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Morea Performing Arts Privacy and Data Protection Policy

Introduction

 

We are a controller for the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulation 2016/679. This means that we are responsible for, and control the processing of, the personal information you provide to us when using our services and/or this website in accordance with this privacy policy.

 

Morea Performing Arts understands that customers care about the use and storage of their personal information and we value your trust in allowing us to do this in a careful and sensible manner. We have created this privacy policy statement in order to demonstrate our commitment to the privacy of our customers.

 

By using our services, attending our courses, and/or website (including our mobile site), our social media pages (Facebook, Twitter and Instagram), our telephone information line and any other of our services, you are acknowledging that we are processing your personal information and, where necessary consenting to such practices, as outlined in this statement. 

 

Personal information which we collect.

 

We collect personal information about you (and others if their personal information is provided by you) when you:

(a) Submit an online application form to reserve/book a place for any of our courses/events promoted on our website and social media accounts;

(b) contact us via the contact page available on our website;

(c) contact us via our social media accounts linked to our website;

(d) send an email to us using the email addresses available on our contact page contact@moreaperformingarts.com and any email address within the @moreaperformingarts.com domain;

(e) enquire about our services through the “Contact Us” form on our website or by calling our telephone information line;

(f) post material to our website and/or social media accounts and/or attach any kind of documents, images that may represent information subject to data protection;

(g) register as a walk-in student or register somebody else as a walk-in student to any of our events/courses;

(h) raise a complaint or dispute with us or are involved in a legally recordable incident at our premises (e.g. in relation to health and safety reporting);

(i) speak to one of our staff members (faculty, office and support);

(j) participate in competitions, promotions, open days, auditions, showcases, concerts, work experience days and any other related activity to our courses;

(k) and/or use our website and student applications in any other way;

(l) when completing your profile on our website including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details or any other personal details and photographs in connection with making an application to study at Morea Performing Arts;

 

(m) enrol on one of our courses;

 

(n) use the colleges’ email account provided to you when enrolling on our full time courses.

The personal information collected in the above manner may include the following about you (and others if their personal information is provided by you):

(a) full name, date of birth and genre

(b) full postal address;

(b1) parents/legal guardian’s full names;

(c) email address, social media account details;

(d) telephone number (landline and/or mobile);

(e) payment details (including card details when applicable);

(f) disability and health information;

(g) supplementary information (dietary and other preferences and special requirements);

(h) behavioural data (tags and cookies – see Cookies and Tracking section below);

(i) image data;

(j) voice data recordings (voice mail);

(k) identification information (such as passports, drivers’ licenses or national identity cards);

(l) travel information (such as flight’s details, booking details);

(m) educational details -current and previous- (academic, dance and performing arts training related);

(n) ethnic origin.

 

Personal information provided by third parties

We may receive information about you from other sources such as previous students, colleagues, employees, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary which we will add to the information we already hold about you in order to help us provide our services and/or products in accordance with your requirements and to ensure that the quality of data we have on your account(s) is maintained properly. We may also obtain information available about you on internet search engines.

How we use your information

We will collect personal information:

1) in order to take the necessary steps in preparation of, or to fulfil our obligations and services provided:

a) Enrolments and payments – provide communications about booking auditions, enrolment processes, products and services being provided to you (and others if their personal information is provided by you);

b) Enrolment updates – send details of new, amended or cancellations related to the studies with us – usually via email;

c) Update you on matters affecting your studies with us– contact you (and others if their personal information is provided by you) in the event of a change that affects your enrolment or any data or personal information you have provided us with, such as changes to terms and conditions of our courses/events or this privacy policy;

d) Adjustment of service communication – provide notifications of any changes to our services that may affect you (and others if their personal information is provided by you);

e) Customer service communication – provide you with requested information or correspondence, or a response from us to an enquiry made by you;

f) To provide assistance in completing bookings – send reminder emails to continue with a booking for an audition day which you have reserved but is not paid and completed;

g) To create/maintain an account – create a profile about you in relation to your course with us, to update our records, create and maintain your account.

h) To provide assistance in completing an enrolment – send reminder emails to continue with an enrolment process for any of our courses/events/services which you have reserved but is not paid and completed;

i) To provide assistance in completing, monitoring and assessing our courses;

j) In order to create promotional material (electronic, printed, audio and video);

k) To ensure that we comply with our safeguarding, health and safety and dance safe practice policies.

2) with your consent:

a) Simplify payment process – use saved payment cards within your account so that, upon making future bookings, you have the convenient option of selecting a previously saved card in order to pay. This information is only stored, used / accessed when you clearly agree and inform us to proceed with this.

b) Marketing communications – create a profile about you for marketing purposes to tailor our communications to you;

c) Promotional offers – inform you about promotional offers and other products or services that may be of interest (in line with Marketing communications above);

d) Maintain records indicating your consent to status – to ensure we accurately reflect your wishes when communicating to you.

