Privacy Policy

Innovation Dance Studios Data Protection Policy
Innovation Dance Studios collects and uses personal information about staff,
students, parents and other individuals who come into contact with the
studios. This information is gathered to enable it to provide performing arts
education and other associated functions. In addition, there may be a legal
requirement to collect and use information to ensure that the studio complies
with its statutory obligations. We do not share this data with any third-party
companies, except at the request of the Police, Local Authority, or
Health Care professional. It is collected purely for the safety of our

Please note: Under new laws we are not able to demand contact details, however if minors (under 16 years) would like to attend our classes and we are not given an emergency contact, a parent/carer will have to stay on the premises for the duration of the class for safety reasons. Also, this means we will not be able to send details of shows/exams therefore special attention will need to be paid to the notice board.


This policy is intended to ensure that personal information is dealt with
correctly and securely and in accordance with the GDPR 2018, and other
related legislation. It will apply to information regardless of the way it is
collected, used, recorded, stored and destroyed, and irrespective of whether it
is held in paper files or electronically.
All staff involved with the collection, processing and disclosure of personal
data will be aware of their duties and responsibilities by adhering to these
What is Personal Information?
Personal information or data is defined as data which relates to a living
individual who can be identified from that data, or other information held.

GDPR 2018 Principles

1. Lawfulness, fairness and transparency

Transparency: Tell the subject what data processing will be done. Fair: What
is processed must match up with how it has been described. Lawful:
Processing must meet the tests described in GDPR [article 5, clause 1(a)].

2. Purpose limitations
Personal data can only be obtained for “specified, explicit and legitimate
purposes”[article 5, clause 1(b)]. Data can only be used for a specificprocessing purpose that the subject has been made aware of and no other,
without further consent.
3. Data minimisation 
Data collected on a subject should be “adequate, relevant and limited to what
is necessary in relation to the purposes for which they are processed” [article
5, clause 1(c)]. In other words, no more than the minimum amount of data
should be kept for specific processing.
4. Accuracy
Data must be “accurate and where necessary kept up to date” [article 5,
clause 1(d)]. Baselining ensures good protection and protection against
identity theft. Data holders should build rectification processes into data
management / archiving activities for subject data. 
5. Storage limitations
Regulator expects personal data is “kept in a form which permits identification
of data subjects for no longer than necessary” [article 5, clause 1(e)]. In
summary, data no longer required should be removed.
6. Integrity and confidentiality
Requires processors to handle data “in a manner [ensuring] appropriate
security of the personal data including protection against unlawful processing
or accidental loss, destruction or damage” [article 5, clause 1(f)].General Statement
The studio is committed to maintaining the above principles at all times.
Therefore the studio will:
  • Inform individuals why the information is being collected when it is
  • Inform individuals when their information is shared, and why and with
    whom it was shared
  • Check the quality and the accuracy of the information it holds
  • Ensure that information is not retained for longer than is necessary
  • Ensure that when obsolete information is destroyed that it is done so
    appropriately and securely
  • Ensure that clear and robust safeguards are in place to protect
    personal information from loss, theft and unauthorised disclosure,
    irrespective of the format in which it is recorded
  • Share information with others only when it is legally appropriate to do
  • Set out procedures to ensure compliance with the duty to respond to
    requests for access to personal information, known as Subject Access
  • Ensure our staff are aware of and understand our policies and


Complaints will be dealt with in accordance with the studio’s complaints

Please click here for our complaint policy and procedure


This policy will be reviewed as it is deemed appropriate, but no less frequently
than every 2 years. The policy review will be undertaken by the Development
Manager, or nominated representative.


If you have any enquires in relation to this policy, please contact

Emma Hardy, Zoe Newell or Carrie Amor who will also act as the contact point for any subject access requests.

Further advice and information is available from the Studio’s Office, or telephone 02089982283

or you can complete our contact form 

Appendix 1

Innovation Dance Studios

Procedures for responding to subject access requests made under the GDPR 2018

Information Consent

We will request your consent to access of your information via our new payment form, consent is authorised by signing under the T’s & C’s at the bottom.

Data Breach

The procedure in place to detect a personal data breach will be a thorough  investigation following a report of an issue.

Right to delete information

At any point you can contact us to delete your information. If a minor is still attending classes other measures will need to be taken in order to ensure the safety of the participant. Please see opening statement.

Rights of access to information

There are two distinct rights of access to information held by schools about

1. Under the GDPR 2018 any individual has the right to make a
Request to access or delete the personal information held about them.

2. The right of those entitled to have access to our records are staff only. No
data will be shared with third-parties except the Police, Local Authority, or
Health Care professional.

These procedures relate to subject access requests made under the GDPR

Action of a subject access request

1. Requests for information must be made in writing; which includes email,
and be addressed to (Emma Hardy, Zoe Newell, Carrie Amor or allocated maternity cover staff). If the
initial request does not clearly identify the information required, then further
enquiries will be made.
2. The identity of the requestor must be established before the disclosure of
any information, and checks should also be carried out regarding proof of
relationship to the child. Evidence of identity can be established by requesting
production of:

  • passport
  • driving licence
  • utility bills with the current address
  • Birth / Marriage certificate
  • P45/P60
  • Credit Card or Mortgage statement

This list is not exhaustive.

3. Any individual has the right of access to information held about them.
However with children, this is dependent upon their capacity to understand
(normally age 12 or above) and the nature of the request. The Director or
Development Manager should discuss the request with the child and take
their views into account when making a decision. A child with competency to
understand can refuse to consent to the request for their records. Where the
child is not deemed to be competent an individual with parental responsibility
or guardian shall make the decision on behalf of the child.
4. The response time for subject access requests, once officially received, is
40 days (not working or school days but calendar days, irrespective of
School holiday periods).
5. Third party information is that which has been provided by another, such as
the Police, Local Authority, Health Care professional or another school.
Before disclosing third party information consent should normally be obtained.
There is still a need to adhere to the 40 day statutory timescale.
6. Any information which may cause serious harm to the physical or mental
health or emotional condition of the student or another should not be
nor should information that would reveal that the child is at risk of abuse, or
information relating to court proceedings.
7. If there are concerns over the disclosure of information then additional
advice should be sought.
8. Where redaction (information blacked out/removed) has taken place then a
full copy of the information provided should be retained in order to establish, if
a complaint is made, what was redacted and why.
9. Information disclosed should be clear, thus any codes or technical terms
will need to be clarified and explained. If information contained within the
disclosure is difficult to read or illegible, then it should be retyped.
10. Information can be provided at the studio with a member of staff on hand
to help and explain matters if requested, or provided at face to face handover.
The views of the applicant should be taken into account when considering the
method of delivery. If postal systems have to be used then
registered/recorded mail must be used.


Complaints about the above procedures should be made to the Chairperson
of the Governing Body who will decide whether it is appropriate for the complaint to be dealt with in accordance with the studio’s complaint procedure.
Complaints which are not appropriate to be dealt with through the studio’s
complaint procedure can be dealt with by the local authority. Contact details of
both will be provided with the disclosure information.


If you have any queries or concerns regarding these policies / procedures
then please contact Emma Hardy or Zoe Newell, Directors , Carrie Amor Dance Development Manager.

please click here to contact us.