GDPR Policy & Procedures
The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
ASA are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
ASA are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Preparing for the GDPR
ASA already have a consistent level of data protection and security across our organisation, however we are now fully compliant with the GDPR. Our preparation includes: -
Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
Policies & Procedures – revising and implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
International Data Transfers & Third-Party Disclosures – where ASA stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
Direct Marketing - we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website, in the office and during studio hours of an individual’s right to access any personal information ASA processes about them and to request information about: -
What personal data we hold about them
The purposes of the processing
The categories of personal data concerned
The recipients to whom the personal data has/will be disclosed
How long we intend to store your personal data for
If we did not collect the data directly from them, information about the source
The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
ASA takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: -
Access controls, password protection, encryptions, IT, authentication
GDPR Roles and Employees
ASA Theatre Arts have designated Alana Shirley as our [Data Protection Officer (DPO) and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
ASA understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR, and has involved our employees in our preparation plans. We have implemented an employee training program specific to the new regulations, will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact Alana Shirley.
What we do at ASA:
We do not disclose or sell personal data to third parties.
We do not disclose personal data to other members of the school and their families.
All held personal data is stored securely using My Music Staff online studio management system, or in a locked filing cabinet in the ASA office.
The school uses contact numbers and emails for newsletters, updates, lesson reminders, whole school and individual communication, invoices, promotions and general information.
Emergency contact numbers are stored, and access is granted to teachers for the sole use of emergency contact only, and child safeguarding.
Personal data is stored in a locked password encrypted email database and My Music Staff locked invoicing system.
Personal information is transferred from ASA to exam boards and bodies such as The London College of Music, Pearson, VLUK, Stagedoor Learning, ABRSM, YMCA, for the purpose of entering students for exams. Data is transferred to Local Authorities for the purposes of performance licenses. These recipients have their own GDPRS systems in place.
Paper registration forms are stored in a secured filing cabinet at the school's office.
Hard copy information is destroyed via secure information shredding service.
Information about individuals is used in certain documents, such as, a weekly register, medication forms and examination documentations.
These documents include data such as children's names, date of birth, ethnicity and emergency contact numbers. These records are shredded after the relevant retention period.
ASA collects an amount of personal data every year including; names, addresses, dates of birth, school and emergency contact telephone and emails of enrolled students, names and addresses of those who have applied for lessons or courses, or those on the waiting list. These records are shredded if the child does not attend, or added to the child’s file and stored appropriately.
ASA stores personal data held visually in photographs or video clips or as sound recordings. Images and video clips are stored in photo albums, displays, on the website or ASA social media sites with prior consent.
Access to My Music Staff, school email account, website, personal data, social media accounts, newsletters and examination details are password protected and is not available to members of the public, members of the school, or its staff. The Principal and Vice Principal have sole access to all this data and the administration team has access to school email account only for welcoming new members, or corresponding with current students for the purposes of ASA only. When a member of staff leaves the school these passwords are changed in line with this policy and our Safeguarding policy. Any portable data storage used to store personal data, e.g. USB memory stick, are password protected and/or stored in a locked filing cabinet. All teaching staff are granted access to students’ emergency contact telephone and email details for the purpose of emergency contact only and child/young person/vulnerable adult safeguarding.
GDPR includes 7 rights for individuals:
1) The right to be informed
ASA collect data for all students including full name, address, date of birth, school, parent and/or guardian’s full name, parent and/or guardian’s address, emergency telephone numbers and email addresses. We also collect any SEN requirements, and are stored via a secured electronic system – My Music Staff. Paper registration forms are stored in a secured filing cabinet at the school’s office.
ASA is registered with the London College of (LCM), Pearson, and ABRSM and as so, is required to collect and manage certain data for the entering of examinations.
As an employer of self-employed practitioners, ASA is required to hold data on its teachers such as names, addresses, email addresses, telephone numbers and bank details. Information such as Disclosure and Barring Service checks (DBS), personal Public Liability insurance, First Aid Certificate's, Membership details and any qualifications. This information stored via a secure electronic system – My Music Staff, and paper forms are stored in a secured filing cabinet at the School's office.