3) in our legitimate interest* to improve our services:

a) Market research – to contact you (and others if their personal information is provided by you) to ask about the experience using our services as part of a continual program of customer service improvement. This is not marketing communication and is separate to Marketing communications above.

b) Customer support – monitor any communication from you to help train staff in relation to our services;

c) Course and service improvement – to improve our courses and services.

4) in our legitimate interest* to protect against fraud:

a) Website improvement and fraud prevention – improve our websites, prevent or detect fraud or abuses of our websites and enable third parties to carry out technical, logistical or other functions on our behalf;

b) Security – carry out security checks when allowing you access to our services and to block fraudulent or suspected fraudulent activity.

5) to comply with any applicable laws and regulations:

a) Taxation – ensure we meet our tax and other regulatory obligations;

b) Registration – ensure local jurisdiction regulations are complied with (where registration is necessary in such jurisdictions).

* any reliance on legitimate interest shall not prejudice your interest or fundamental rights and freedoms.

Marketing

We may periodically send promotional material to you about our services, special offers or other information which we think you may find interesting based on the profile we have created about you to the email addresses and phone numbers which you have provided.

If these are similar to products, services and bookings previously supplied by us to you, we will assume, under our legitimate interests to promote similar goods and services, that you are willing to receive this information unless you tell us otherwise. Please note that we do not want to send you information that you do not want to receive and you can opt out at any time (please see ‘The right to ask us to stop contacting you with direct marketing’ below for further information).

From time to time, we may also use your information to contact you for research purposes and / or to ask about your experience using our services as part of a continual programme of customer service improvement. We may contact you by email, telephone, text, social media and / or mail. We may also use the information to customise our services according to your interests.

How long we will keep your personal information

We retain your information for a range of purposes which determine the period of time for which we need to keep such information. For example (list is not exclusive):

For the purposes of marketing - 7 years from the point of last contact with you, this may include use of our websites, services or responses to communications with you.

For compliance with legal obligations arising from contracts entered into with you, for example tax regulations - 7 years from the point of last contact with you, this may include use of our websites, services or responses to communications with you.

For the purposes of assessing, completing and monitoring any activities related to our courses - 7 years from the point of last contact with you, this includes any contact made by email, via our website, telephone or after finalising your course with us.  

We will remove your data from our systems at the end of the applicable data retention periods unless we are required by current or future law to retain your personal information for a longer period. If we do, we will continue to make sure your privacy is protected.

Our approach to information security

To protect your information, Morea Performing Arts has policies and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in a secure and sensible manner and all systems that can access the information have proportionate and reasonable security measures in place. To achieve this, employees, contractors, sub-contractors and third-party suppliers have contracts, with defined roles and responsibilities.

While we take commercially reasonable measures to ensure the safety and security of your data, due to the inherent risks with the Internet, we are unable to warranty the absolute security of your data when using our services.

Transfers of your information out of the EEA

Morea Performing Arts does not share and transfer your personal information to support partners which are located outside the European Economic Area.

Your rights

In order to process any of the requests listed below, we may need to verify your identity for your security. In such cases your response will be necessary for you to exercise this right.

The right to access information we hold about you

At any point you can contact us to request details concerning the information we hold about you, why we have that information, who has access to the information and where we got the information. In most cases you may be entitled to copies of the information we hold concerning you. Once we have received your request we will respond within 30 days.

The right to correct and update the information we hold about you

If the data we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.

The right to have your information erased

If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.

The right to object to processing of your data

You have the right to request that Morea Performing Arts stops processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your data to comply with your other rights.

The right to ask us to stop contacting you with direct marketing

You have the right to request that we stop contacting you with direct marketing. You can unsubscribe by sending an email to

dpo@moreaperformingarts.com

 

Or by post

Data Protection Officer

Morea Performing Arts

35 St George’s Street

Cheltenham

GL50 4AG

United Kingdom

The right to data portability

You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so.

The right to object to automated decision making / profiling

You have the right to request that we stop profiling you in relation to our direct marketing practice. You can inform us and we will deal with your request accordingly.

The right to complain

You can make a complaint to us by contacting us via dpo@moreaperformingarts.com or to the data protection supervisory authority – in the UK, this is the Information Commissioner’s Office, at https://ico.org.uk/.

Consent

In those cases where we need your consent to process your information, we will ask you to make a positive indication (e.g. to tick a box or insert your contact details on the relevant form or web page requiring consent). By actively providing us with your consent, you are stating that you have been informed as to the type of personal information that will be processed, the reasons for such processing, how it will be used, for how long it will be kept, who else will have access to it and what your rights are as a data subject and that you have read and understood this privacy policy.

Sharing your information with other organisations

The information and data we collect is important for Morea Performing Arts and we understand that you care about the use and storage of your personal information; we value your trust in allowing us to do this.

