Wolverhampton Music Service is committed to protecting your personal information and being transparent about what information we hold about you and your child/children in your care. We take our responsibilities very seriously and we aim to be fully compliant with data protection legislation and the policies and procedures within Wolverhampton City Council.

This privacy notice is intended for applicants, participants, students and their parents/guardians, schools in which students learn, customers, friends, current and future donors and supporters (together referred to as “you”). It is intended to give you a clear explanation about your rights, how we keep personal information safe, the legal basis we rely on to use information and the purposes for which we use the information we collect from you and relevant third parties.

Wolverhampton Music Service is the “data controller” for the purposes of Data Protection Law. If you have any questions about this privacy notice or require further information, please contact:

Ciaran O Donnell
Graiseley Hill
Wolverhampton WV2 4NE
or via email: ciaran.o’donnell@wolverhampton.gov.uk

If you have concerns with the way in which your personal data has been processed, and we have been unable to rectify it, you may complain directly to the Information Commissioner’s Officer. Further information can be found on the ICO website.

The lawful basis for obtaining and using personal data

Wolverhampton Music Service needs data in order to fulfil its contractual obligations with customers and service users.

We will only process personal data where we have one of 6 “lawful bases” to do so under the General Data Protection Regulations:

  • To fulfil a contract with you, or where you have asked Wolverhampton Music Service to take specific steps before entering into a contract,
  • For the legitimate interests of Wolverhampton Music Service, provided the individuals’ 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
  • To perform a task in the public interest

Where the processing of data is necessary to comply with a statutory obligation such as information pertaining to statutory assessment as set out in the guidance produced annually by the Standards and Testing Agency (STA), the processing of this data is consistent with the processing of other types of personal data.

The personal data we hold

Wolverhampton Music Service will use the information you provide during the application/registration process and may supplement this with information provided thereafter.

The personal data we may collect, store, use and share about you includes, but is not restricted to:

  • Full name, title, date of birth and gender
  • Postal address, email address and contact number(s)
  • Emergency contact details and contact preferences
  • Characteristics, such as special educational needs
  • Details of any medical conditions and/or dietary requirements
  • Details of the schools you have attended
  • Student records, including relevant education, assessment information, career and ensemble details as well as other achievements, hobbies and/or interests
  • Attendance information
  • Safeguarding information
  • Details of any support received
  • Details of instrument(s) you play and any instrument(s) on loan to you
  • Results of auditions, internal assessments and external examinations
  • Bank or payment card details (these are not stored)
  • Gift Aid status
  • Photographs and video recording
  • CCTV images captured on Wolverhampton Music Service premises

We may combine information provided by you with information available from external, publicly available sources in order to get a better understanding of our customers and audiences in order to improve our products, services, marketing and fundraising methods.

Children’s data

Some of our services are specifically aimed at young people and to deliver these services safely it is necessary for us to collect data through a registration process. Before we collect data from anyone under 18 years of age, we will ask them to obtain permission from a parent or guardian before registering, or ask that a parent or guardian register on their behalf. It is our policy not to request donations or subscriptions, or to accept product orders, from anyone under 18 years of age.

How we use this data

We use this data to:

  • Comply with contractual/regulatory obligations (e.g. reporting to BCC, Arts Council England)
  • Manage the registration/application and/or audition processes and ensembles
  • Manage student registration, participation in and progression through Services For Education programmes, including school based activities
  • Provide music tuition and advisory support
  • Support student learning
  • Monitor and report on student progress
  • Provide appropriate pastoral care and ensure welfare of children/students/learners whilst in our care, particularly when on tours and courses
  • Protect student welfare and meet our legal obligations relating to child protection and safeguarding
  • Share with partners for joint activities
  • Administer payments and donations including the processing of Gift Aid
  • Manage applications for financial support
  • Keep you updated with Wolverhampton Music Service activities that are relevant to you
  • Offer you opportunities to engage further with our activities
  • Promote events and concerts
  • Promote volunteering opportunities
  • Celebrate the success of our students and raise awareness of their achievements
  • Keep in touch with our alumni
  • Generate publicity and advertise Wolverhampton Music Service’s activities and programmes
  • Assess the quality of our services, courses and programmes
  • Carry out research for our own purposes
  • to inform fundraising initiatives
  • Promote the achievement of our charitable aims

Wolverhampton Music Service is the lead organisation in the Music Education hub and must process data to comply with contractual/regulatory obligations in this role.

