WestWay
Performing Arts
Introduction
WestWay Theatre School of Performing
Arts Limited and its subsidiaries (trading as WestWay School of Performing
Arts) is committed to protecting your personal data. As a business it is
necessary for us to collect, store and process personal data about our
customers, suppliers, and other third parties who we engage with to provide
services for us or with whom we do business. This Privacy Policy gives you
detailed information on when and why we collect your personal data, how we use
it and how we keep it secure.
With the introduction of the General Data Protection Regulation ((EU) 2016/679)
(GDPR), the way personal data is kept and used by businesses has come under
much greater scrutiny. This Privacy Policy is therefore very important to us
and sets out how we will process personal data we collect from, or is provided
by, data subjects and others on their behalf.
This Privacy Policy sets out how we comply with our legal obligations when
processing personal data and enables individuals about whom we hold data to
have confidence in us. It is important that you read this Privacy Policy. This
Privacy Policy may be amended at any time so please check back to this page
from time to time. We may also inform you of any changes where we hold an
appropriate email address for you. This Privacy Policy was updated in August
2018.
Contact Information
WestWay School of Performing Arts
Limited (“WestWay”) is a limited company incorporated in England and Wales
If you have any questions regarding how we use your personal data, please
contact us at:
Address: 52 Church Road,
Richmond, TW10 6LN
Telephone: 07449500530
Email: westwayperformingarts@outlook.com
What do the terms used in this
Privacy Policy mean?
There is likely to be a lot of data
protection terminology that you may be unfamiliar with and which has a specific
meaning under data protection legislation. The terms that are used most
frequently include:
Data subject means a living individual about whom we hold personal data. A data
subject need not be a UK national or resident.
Data controller is a term used to describe the people who, or organisations
which, determine the purpose and manner for which any personal data is
processed. Both WestWay Head Office and WestWay Franchisees are data
controllers of the personal data used in our business for commercial purposes.
Data processors means any person or organisation that processes personal data
on our behalf and on our instructions. Employees of data controllers are
excluded from this definition, but it could include suppliers, administrators
and teachers who handle personal data on behalf of the the data controller.
Personal data means data relating to a data subject who can be identified (directly
or indirectly) from that data (or from that data and other information in our
possession or available to us). Personal data can be factual (e.g. a name,
address, date of birth or a photograph etc.) or it can be an opinion about that
data subject, their actions and behaviour.
Processing is a term used to describe what we do with the data, such as
collection, recording, organisation, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction. Processing also includes transferring (or
disclosing) personal data to third parties.
Special categories of personal data is a term used to describe sensitive personal
data such as information about a person's racial or ethnic origin, political
opinions, religious or similar beliefs, trade union membership, physical or
mental health or condition or sexual life, genetic data and biometric data
where processed to uniquely identify a person or about the commission of, or
proceedings for, any offence committed or alleged to have been committed by
that person, the disposal of such proceedings or the sentence of any court in
such proceedings. Sensitive personal data can only be processed under strict
conditions.
How we collect your personal data
Generally, we collect your
information when you decide to interact with us. This could include you sending
us your details online, over the phone or in person.
We collect information in a number of ways which are listed below:
1.
When you use our website to enrol
your child, pay fees, register for an event or enquire about our services.
2.
When you contact us by phone to enrol
your child or enquire about our services.
3.
When you contact us by post
4.
When you visit our website we use
cookies to help make the experience of using our website better and to
personalise the service you receive from us – this means we will remember your
previous visits and track the pages on our website that you visit. For more
information please see our Cookie Policy.
5.
From time to time, we may also get
data about you from third parties – please see the ‘How we may use your
information’ section for more details. This could include data obtained by a
supplier or where you have participated in a survey or event.
6.
You may provide us with information
to be used in connection with a show or performance.
The type of personal data we collect
We only collect the information that’s
necessary to carry out our business, provide the particular service you’ve
requested and/or to keep you informed. There are occasions when you can choose
not to give us certain information, but this may limit the level of
personalisation we can offer e.g. – for example, you may not get to hear about
an event you would have loved to have attended.
In some circumstances we will request your consent to use certain information
for specified purposes. In such circumstances you will have the free choice to
give, refuse or withdraw consent. In the case of personal data relating to a
child under the age of 16, we will require the consent of a parent or
legal guardian. Individuals aged 16 or over may give, refuse or withdraw
consent (whether the consent was originally given by themselves or on their
behalf) themselves.
