We at Northamptonshire Music and Performing Arts Trust (NMPAT) are committed to protecting your personal information and being transparent about what information we hold about you and your child and children in your care.
This privacy statement is intended for applicants, participants, students and their parents or guardians, schools in which students learn, donors and supporters (together ‘you’ or ‘music service users’).
The purpose of this policy is to give you a clear explanation about how NMPAT and subsidiaries of NMPAT use the information we collect from you directly and from third parties.
NMPAT is the ‘data controller’ for the purposes of data protection law.
The lawful basis for obtaining and using personal data
NMPAT needs data in order to fulfil its contractual obligations with music service users 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 13 will act on behalf of their children. Children over 13 years of age are deemed competent to understand this privacy statement.
We will only process personal data where we have one of 6 ‘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 NMPAT to take specific steps before entering into a contract
- For the legitimate interests of NMPAT (provided the individual’s rights and freedoms are not overridden)
- Where the individual (or their parent / carer when appropriate in the case of a child) 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
NMPAT will use the information you provided in the application or registration form and may supplement this with information provided following an initial application.
Personal data that we may collect, use, store and share (see Data Sharing below) about individuals and music service users includes, but is not restricted to:
- Your full name and title and date of birth and your gender
- Postal address, email address and phone number
- IP (internet protocol) address e.g. cookies
- Emergency contact details and contact preferences
- Name of school attended
- Student records
- Results of auditions, internal assessments and externally set exams
- Characteristics, such as special educational needs
- Details of any medical conditions or dietary requirements
- Passport details
- Attendance information
- Safeguarding information
- Details of any support received
- Gift Aid status
- Payment card details (these are not stored)
- Photographs and video recording (see below)
- CCTV images captured on NMPAT premises (see below)
- If you hold a NMPAT instrument on loan
Why we use this data
We use this data to:
- Manage the application and audition processes
- Manage students’ registration, participation in, and progression through NMPAT programmes including school based music activities
- Provide music and performing arts tuition
- 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 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
- Manage applications for financial support
- Carry out research for our own purposes
- Comply with contractual / regulatory obligations e.g. reporting to the Arts Council
- Share with partners for joint activities e.g. Music for Youth
- Administer payments and donations including the processing of Gift Aid
- Keep you updated with NMPAT activities that are relevant to you
- Offer you opportunities to engage further with our activities
- Further fundraising activities on behalf of NMPAT
- Keep in touch with our alumni
- Generate publicity and advertise NMPAT’s services
- Promote events / concerts
- Celebrate the success of our students and raise awareness of their great achievements
- Help achieve the Trust’s aims: the Trust exists to provide the young people of Northamptonshire with musical and artistic opportunities. NMPAT’s core values are ‘to inspire, to nurture and to excel’
Photographs and video recording
As part of NMPAT’s activities, we will take photographs and record images of county groups, centre groups, centre activities and individual performers. Such material will be used solely by NMPAT, for example, for publicity purposes, such as prospectuses and other similar information about the Trust; for display in our buildings, on banners at concerts, on our website and for social media purposes; for assessment and educational purposes; and for fundraising or other purposes to help achieve the Trust’s aims.
For music groups entering the National Festival, run by our partners Music for Youth, and for other national festivals and competitions, photographic data may be collected and used in the same way.
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 music service users provide good reason why we should withdraw certain images. If you ask us to withdraw an image of your child 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. We will only use images of pupils who are suitably dressed, to reduce the risk of such images being used inappropriately.
We use CCTV in various locations around the NMPAT site to ensure it remains safe. We will adhere to the ICO’s code of practice for the use of CCTV.
We do not need to ask individuals’ permission to use CCTV, but we make it clear where individuals are being recorded. Security cameras are clearly visible and accompanied by prominent signs explaining that CCTV is in use.
We do not share personal information with any third party unless otherwise stated in this policy without consent, unless the law requires us to do so.
Where it is legally required, or necessary (and it complies with data protection law) we may share personal information with:
- Local Authority Children’s Services – to comply with Child Licensing regulations under the Body of Persons’ Approval (BOPA)
- Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns
- A student’s family and representatives
- Schools – where we provide tuition for your child in partnership with their school, NMPAT and the school act as joint data controllers
- Educators and examining bodies
- Suppliers and service providers – to enable them to provide the service we have contracted them for e.g. examining bodies, providers of registration services, payroll service providers, cloud computer service providers
- Financial organisations – to enable payment processing and debt collection
- Central and local government
- Our auditors
- Health and social welfare organisations
- Professional advisers and consultants
- Charities and voluntary organisations
- Police forces, courts, tribunals
- Professional bodies
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, as far as possible, 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.
Where we transfer data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.
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
NMPAT Data Protection Manager: Mark Malitskie
Or to the Chair of the Board of Trustees c/o firstname.lastname@example.org
Address: 125 Kettering Road, Northampton, NN1 4AZ
Important note. This is a living document and the definitive version is on the Trust website: www.NMPAT.co.uk/SLA. Updates and amendments should be expected. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
The Policy will be reviewed on a biennial basis, or to reflect updates in legislation. This Policy is next due for renewal in August 2019.
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