Privacy/Data Protection Policy– GDPR 2018
On 25th May 2018, a new European Union (EU) data protection law, the General Data Protection Regulation (GDPR), takes effect.
The GDPR gives individuals in the EU more control over how their data is used and places certain obligations on businesses that process information of those individuals. We are updating our Policy to take into account the new requirements of the GDPR.
Student confidentiality has always been important to us but in light of the recent Act, we need to ensure that the student and you as parent are aware of all our procedures.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender (in respect of students under the age of 18, this will also include information relating to the person who has parental responsibility for you).
Contact Data includes home address, email address and telephone numbers.
Financial Data includes details of your membership, subscriptions paid or payable to us.
HOW IS YOUR DATA COLLECTED
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- become a member of the Reflex Academy school;
- create an account on our website;
- request marketing to be sent to you or make an enquiry regarding our classes;
- enter a competition, technical course or grading; or
- give us some feedback.
Reflex Academy Limited & B&T Stronach (“Reflex”)collects and processes certain data regarding its students which is necessary to perform a contract for services between Reflex and each student. This information is principally collected at the point of enrolment by the student and contains details of the student’s name, address, date of birth, any medical conditions relating to the student and emergency contact details.
References in this policy to students, shall where such a student is below the age of 18 include the students parents, as notified by such student at the date of registration with Reflex.
In addition to written information regarding student’s identity, Reflex may from time to time take photographs of students at belt tests for the purpose of visually remembering the students who graded and their belt level at that moment in time. With student’s (or parents) signed consent, some photo’s have been used by Reflex for publicity purposes in the past. Where students are below the age of 18 at the date of publication of the photograph, parental consent to such publication has and shall continue to be obtained.
Reflex will periodically ask students to update information by completing a new application form/first aid details form so that Reflex maintains an accurate record of such information.
Reflex will periodically review student records and in any event not less than once each year to ensure that incorrect or out of date information is corrected and/or destroyed. Students are requested to keep Reflex informed of any important changes such as a change in address, contact numbers and medical conditions for a student.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new member||(a) Identity
|Performance of a contract with you|
|To maintain your membership:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Notifying you of changes to our service, class timetables, additional events & queries
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Reflex collects and processes information relating to students for the purpose of fulfilling Reflex’s legal obligation to provide a service to such student, including the following:-
- To enable Reflex to process the student’s membership of the school and Association
- To allow Reflex to maintain class registers, first aid forms, payment information, license booklets, license reminders and grading lists
- To enable Reflex to be aware of any medical conditions of a student whilst they are training.
- To provide Reflex with emergency contact numbers & names in the event of an incident arising at a Reflex lesson or event
- To enable Reflex to contact students (or their parents) with regards to changes to classes, discussions over progress of the student etc.
- To allow Reflex to process grading cards, reminders and membership booklets in respect of each student.
Other Information collected:-
- An events form is completed by the student (or parent) when a student attends an official TAE event such as a sparring seminar.
- A First Aid/Accident form is completed by a First Aider in the event of a medical incident occurring.
- A competition application form is completed by a student (or parent) when a student wants to attend an organised competition.
- An application form is completed for the student and by the student (or parent) for pre-tests and black belt grading’s, with a photograph of the student attached.
How is the information stored?
The only information held on our work mobile (number given to students or their parents at class) is student or parental contact numbers in case we need to communicate with you by text. We do not link this work phone to the internet. It is therefore used purely for the receipt and sending of text messages and making and receiving calls. When a photograph has been taken by us (Reflex) at a grading or other event, we have used the photograph as intended (with consent) and deleted it from our phone camera.
All paper information we hold for a student is stored securely. We do not scan paper documents and nothing is kept on our desktop or other mobile devices. All database information is kept on a secure in-house removable pen drive for our use only.
E-mailed enquiries about classes are kept on our work laptop until they are periodically copied over to our waiting list and onto a secure pen drive for safe keeping and future reference. By making an enquiry about classes, you agree that we may contact you at the appropriate time with the contact details you have supplied regarding a space.
Who is the information shared with?
In general we will not share your information with any third party (including any marketing companies) and we do not use any third party for the chasing and/or collection of outstanding payments due to us, payment queries, student queries or other.
There are a few important exceptions to the rule of sharing however:-
- Applications for Black Belt grading’s and pre-tests. Information regarding a student is shared electronically and in paper form for the purpose of the black belt pre-test and Black Belt grading. This information may also be shared with the TAE Secretary who will pass the student’s information to ITF England for processing and to obtain the necessary ITF Certificate of International Black Belt upon successful achievement.