We may disclose your personal information to our regulator (The Imperial Society of Teachers of Dancing), any of our employees, officers, insurers, professional advisers, agents, examinations boards, professional suppliers (in particular the college’s physiotherapist) or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

We may also from time to time need to share your personal information to support our partner which is located within the UK for the purpose of promoting their services. This organisation is The Dance Summer School and they will contact you only when a potential relevant service to you (according to your profile) will take place.

Any transfer of your data will be subject to adequate levels of protection that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

Apart from sharing your information (and others if their personal information is provided by you) with The Dance Summer School and organisations mentioned above, we would not want to share this with anyone else unless we have your express consent; we will never disclose, rent, trade or sell your personal information to any third parties for their marketing purposes.

We do not disclose or transfer your data or personal information to other companies, data processors or agents employed by us to perform any necessary functions on our behalf (such as hosting and maintaining our website, providing us with data management systems, market research, customer satisfaction surveys and support services).

In the event that Morea Performing Arts or any part of its business is sold to or integrated with another business, Morea Performing Arts may disclose your personal information to the new owners (and their professional advisers on the transaction) to be used by the new owners and their group of companies in the same ways as set out in this privacy policy, including to continue providing you with the same services and marketing information services as are currently provided by Morea Performing Arts. 

Use of cookies

Morea Performing Arts websites and mobile app use cookies and tags. A cookie is a small text file that can be stored by your browser on the device you use to access the internet and allows the browser to pass small amounts of information about user behaviour on the given website to a web server. Tags are pieces of code that exist on web pages and collect information about usage of the web pages.

At Morea Performing Arts we use cookies and tags from third parties to enable the smooth operation of the websites. We also use cookies/tags to monitor visits to our website and continuously look for places to improve your website experience. Our marketing partners and other media platforms also use cookies and tags to monitor the performance of our advertising and to serve appropriate Morea Performing Arts advertisements to you on other websites or social media means of communication.

We will never share any personal information about you with these third parties and the cookies and tags used maintain your anonymity.

Cookie Consent

The first time you access Morea Performing Arts website, you will be informed about our use of cookies to improve your site experience. By continuing to browse our website you consent to our use of cookies.

Cookie name                                                        Life span                                               Purpose

svSession                                                             Permanent                                          Creates activities and BI

hs                                                                          Session                                                 Security

incap_ses_${Proxy-ID}_${Site-ID}                    Session                                                 Security

incap_visid_${Proxy-ID}_${Site-ID}                  Session                                                 Security

nlbi_{ID}                                                               Persistent cookie                                Security

XSRF-TOKEN                                                        Persistent cookie                                Security

smSession                                                           Two weeks                                           Identify logged in site members

Third party cookies

Morea Performing Arts also features a number of external services, such as social media sharing, which may also use cookies when you use them. You can find out more about these services and their use of cookies through their respective websites and privacy policies, some of which we have linked below for your convenience:

JOB APPLICANTS, CURRENT AND FORMER MOREA PERFORMING ARTS EMPLOYEES

Morea Performing Arts is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at dpo@moreaperformingarts.com

What will we do with the information you provide to us?

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors, whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for. 

What information do we ask for, and why?

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t. 

Application stage

We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

You may also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

Shortlisting

Our hiring managers shortlist applications for interview. They will not be provided with your name or contact details or with your equal opportunities information if you have provided it.

Assessments

We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by Morea Performing Arts.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise. 

Conditional offer

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability. 

You will therefore be required to provide: 

Proof of your identity – you will be asked to attend our office with original documents, we will take copies.

Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.

You will be asked to complete a criminal records declaration to declare any unspent convictions.

We will provide your contact details to DDC Due Diligence Checking who will contact you to complete an application for an enhanced Criminal Records check via the Disclosure and Barring Service, or Access NI, or Disclosure Scotland, which will verify your declaration of unspent convictions.

We may contact your referees, using the details you provide in your application, directly to obtain references.

We may also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done so we can comply with Health and Safety regulations.

If we make a final offer, we will also ask you for the following:

Bank details – to process salary payments

Emergency contact details – so we know who to contact in case you have an emergency at work

Membership of a Civil Service Pension scheme – so we can send you a questionnaire to determine whether you are eligible to re-join your previous scheme (if applicable).

How long is the information retained for?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

 

 

Your rights

Under the Data Protection Act 1998, you have rights as an individual which you can exercise in relation to the information we hold about you.

You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

Contact details

If you have any queries about this policy, need further information or wish to lodge a complaint you can use the details below to contact us.

dpo@moreaperformingarts.com

Or by post

Data Protection Officer

Morea Performing Arts

35 St George’s Street

Cheltenham

GL50 4AF

United Kingdom

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Changes to this Privacy Policy

Whenever we change this policy, we are committed to inform you immediately.

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