The General Data Protection Regulation (GDPR) came into effect on 25th May 2018.
This Notice provides information on how we, ShowKids, are complying with this Regulation.
Purpose and Statement:
ShowKids is committed to ensuring our data remains safe and secure. This policy has been written in line with legislative change, including both the Data Protection Act (1998) and the EU’s General Data Protection Regulation (GDPR).
How ShowKids collect personal data
ShowKids customers and participants supply their personal data when signing up for workshops through our registration form either via the website, email or via paper form. This is either completed by a parent/guardian. Customers may also supply their information to ShowKids through street promotion, providing contact details to ShowKids when interested in receiving information relating to our activities, courses and workshops.
Why we collect it
To attend any of ShowKids courses, workshops or activities participants/parents/guardians must agree to some processing of their personal data.
This is due to Legitimate Interests – GDPR Article 6(1)(f), Legal Obligation GDPR Article 6(1)(c), Contract – Article 6(1)(b) and/or Consent – Article 6(1)(a).
Should ShowKids be unable to process participant’s data, we would be contravening both our Health & Safety and Child Safeguarding policies. We would also be ignoring best practice regarding working with children. Our participants must remain safe at all times, therefore information about participants must be collected in order to create registers and accurate student records. This information is also used to provide participants with appropriate workshops, including dividing students into age groups.
Special category data is only collected with the consent of the data subject. Special category data ShowKids collects includes but is not limited to: Medical/Disability information and Gender. As our workshops and courses include physical activity it is essential that this consent is given should a participant have any medical/disability needs. This allows us to incorporate participants safely into workshops. It is also used in assessing if we can incorporate participants safely into workshops.
What data we collect
Personal data and some special category is collected.
It is essential to our primary function (providing workshops and courses to participants) that we are provided, and allowed to process and store the following:
Participant Personal Data:
• Full Name – GDPR Article 6(1)(f)
• Date of Birth – GDPR Article 6(1)(f)
• Home Address – GDPR Article 6(1)(f)
• Sex – GDPR Article 6(1)(f)
• Permission to go home alone – GDPR Article 6(1)(f)
• School/Educational Institution – GDPR Article 6(1)(f)
• Exam results (vocational exams taken through ShowKids only) – GDPR Article 6(1)(f)
• Classes attended/Price paid – GDPR Article 6(1)(f)
Participant Special Category Data:
• Medical Information/History – GDPR Article 9 (a)
• Disability Information – GDPR Article 9 (a)
• Gender/Sex – GDPR Article 9 (a & j) – further explicate consent sought
Parent/Guardian Personal Data:
• Name – GDPR Article 6(1)(f)
• Address – GDPR Article 6(1)(f)
• Email Address – GDPR Article 6(1)(f)
• Mobile Telephone Number – GDPR Article 6(1)(f)
• Work/Home Number – GDPR Article 6(1)(f)
• Emergency Contact Number – GDPR Article 6(1)(f)
How data is sent internally
ShowKids transports data with all due diligence.
Registration and booking forms for workshops and courses are sent to ShowKids through an encrypted email server directly from our website which has controlled access. Received forms are stored on an encrypted email server for no more than 6 months.
Storage/retention of data
Data received through registration and booking forms is uploaded manually into our database. Our database is stored on office-based hardware and backed up regularly on an external hard drive. Access to these files is restricted through password protection and only available to Natalie Burton, ShowKids Managing Director.
Hard copies of registers and emergency contacts are carried by authorised staff members only. They are stored securely while not in use. When they are no longer in use or out-dated, they are destroyed thoroughly.
Our standard retention policy (without the data subject’s right to access, rectification and erasure etc.) is THREE YEARS post final attendance.
Exceptions to our retention policy:
• Financial records are kept for 6 years due to legal obligation
• First Aid records are kept for 21 years due to legal obligation
• Child Safeguarding records are kept indefinitely on a case-by-case basis, the minimum these will stored for is 6 years due to legal obligation
• Bank details are deleted after the action concerning them is complete
Third parties
ShowKids does not share data with third parties however, there are certain instances where sharing information is crucial to our business processes:
• Freelance Teachers:
As many of our ShowKids teachers are freelance staff, we have confidentiality and data processor agreements in place. Teachers will never be provided with personal details aside from participant’s first names, age, parent/guardian first name and contact number and any medical information that is pertinent to the running of a workshop (subject to consent from the data subject)
• Child Safeguarding Concerns:
In the unlikely event ShowKids has a safeguarding concern in relation to one of participants, ShowKids are legally required to provide data to the safeguarding board at the local council. ShowKids is satisfied that their GDPR process are thorough and any data will be stored in a secure environment, and not unnecessarily retained.
• Event Programmes:
ShowKids may occasionally produce programmes for events. These will only ever contain the first name and first initial of a child’s last name (unless otherwise consented to).
• Examination Entry:
In order to enter examinations, ShowKids must provide some personal data to examination boards (currently ShowKids work with: LAMDA). This sharing of data is to be consented to by the data subject and/or parent/guardian upon being entered for the exam.
Rights of the data subject and ShowKids compliance with responses
Any data subject with personal data stored within ShowKids is entitled to the rights of:
• Access
: You may contact ShowKids at any time to access all data held relating to you and/or your child(ren). ShowKids will ensure that we respond to a subject access request without undue delay and within 72 hours of receipt. If the information request will also include data regarding others, ShowKids has the right to refuse the request or take steps in order to obtain consent from other involved parties.
The right of access does not apply to ShowKids’ legal obligations such as Child Safeguarding records.
• Rectification : You may contact ShowKids at any time in order to rectify data held relating to you and/or your child(ren). ShowKids will ensure that we respond to a rectification request without undue delay and within 72 hours of receipt. The right to rectification does not apply to ShowKids’ legal obligations such as payment record information.
• Erasure : You may contact ShowKids at any time in order to erase data held relating to you and/or your child(ren). ShowKids will ensure that we respond to an erasure request without undue delay and within 72 hours of receipt. The right to erasure does not apply to ShowKids’ legal obligations such as First Aid records.
• Restrict Processing : You may contact ShowKids at any time in order to restrict the data we process relating to you and/or your child(ren). ShowKids will ensure that we respond to a request to restrict processing without undue delay and within 72 hours of receipt.
• Objection : You may contact ShowKids at any time in order to object to the processing of data relating to you and/or your child(ren). ShowKids will ensure that we respond to a request to restrict processing without undue delay and within 72 hours of receipt.
Photos/videos of participants
ShowKids often use footage/photos used from shows, performances and workshops for marketing purposes both in print media and the website. Participants/their Parent and/or Guardians may choose if they do not wish their child to be depicted.
Social Media:
ShowKids regularly share photos/videos of students in workshops, events and performances through social media platforms including; Instagram and Facebook. These will never be shared with any identifying information (age, location etc.)