- It may be necessary for information regarding a student to be shared with other associated Instructors, medical personnel or other authorities such as the police, or fire brigade in the case of an emergency occurring in class or at an event.
- Information regarding a student may also be shared on the rare occasion with an acting Instructor who may take the class in the usual Instructor’s absence. This is normally in the form of the class register and details of any serious medical conditions for them to be aware of.
- Upon a student leaving the school, an e-mail will be sent to all the other TAE connected schools containing the student’s name and to ensure that all TAE schools are aware (from a membership point of view)
- License reminders, license books, payment reminders may be handed to guardians/child minders/other family members for a student under 18 years if the usual parent/guardian is not present and the student’s care has been entrusted to another adult at that time.
- As most payments we received are by standing order, the student’s name (or parents name) with payment amount is noted on our Bank statements. This information is shared with our Accountant (and possibly HMRC) for forumulating our Accounts.
Organisations with who ‘we’ share your information will be asked to confirm that the information will be destroyed once it has been used for the purpose intended, and that such information will not be passed to any other party whatsoever without your knowledge and consent.
WE WILL NOT DIRECTLY SHARE YOUR INFORMATION WITH MARKETING COMPANIES.
How is information transferred?
If any detailed information regarding a student needs to be sent electronically to another Instructor, this will be done using Password Protection for the attached document. These are a list of the possible times when information regarding a student may be transferred electronically:-
- Sending grading candidates details and applications to the grading examiners for the Black Belt pre-test and Black Belt gradings
- Sending a list of competitors to the organiser for a local TAE organized competition
- Sending a list of competitors to the organiser of a national or international competition
- Sending a photograph to another Instructor/school for population on their website or social media page (if/when consent received)
The only time when a password protected document will not be used is when an e-mail is sent communicating to the other TAE associated schools that a student has left or for other similar types of general e-mailed discussions such as competition or grading results.
Websites, Facebook and Social Media
As already the case, specific consent will be obtained by Reflex for the uploading of a photograph by us of a student onto social media or on our school website (reflextkd.com). Consent by the student/parent can be withdrawn at any point and the image will be removed. We cannot however prevent the sharing or copying of an image during the time it is uploaded and please remember that websites/Social Media can be viewed all over the World.
Please also note that whilst every effort is made by us to prevent people taking pictures/videos during classes, we CAN NOT entirely monitor this and therefore images may be uploaded without our knowledge and without our and a student’s/parent’s consent.
Specific parental consent will be obtained at competitions, seminars etc (as part of the application process) for the taking and uploading of a picture onto websites and/or Social Media.
At Reflex gradings in Whitley Bay, we will obtain student/parental verbal consent for parents to take a photograph of all students at the end of the grading. This is on the basis that it will not be shared and/or uploaded onto websites or social media sites, unless written consent has been obtained from all parents/students at the time of the grading.
PLEASE NOTE:- Photographs are generally permitted at competitions and certain other organized events such as technical seminars and pre-tests and we cannot guarantee that parents/spectators/other schools attending will not upload pictures of a student in attendance on their social media and/or website page. If you observe a picture and/or name of a student being uploaded onto sites and you want these removed, please advise us and we will try our best to have these removed on your behalf. Sharing or copying may have already occurred however.
AT SOCIAL EVENTS SUCH AS CHRISTMAS PARTIES, THE TAKING AND SHARING OF PHOTO’S WILL BE CONSIDERED AN INTEGRAL PART OF CELEBRATING THE EVENING.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our students (including Contact, Identity, and Financial Data) for six years after they cease being customers for [tax] purposes.]
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Photo images of a student taken by Reflex at grading’s and other events will be deleted after their use, for instance uploading onto a website or on Social Media (with consent obtained for uploading and use as necessary). If a student leaves the school, their details will be deleted from our register and database and any photo images uploaded onto the Reflex website will be removed. Some images may have already been shared however by others.
You may request at any time to have the data we hold about you destroyed. Please note however that for health and safety reasons, it is essential that we have such information if a student is to continue with their classes at Reflex and it is preferable for us to retain such information for a period of six years after leaving the school.
A student/parent can request sight of their information at any point. This will be made available within one month of the request.
How we will communicate with you?
We will generally use a text message (number available from us in class) or e-mail (email@example.com) to communicate with you. We will sometimes call you on the numbers you have provided to us. Most communication is in person however at Reflex. . Social media will be used mainly for informing students of important news/events coming up.
THESE RULES ARE SUBJECT TO PERIODIC REVIEW AND AMENDMENT. PLEASE CHECK THEM REGULARLY.
Any queries can be directed to Reflex at:- firstname.lastname@example.org
By enrolling with Reflex, you agree that you have read and understood our Policy and agree to comply with it.