2) The right of access
At any point an individual can make a request relating to their data and ASA will need to provide a response (within 1 month). ASA can refuse a request, if we have a lawful obligation to retain data, but we will inform the individual of the reasons for the rejection.
3) The right to erasure
You have the right to request the deletion of your data where there is no compelling reason for its continued use. However, ASA has a legal duty to keep student and parents details for a reasonable time*. ASA retain any records relating to student's accident and injury records for 19 years (or until the child reaches 21 years), and 22 years (or until the child reaches 24 years) for Child Protection records. Self-employed teaching records will be erased when the member of leaves their position. All hard copy information is destroyed via secure information shredding service. Records will be kept in line with HMRC requirements.
* ASA holds personal data while the student is registered at the school. The school requires a written notice to leave the school to put into action the erasure of your data. If records of this is not found, the school will continue to use your data for school purposes only.
4) The right to restrict processing
Parents, visitors and staff can object to ASA processing their data. This means that records can be stored but must not be used in any way, for example school newsletters, general emails about school news and updates and My Music Staff email and text service. In this situation, the school has no obligation to refund any classes missed or cancelled due to 'lack of communication'. It will be the parents’ responsibility to ensure they are informed about the termly event's happening at the school.
5) The right to data portability
ASA requires data, for example registration forms, medical declarations, exam entry forms or photo/video consent forms to be transferred from student, to teacher, to school principal. The school is also required to provide data such as student full name, address, DOB, gender, ethnicity, SEN requirements and exam pin number's to be able to enter students in relevant exams. In this case recipients use secure file transfer systems and have their own policies and procedures in place in relation to GDPR.
6) The right to object
Parents, visitors and staff can object to their data being used for certain activities like marketing or research.
7) The right not to be subject to automated decision-making including profiling.
Automated decisions and profiling are used for marketing based organisations. ASA does not use personal data for such purposes.
Last review: 01.09.21
Policy review date: 01.09.22
OUT OF SCHOOLS SETTING/PART TIME ACADEMY Terms & Conditions of Enrolment & Services Rendered
SINGING, ACTING & MUSIC LESSONS
By agreeing to the following terms and conditions, the 'New Student Enrolment' form will act as a contract entered into by ASA Theatre Arts Ltd (hereinafter referred to as "the Provider") and the student (or parent if under 18 years of age) as named on the completed 'New Student Enrolment' form (hereinafter referred to as "the Client") on the date as detailed within the 'New Student Enrolment' form.
The Client hereby engages the Provider to provide services for private Singing, Music, Acting and/or Performing Arts tuition. The Provider hereby agrees to provide the Client with such services in exchange for consideration described herein under “Terms & Conditions for Services Rendered”.
The Client is to be prompt with all payment deadlines. This includes private coaching fees, rehearsal & show fees, exam fees and costume expenses, as well as any other related costs. Lesson fees are to be paid by the first of every month for the coming month’s lessons. An invoice will be issued to you 7 days prior to this deadline.
1:1 lessons are undertaken on a weekly or fortnightly basis. Payments are to be made via direct bank transfer or My Music Staff using the link on your invoice. Bank details will be issued to you on each invoice, please ensure to provide the students name as a reference. Any late payments will incur a £5 late fee administration charge. Please note that only 2 lessons per academic year (1st September-31st August) may be missed without charge (eg. if the students has a school trip, dance show etc). These lessons still require a 24 hour cancellation notice period. After the two permitted absences, missed sessions will be charged for IN FULL in order to hold your space and enrolment. Missed lessons without the required notice, or lessons whereby the notice period is not adhered to, will be charged IN FULL and no refund will be issued. Where absences are known in advance, the Provider will endeavour to reschedule the missed lessons to an alternative day or week, as available in the ASA Theatre Arts calendar.
Once lessons are booked and confirmed, cancellations must be made with 24 hours notice.
This must be done by contacting us via email, using the address
Failure to adhere to the notice period will result in you being fully charged for the missed appointment.
Should your teacher be absent due to illness, a pre-existing work commitment or a holiday, clients will be given the same 24 hour notice period. Lessons will be re-scheduled to another suitable time/day, or an academy cover teacher will be provided.