The processing of the data in relation to Music Education Hub provision is lawful under Article 6, 1e) because processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

For special category data: the processing of this data is lawful under Article 9, 2g) because it is necessary for reasons of substantial public interest (on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject). In addition, the public-sector equality duty as set out in section 149 of the Equality Act 2010 gives public authorities a duty, when exercising their functions, to have due regard to the need to eliminate discrimination, harassment or victimisation or any other conduct prohibited by the Equality Act 2010.

Pupil data will be retained for a period of 6 years to remain compliant with audit regulations for the monitoring of musical instruments as assets, after which it is to be securely deleted from all Wolverhampton Music Service computer servers.

Managing your communication preferences

From September 2018, Wolverhampton Music Service has followed an “opt in” communication policy for our marketing activity, meaning that we only send marketing communications to you if you have explicitly stated that you are happy for us to do so via your preferred communication channel(s): post, phone, email or SMS/text.

IT systems may be used to monitor the effectiveness of our electronic communications with you. The data from this monitoring is generally used in an aggregated and anonymised form to inform future marketing activities.

We use profiling to improve engagement, to ensure communications are relevant and timely, and to provide an improved experience for all our customers. In addition, profiling enables us to operate more effectively, thereby helping us to raise more funds and deliver the best services possible for our customers and service users.

You may request a change to your communication preferences at any time by contacting ciaran.o’donnell@wolverhampton.gov.uk

Photographs and video recording

As part of Wolverhampton Music Service ‘s activities, we will take photographs and record images of groups, ensembles and individual performers. Such material will be used by Wolverhampton Music Service (and our partners, where we are undertaking joint activities), for example, for publicity purposes, such as flyers and brochures; for display at our concerts, on our website and for social media purposes connected with the above; for assessment and educational purposes; and for fundraising or other purposes to help us to achieve our charitable aims.

When using photographs and videos for publicity, display or website purposes, we will not accompany them with any other personal information about the student to ensure that the student or learner cannot be identified. Consent to use photographs and video of individuals will always be sought. Whilst we will carefully use images on the basis of our “legitimate interests”, we recognise that there may be occasions where service users wish to not provide their consent or withdraw consent at a later time. In these circumstances, we will delete the photograph or video and not distribute it further.

Inappropriate images that might cause distress will not be used.

CCTV

We use CCTV at Wolverhampton Music Service premises to ensure that it remains safe. We adhere to the ICOs code of practice for the use of CCTV.

We do not need to ask individual’s permission to use CCTV, but we make it clear where individuals are being recorded. Security cameras are clearly visible and accompanied by signs indicating that CCTV is in use.

Data sharing

We do not share personal information with any third party unless otherwise stated in this privacy notice without consent, unless the law requires us to do so.

Where it is legally required, or necessary (and complies with data protection law) we may share personal data with:

  • Relevant Local Authority Children’s Services – to comply with Child Licensing regulations
  • The 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
  • Educators and examining bodies
  • Partners undertaking joint activities
  • Suppliers and service providers – to enable them to provide the services we have contracted them for (e.g. examining bodies, mailing houses, cloud based IT systems)
  • Health and social welfare organisations
  • Financial organisations – to enable payment processing, donations and debt collection
  • Professional advisers and consultants
  • Professional bodies
  • Our auditors
  • Central and local government
  • Police forces, courts and tribunals

While we will not share with, give or sell your details to other organisations for their own marketing purposes, we may send marketing materials on their behalf to you with your consent. We will only send information on behalf of organisations where we believe it will be relevant and of interest to our customers.

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 reasonably possible, that any third parties we use for processing your personal information will do the same.

Information will be stored only for 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 personal data breaches in accordance with the General Data Protection Regulation requirements.

Your rights to your personal information

If you wish to update your personal data or contact preferences, please contact a member of our Administration Team.

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 email ciaran.o’donnell@wolverhampton.gov.uk 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.

We are a “public authority” as defined under the Freedom of Information Act and therefore will respond to requests for information under this Act.

This privacy notice was last reviewed on 15 Oct 2018 and will be reviewed on a regular basis or to reflect updates in legislation, as appropriate.