endeavour to keep personal data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
- The right to access personal data we hold on you
- At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the information and where we obtained the personal data from. Once we have received your request we will endeavour to respond within one month.
- There are no fees or charges for the first request but additional requests for the same personal data may be subject to an administrative fee.
- The right to correct and update the personal data we hold on you
- If the personal data we hold on you is out of date, incomplete or incorrect, you can inform us and your personal data will be updated.
- The right to have your personal data erased
- If you feel that we should no longer be using your personal data or that we are illegally using your personal data, you can request that we erase the personal data we hold.
- When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your personal data
- You have the right to request that we stop processing your personal data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your personal data. Even after you exercise your right to object, we may continue to hold your personal data to comply with your other rights or to bring or defend legal claims.
- The right to data portability
- You have the right to request that we transfer some of your personal data to another controller in certain circumstances. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of personal data to which consent was sought.
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
Transfer of Data Abroad
Any personal data transferred to countries or territories outside the UK or the EU will only be transferred where we have put in place appropriate safeguards to protect your personal data usually through contracts approved by the European Commission. Our website is also accessible from overseas so on occasion some personal data (for example in video submissions on the CS website) may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on our website cambridgesaxophone.com/privacy-notice If we make a significant change, we will notify you. This Notice was last updated in May 2018.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller, Cambridge Saxophone 23 East Royston Road Whittlesford, Cambridge CB22 4NW
Email: [email protected]
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.