Due to the nature of lesson scheduling, your session cannot be extended to compensate for lateness. Please arrive 2-3 minutes early (no earlier). Full lesson costs are still applicable if the student is late. If the client is more than 10 minutes late, the provider reserves the right to cancel the lesson without refund.
All teachers have been briefed upon, and signed The Alana Shirley Academy Child & Vulnerable Adults Protection Policy, Health and Safety Policy and Risk Assessment. Personal items are the sole responsibility of the Client. The Client is asked to behave in a sensible and attentive manner, to prevent injury within the teaching environment, and get the most out of each session. All teachers are fully DBS checked, and ASA Theatre Arts holds a comprehensive insurance policy. A First Aider is always on site.
Students Aged 16 Years & Under
Parents are required to provide data information for performance licenses when participating in a show, to be submitted to their local education authority for approval. The appropriate forms will be issued as and where necessary. Emergency contact details will also be required.
All photographs and video footage from ASA Theatre Arts performances, rehearsals, events & lessons will remain the property of the Provider, and can be used as required for publicity and advertising. This may be print or internet based. Written permission will be sought from parents of under 16's for each performance.
Please grant your permission for you/your child to be photographed and/or video recorded during lessons, rehearsals and shows for the purposes of social media, website posts, advertising , or any other promotional/advertising materials using the 'New Student Enrolment' form to the left.
For any queries, please contact the academy by email on firstname.lastname@example.org
Fire Safety Policy & Procedure
Fire Safety Policy
1. General Statement
We take our fire and safety duties seriously and have formulated this Policy to help us
comply with our legal obligations to staff, students and visitors under the Fire Safety
Order (2005). These include the provision of safe premises to conduct our business
where fire safety risks are minimised. Due to its importance, this Fire Safety Policy
forms part of our overall Health and Safety Policy. Our priority, at all times, is the
safety of individuals.
2. Staff/Tenants Duties
All staff/tenants have a duty to take reasonable steps to ensure that they do not place
themselves or others at risk or harm. All staff/tenants are expected to co-operate fully
with any procedures that may be introduced as a measure to protect the safety and well
being of staff, students and visitors.
All staff/tenants will be kept informed of any relevant changes to fire safety
procedures or fire risk assessments.
The following procedures are in place by COPAH Studios (Vicki Stevenson) to ensure high standards of fire safety.
• Fire risk assessments have been undertaken, and will be reviewed regularly by the
owner of the premises where we carry out our business.
• The fire evacuation procedure will be practised as recommended and a record will
be kept of the date and the time taken to evacuate the building.
• All new and temporary members of staff will be given training on how to raise the
alarm and the available escape routes. Regular staff will be given annual refresher
• All escape routes shall be clearly signed and kept free from obstruction at all
times. Escape routes shall be checked regularly by the Health and Safety Officer
of the owner of the premises where we carry out our business.
• Alarms are checked and tested regularly.
• Anyone who is staying in the building must signed-in on arrival and sign-out on
departure by whomever they are visiting.
5. Emergency Evacuation Plan
If you discover a fire:
• Raise the alarm immediately
• Evacuate immediately using the nearest available fire exit. Do not stop to pick up
any personal possessions. Do not stop to shut windows, but the last one out of a
room should ensure that the door is firmly closed.
• If a teacher is with their students, then they should take the sign-in sheet/register
with them. The onus is on staff to ensure that under 18s, in particular, get out of
the building safely.
• Report to the fire assembly point for roll call – Our car park, or if safer, Carpet
World car park
If you hear the fire alarm:
• Leave the building immediately using the nearest available fire exit.
• Staff need to ensure that any students under 18 in their presence get out of the
building safely. If you know that an under 18 is in the toilet or another part of the
building away from the class, inform the fire marshal as you leave.
• Report to the fire assembly point for roll call.
In the event that the fire alarm is for a genuine fire we will call the fire brigade as soon
as possible. However, in the event that the fire alarm is a false alarm, we will establish
the cause before letting anyone re-enter the building.
