Data Protection Policy
Data Protection is an issue Bath Academy of Musical Theatre (BAMT) takes very seriously. Beyond compliance, we aim to observe best practice to protect and reassure our various contacts and students. In short, we commit to procedures that protect sensitive data at all times with secure cloud-based record-keeping, and files that are regularly reviewed, updated and, if necessary, deleted. Our Data Protection Policy refers to our commitment to treat information about students, stakeholders and other interested parties with the utmost care and confidentiality. Through this policy, we will ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights. It is presented to all staff and is available to students and stakeholders upon request.
SCOPE
This policy refers to all parties (employees, job candidates, students, stakeholders etc.) who provide any amount of information to us. Employees of our company must follow this policy. Contractors, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or who acts on our behalf and may need occasional access to data.
GENERAL
As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, digital footprints, photographs etc. Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the rules below apply. Our data will be:
Accurate and kept up-to-date
Collected fairly and for lawful purposes only
Processed by the company within its legal and moral boundaries
Protected against any unauthorized or illegal access by internal or external parties
Made available only to individuals with a legitimate reason to see and use it
Within a reasonable timescale, accessible to individuals to whom the data relates
Largely kept electronically and paper files will be held securely
Our data will not be:
Communicated informally
Stored for more than a specified amount of time or longer than it is needed
Transferred to organisations, states or countries that do not have adequate data protection policies
Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities)
In addition to ways of handling the data the company has direct obligations towards people to whom the Data belongs. We will:
Be transparent so people know which of their data is collected
Provide information to people about how we’ll process their data
Be clear about who has access to their information
Have provisions in cases of lost, corrupted or compromised data
Allow people to request that we modify, erase, reduce or correct data contained in our databases
DATA WE KEEP
BAMT currently keeps data for the following purposes:
Communications with all stakeholders including students and consultants
Marketing and general trading purposes
To ensure good governance of the business and to comply with legal requirements
Personnel, checking references and monitoring equal opportunities, and emergency contact details
Data subjects include:
Staff members
Students who have trained and studied with BAMT
Contacts from the local area who work with young people with an interest in performing arts
The kinds of details we keep are:
Contact and other personal details
Personnel information such as application details, training and personal development information
Some information is made available to the following bodies:
People whose data the company holds
HMRC, Companies House and other government and legal authorities
Staff and managers who need to see information to undertake their duties for BAMT
The company’s accountant and, when appropriate, legal advisors
ACTIONS
To exercise Data Protection we will:
Restrict and monitor access to sensitive data
Develop transparent data collection procedures
Build secure networks to protect online data from cyberattacks
Establish clear procedures for reporting privacy breaches or data misuse
Include contract clauses or communicate statements on how we handle data
Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.)
Publicise our data protection provisions our website
Disciplinary Consequences
All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.
GDPR
BAMT has taken steps to become compliant with the new General Data Protection Regulations enforced in May 2018. Our data processing is compliant with the lawful basis of ‘Consent’. As the law specifies, we “can show that an individual has performed a clear affirmative action to allow [us][ to process their personal data for a specific purpose”. As of May 2018 all of our electronic communications request affirmative action in order to continue receiving contact from BAMT. Following the implementation date of GDPR of 25th May 2018, we have removed personal contact details for people who have not provided consent from our databases.
Where we have identified a contact who’s work supports our own, we may contact the individual at their business address in line with legitimate business interest directive as outlined by the ICO. Via our digital marketing platform (Mailchimp) all of our contacts have the right to access, rectify, restrict and erase their data. Contacts also have the right to object to any communication via clearly indicated contact methods with BAMT's staff. BAMT ensures that contacts can exercise the right to be in informed about the use of their data via clearly labelled disclaimers at the point providing personal data. Any individual whose data we hold but whose data is not held in a mailing list, may exercise any of their rights above, by contacting BAMT directly through clearly signposted methods on www.ba-mt.co.uk, on our literature and on social media channels.