BERWYN SCHOOL OF MUSIC
Privacy and cookies policy
1.1 We are committed to safeguarding the privacy of our students, website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.3 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.5 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include [the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is [our legitimate interests, namely the proper administration of our website and business and communications with user.
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely[the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Retaining and deleting personal data
5.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) Usage data, enquiry data, transaction data, notification data and correspondence data will be retained for a minimum period of 18 months following our receipt of that data, and for a maximum period of 7 years following the expiration of our reasonable claim of access to that data, the legal basis for that claim being our legitimate interests, namely the proper administration of our website and business.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of Usage data, enquiry data, transaction data, notification data and correspondence data will be determined based on our reasonable claim of continued access to that data the legal basis for that claim being our legitimate interests, namely the proper administration of our website and business.
5.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
8.2 We may withhold personal information that you request to the extent permitted by law.
8.3 You may instruct us at any time not to process your personal information for marketing purposes.
8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies used by our service providers
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you may not be able to use all the features on our website.
12. Our details
12.1 This website is owned and operated by Patrick Gough.
12.3 Our principal place of business is at Berwyn School of Music, Room 9, 13 Church Street, Oswestry, Shropshire, SY11 2SU
12.4 You can contact us:
(a) by post, to the postal address given above
(b) by telephone, on the contact number published on our website from time to time
(c) by email, using email@example.com
13. Data protection registration
13.1 We are registered as a data controller with the UK Information Commissioner’s Office
13.2 Our data protection registration number is ZA352541
14 Data protection officer
14.0 Our data protection officer’s contact details are: Patrick Gough, 5 The Mews, Roft Street, Oswestry, Shropshire, SY11 2FD