The type of information we collect depends on where and when it is gathered:
Information we obtain directly from
you:
When you register on our website or contact us to enquire about a service, to
enrol, become a Teacher or Principal or attend an event, by post or phone we
need to collect information from you in order to provide the service you are
requesting.
We may collect:
·
Your Name
·
Your Child’s Name
·
Gender
·
Your Child’s Gender
·
Your Email Address
·
Your Child’s Date of Birth
·
Contact phone number(s)
·
Payment Details
·
Your Child’s Medical Information
·
Address(es)
When visiting our website, we may collect the following
information:
Automatically populated IP address: a
public IP address is a unique number which allows a computer, group of
computers or other internet connected device to browse the internet. The log file
records the time and date of your visit, the pages that were requested, the
referring website (if provided) and your internet browser version. This
information is collected to help diagnose and manage the website, to audit the
geographical makeup of users, and to establish how they have arrived at the
website. This is known as a cookie.
For further information about Cookies and how WestWay uses them, please read
the WestWay Cookie
Policy
Information we obtain independently from you:
Your information may be shared with
us by independent organisations, for example other course organisers that WestWay
has worked with. These independent organisations will only do so when it is
required to complete a contract and/or when you have indicated your consent.
You should check their privacy policy when you provide your information to
understand fully how they will process and safeguard your personal data.
Third Party Organisations:
We may combine information you have
given to us with this additional information available from external sources.
This will only be done when you give permission to the relevant third party
organisations to share the data they hold on you, or if the data is already
publicly available.
Information available publicly:
We may include information published in articles/ or newspapers or on
freely accessible social media platforms.
Why we collect your personal data and
how we use it
The information we hold on you will
be used in a number of ways. Here are the main ones: to provide a service you
have requested, offer you a personalised experience and understand your needs
better, inform you of events or updates you’ve asked for or contact you if we
need to obtain or provide additional information.
Specifically, we use your information we collect in the following ways:
To carry out our business and to provide a service or fulfil a contract with
you:
·
To fulfil enrolment registration and
information requests.
·
Medical details are obtained to
enable us to fully support your child’s welfare in setting.
·
Provide the best possible customer
services and to help us with internal administration.
·
Contact you with important
information relating to your registration, such as confirming your request,
reminding you of an upcoming event or letting you know about changes to the
service.
Where we have your consent:
·
Send you updates via email about
upcoming events and opportunities that we think may be of interest to you.
·
Email you about a specific topic you’ve
requested to hear more on such as our student scheme or other projects.
·
Share your details with other
performance arts-based organisations (including our partner, Trafalgar
Entertainment Group) who collaborate with WestWay. These organisations will
contact you to let you know how they collected your data and to check that
you’re still happy to hear from them. You will always be able to opt out of
their communications by contacting them directly.
·
Use your personal data (or that of
your child) in our marketing campaigns.
Where we have justifiable reason
(including legal obligation and legitimate interest):
·
Learn about your interests and
preferences so that we can contact you with information that is relevant to
you.
·
Help us target our marketing communications
and adverts so that they’re more relevant to you.
·
Use your pseudonymised details to
show you advertising on such Social Media platforms as Facebook and Instagram
or through other third party advertising that may appear on other websites you
use. The information shared with these platforms is pseudonymised to protect
your personal data.
·
Measure and understand how our
audiences respond to a variety of marketing activity so we can ensure our
activity is well targeted, relevant and effective.
·
Undertake user research: we may
contact you to ask you to participate in user research either via an online or
telephone survey or in person. You are under no obligation to participate in
research and, should you provide any further information, WestWay will inform
you how any further information will be used.
·
Analyse and continually improve the
services we offer including our website and our other products.
·
To help us run the test version of
our website that we use internally to pilot new features and ensure the smooth
running of our web services.
How we process your personal data
WestWay will never share, sell, rent
or trade your personal information to any third parties for marketing purposes
without your prior consent.
Some of our service providers may have access to your data in order to perform
services on our behalf. We make sure anyone who provides a service for WestWay
enters into an agreement with us and meets our standards for data security.
They will not use your data for anything other than the clearly defined purpose
relating to the service that they are providing.
We may share your details with:
·
Service providers who work on behalf
of WestWay for the performance of any contract we enter into with them or you,
for example, payment processing, printers and mailing houses, marketing
agencies, database services, website hosting or email delivery service.
·
Other organisations such as
competition organisers, photographers and survey providers etc. if you choose
to take part in such activities that need administration by third parties and
you choose to opt in for contact from those organisations.
