Data Protection Policy
1. Introduction
In the course of it’s service delivery, ARTventurers as a business needs to collect and use certain types of information about the Individuals, customers or Service Users (including children) who come into contact with us, book onto any of our sessions or attend a session delivered by us.
This personal information must be collected and dealt with appropriately whether is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the Data Protection Act 2018 and GDPR and any other applicable data protection legislation.
Information collected by us will include :
Parent/carer details including name, address and contact information (email address and phone number) and emergency contact details
Children’s names and dates of birth and medical/allergy/health information
Whether or not they provide permission for photographs
This information is required by ARTventurers for Health and Safety and Child Protection reasons, insurance and for session planning purposes.
ARTventurers is a franchise business. Each franchise branch is an independent legal entity and each branch adopts this policy as their own. Each franchise branch has a nominated Data Controller and is independently registered with the Information Commissioner.
2. Data Controller
ARTventurers Limited is responsible for any data collected directly via this website – see our website policy below.
Each franchise branch operates its own booking system through which they collect customer information. Each branch has its own Data Controller under the Act, which means that they determine what purposes personal information held, will be used for. They are also responsible for notifying the Information Commissioner of the data they hold or are likely to hold, and the general purposes that this data will be used for.
3. Disclosure
In certain circumstances data from the individual franchise branch may be shared with ARTventurers Head Office or with other members of the ARTventurers Team. This for example would be when a franchise branch is sold or transferred and and customer information is passed from one franchisee to another.
ARTventurers may share some data with other agencies such asthe local authority, funding bodies and other agencies.
The Individual/Service User will be made aware in most circumstances how and with whom their information will be shared. There are circumstances where the law allows ARTventurers to disclose data (including sensitive data) without the data subject’s consent.
These are:
- Carrying out a legal duty or as authorised by the Secretary of State
- Protecting vital interests of a Individual/Service User or other person
- The Individual/Service User has already made the information public
- Conducting any legal proceedings, obtaining legal advice or defending any legal rights
- Monitoring for equal opportunities purposes – i.e. race, disability or religion
- Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.
ARTventurers regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.
ARTventurers intends to ensure that personal information is treated lawfully and correctly.
To this end, ARTventurers will adhere to the Principles of Data Protection, as detailed in the Data Protection Act 2018.
Specifically, the Principles require that personal information:
- Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
- Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
- Shall be adequate, relevant and not excessive in relation to those purpose(s)
- Shall be accurate and, where necessary, kept up to date,
- Shall not be kept for longer than is necessary
- Shall be processed in accordance with the rights of data subjects under the Act,
- Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
- Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Service Users in relation to the processing of personal information.
ARTventurers will, through appropriate management and strict application of criteria and controls:
- Observe fully conditions regarding the fair collection and use of information
- Meet its legal obligations to specify the purposes for which information is used
- Collect and process appropriate information, and only to the extent that it is needed to fulfill its operational needs or to comply with any legal requirements
- Ensure the quality of information used
- Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:
- The right to be informed that processing is being undertaken,
- The right of access to one’s personal information
- The right to prevent processing in certain circumstances and
- The right to correct, rectify, block or erase information held about them
- Take appropriate technical and organisational security measures to safeguard personal information
- Ensure that personal information is not transferred abroad without suitable safeguards
- Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
- Set out clear procedures for responding to requests for information
4. Data collection
Informed consent is when
- An Individual/Service User clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data
- And then gives their consent.
ARTventurers will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.
When collecting data, ARTventurers will ensure that the Individual/Service User:
- Clearly understands why the information is needed
- Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing
- As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
- Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
- Has received sufficient information on why their data is needed and how it will be used
5. Data Storage
Information and records relating to service users will be stored securely and will only be accessible to authorised staff and volunteers.
In particular :
1) All documents in electronic form will be kept securely and password protected
2) Each franchise branch operates its own booking system which is hosted by ThinkSmart Limited. Customers book and submit payment for sessions through this booking system and customer data is transferred directly to the franchise branch, not via or to ARTventurers Limited.
2) All information submitted by Individuals/Service Users through the ThinkSmart Limited booking system is submitted through a secure site with an up to date security certificate
3) ThinkSmart Limited are responsible for the privacy of data submitted through their booking system and software and a full copy of their privacy policy can be found at https://www.thinksmartsoftware.com/privacy-policy/uk
3) Paper records will be stored securely in a locked fire proof cabinet in a secure environment and any paper records taken out and about to sessions will be kept confidential and secure
Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.
It is the Data Controllers responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.
6. Data access and accuracy
All Individuals/Service Users have the right to access the information ARTventurers holds about them. ARTventurers will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, the Data Controller will ensure that:
- Everyone processing personal information understands that they are contractually responsible for following good data protection practice
- Everyone processing personal information is appropriately trained to do so
- Everyone processing personal information is appropriately supervised
- Anybody wanting to make enquiries about handling personal information knows what to do
- They deal promptly and courteously with any enquiries about handling personal information
- The franchise branch describes clearly how it handles personal information
- The franchise branch will regularly review and audit the ways it hold, manage and use personal information
- The franchise branch regularly assesses and evaluates its methods and performance in relation to handling personal information
- All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them
This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR) 2018
In case of any queries or questions in relation to this policy please contact the Data Protection Officer
Our Website Privacy Policy
Who we are
Our website address is: https://www.artventurers.co.uk
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
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Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have left comments on this website, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where your data is sent
Visitor comments may be checked through an automated spam detection service.