You can contact us during lesson times on 07930 278994
If you wish to contact us outside of lesson times, please e-mail
Version number 2
Date: September 2020
Adopted on 01/9/2020
By (full name) Vicki Stevenson / Alana Shirley
By (signature) A.Shirley
Next review date: September 2021
COVID-19 Policy & Procedures
Covid-19 Policy and Procedures commencing 01/09/2020 in line with return to music lessons/work at ASA Theatre Arts Ltd following the Government social distancing guidelines.
Health and Safety Statements
ASA Theatre Arts takes seriously their responsibility to ensure the safety of
their Students, Staff, Parents & Visitors.
1. All Students must use the front door only as an entrance to the Centre. On both entering
and leaving the premises all Students must sanitise their hands, with the sanitiser
provided in the entrance.
2. The car park is to only be used for the parking of cars belonging to STAFF &
TENANTS ONLY for the initial return period. We kindly ask you to make
your visitors aware of the car park closure. This is because the car park is being
marked out for parents queuing on evenings/weekends when Eloquent Dance
Academy students are dropped off & collected for lessons. It enables an open space for
parents to wait when dropping off and collecting without congregating at the front door.
The front door is temporarily not in use for Eloquent, and will be for sole use of
COPAH Tenants who can greet their own visitors/Students at the front door, without
them having to mix with groups of Eloquent students, which will keep you more safe. We will put a sign up outside the front door, requesting visitors to respect social distancing when waiting to be let into the building.
(We appreciate this will mean visitors using street parking, or other public car parks on
Holliers Walk, but safety of social distance drop off/collection is paramount for the first
month or couple of months. It will be regularly assessed)
3. NO PARENTS/GUARDIANS are allowed to enter the building with their child.
Please wait outside the front door. Do not press the buzzer or use the keypad. Your teacher will come down at the start of your lesson to let you in. The fewer the people in the building the better.
4. All communal areas will be closed for the short term. Kitchen and changing areas will
be locked to ensure visitors are only in limited areas downstairs or upstairs, such as the
tenants own office/room or studios being used for the classes and toilets. Due
to no parents being allowed in the building at this time, the kitchen is not required as a
waiting area. Students/Visitors should enter the building greeted by whomever they are
visiting, attend the lesson/meeting only and then leave, with no socialising to take
place. If using the toilets, washing of hands is paramount.
5. In case of a fire emergency, please have a clear understanding of procedures listed in
the next section.
6. We will undertake regular assessment of risks regarding the premises, and any concerns
will be raised with Alana Shirley.
7. A fully equipped first aid box within our own ASA studios/office is available. In case of an incident, an accident report must be completed.
8. Teachers will supervise students during class time, with students being required to sign in via iPad (teacher to do this for the student). Parents/guardians must ensure the safety of their children in the car park or street when dropping off or collecting. Please ensure you come to the front door at the end of the lesson time to safely collect your child. We will not let children leave without an adult that we know, so please ensure we know ahead of time if someone we don’t know will be collecting. Your promptness on collection is appreciated to minimise the disruption to the following lesson.
9. We accept no responsibility for children and young adults using the grounds around the
10. All students and parents should inform us of any health considerations or existing injuries before entering the studio. It is vital we are informed if any visitor/student or their family, including themselves have experienced or are experiencing any symptoms of Covid-19 and we must ask that you do not attend your lesson/appointment at ASA Theatre Arts.
Upon entry to 1:1 Music & Singing Lessons in ASA Privately rented rooms:
Hand sanitiser is provided on entry to the upstairs studios and we kindly ask all students to sanitise their hands.
Students are to stand on the spot on the floor.
All students and staff to observe the 2m social distancing at all times.
A clear plastic screen will be up between the student and teacher.
Students are to face the window when singing where possible.
All windows will remain open to encourage ventilation and air flow.
Students will be escorted back to their parents at the front door at the end of the lesson.
In case of enforced lockdown or isolation:
Where students or staff are put into enforced lockdown or isolation, and are still well within themselves, lessons will continue via Zoom at the usual lesson rate.
All other cancellation policies stand.
This policy will not be implemented in full when Governement guidelines have ceased to be enforced. ASA Theatre Arts will act responsibly at such a time to ensire the continued safety of staff and patrons.