·
Third party data services, -
for example, Experian, - who help us to segment and understand our audience by
providing additional information so that we can send the most relevant and
targeted communications possible.
·
Third party advertisers (such as
Facebook or Google) to help us identify customers similar to our audience or to
serve relevant adverts to you on third party websites. The information shared
with these advertisers is pseudonymised to protect your personal data.
·
Trafalgar Entertainment Group, a
partner of WestWay Performing Arts. This data will only be shared subject
to you choosing to opt in for contact from them. The Trafalgar Group
Privacy and cookie policies can be reviewed at
http://trafalagarentertainment.com/privacy-and-cookies-policy
·
WestWay is not responsible for the
privacy policies and practices of other websites even if accessed using links
from www.WestWay.co.uk/WestWayfranchise.com and recommends that you check the
privacy policy of each website you visit and contact its owner or Data
Protection Manager if you have any concerns or questions.
Despite all our precautions, no data transmission over the internet is 100%
secure. So, we cannot guarantee the security of any information which you
disclose to us and so wish to draw your attention to the fact that you do so at
your own risk.
Keeping your personal data secure
WestWay is committed to protecting
the personal information you entrust to us. We adopt robust and appropriate
technologies and policies, so the information we have about you is protected
from unauthorised access and improper use.
As part of the services offered to you through the WestWay website, the
personal information you provide may be transferred to countries outside the
European Economic Area (EEA). By way of example, this may happen if any of the
computer servers used to host the website are located in a country outside of
the EEA. If WestWay transfers your personal information outside of the EEA in
this way, we will take steps to ensure that your privacy rights continue to be
protected as outlined in this Privacy Policy.
WestWay may transfer your data to the USA to organisations such as Facebook or
Google. The USA has weaker data protection laws than that of the EEA, and therefore
we will ensure that only organisations who are a part of the EU/US
privacy shield initiative will handle your personal information. More details
on this certification can be found at www.privacyshield.gov/welcome
We will keep your information only for as long as is reasonably necessary for
the purposes set out in this Privacy Policy and to fulfil our legal
obligations. We will not keep more information than we need. The retention
period will vary according to the purpose. For example, partially completed
enrolments (12 months), enquiries (12 months), CV’s (6 months). For
further information about how long we will keep any particular piece of
information, please contact us using the contact details outlined in this
Privacy Policy.
If you ask us to stop sending direct marketing communications to you, we will
keep the minimum amount of information (e.g. name, address or email address) to
ensure we adhere with such requests.
Your rights
You
should find it easy to access and amend the personal information that we hold
on you, or request that we stop contacting you. It’s your data and we want to
make sure you feel in control of it.
Every email we send to you will include details on how to change your
communications’ preferences or unsubscribe from future communications. If you
would like to see what information we hold, you can request full details.
You can also request full details of personal information we hold about you
under the Data Protection Act 1998, or after 25 May 2018, The General Data
Protection Regulation 2018, by contacting the Data Protection Officer, Peter
Brayshaw. Please email a description of the information you would like to see,
together with proof of your identity to finance@WestWay.co.uk.
At any time you have the right to ask WestWay to amend or stop how it uses your
personal information including for marketing purposes. You can do this by
phoning, emailing or writing using our contact details below. You have the
right to get information held about you by us corrected. If you have any
concern about the accuracy of your personal data, please let us know using the
below contact details. If you would like us to remove the personal information
we hold about you, please contact us using the contact details below.
If you have given consent to the collection, processing and transfer of your
personal data for a specific purpose, you have the right to withdraw your
consent for that specific processing at any time. To withdraw your consent,
please contact us, WestWayperformingarts@outloo.com
Once we have received notification that you have withdrawn your consent, we
will no longer process your information for the purpose or purposes you
originally agreed to, unless we have another legitimate basis for doing so in
law.
When dealing with a request from a child relating to any of the above rights,
we will need to make a decision on whether the information should be provided
to them or to their parents/legal guardian and will be guided by the
individual’s age at the time of request and their level of understanding about
what they are requesting and why. For these purposes, we take the view that
most children will reach this level of understanding at around age 16.
You have the right to lodge a complaint with the supervisory authority, The
Information Commissioner’s Office – www.ico.org.uk
By email: Please complete the form at
https://ico.org.uk/global/contact-us/email/
By phone: 0303 123 1113
By post: Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
WestWay School of
Performing Arts Limited
March 2020