Privacy Notice
Jersey Academy of Music referred to as (“JAM”), ‘we’ or ‘our’ is committed to protecting the privacy and security of your personal information.
This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us under the Data Protection (Jersey) Law 2018 (“DPJL”).
JAM is a “Data Controller”, which means we are responsible for deciding how we hold and use personal information.
We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
JAM is registered with the Jersey Office of the Information Commissioner (“JOIC”) – Registration No. 100284
We will comply with data protection law, the principles of which says that the personal information we hold about you must be:-
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept your data only as long as necessary for the purposes we collected it.
6. Kept securely.
We will also only transfer your information when it is safe to do so, when necessary, and your information is protected in the same way that we protect it.
JAM is accountable to you and the Authorities to show compliance with the data protection laws and demonstrate how we are compliant.
The Data Protection Manager (“DPM”)
We have appointed a DPM to oversee compliance with this Privacy Notice.
If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPM at mailto: principal@jerseyacademyofmusic.co.uk
principal@jerseyacademyofmusic.co.uk
You have the right to make a complaint at any time to the JOIC.
Contact details for these are outlined at the bottom of this Privacy Notice.
The Kind of Information We Hold 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).
To explain this to you, we will list our different services when we collect or use additional information about you.
How Is Your Personal Information Collected?
We collect personal information about you when you contact us, when you enquire about our product and services or provide us with your data for another specific purpose.
What information do we collect about you?
Name
Title
Address
Date of Birth
General Practioner
Photograph
Telephone number
Occupation
Email address
Signature
Medical History
School Attendance
What Special Category Data do we collect about you?
When we collect Special Category data, we will always have a clear legal basis to process this or your explicit consent. If we rely on your explicit consent, you can withdraw this at any time by contacting our DPM at mailto: principal@jerseyacademyofmusic.co.uk principal@jerseyacademyofmusic.co.uk
Special Category data is any information relating to your health, gender, race, sexual orientation, sex life, genetic or biometric data etc.
An example of this processing would be disclosing any relevant health or medical information, that your childs’ tutor may need to know. We have a legal obligation to collect this information and store it.
How We Will Use Information About You?
We will only use your personal information when the law allows us to.
Most commonly, we will use your personal information in the following circumstances:
1. You have entered into a contract with us to provide you with a service; an example of this would be when you accept our terms and conditions to benefit from music lessons.
2. Where you have given your Consent to contact you for a specific purpose; an example of this would be, us using your child(ren)’s image to be used for academy promotional material.
3. We need to comply with a legal obligation; an example of this would be when we have to keep a register of names of people who are in the building for Health and Safety purposes and or for medical purposes and or to declear to Police.
4. Where it is necessary for our legitimate interests (or those of a third party), your interests and fundamental rights do not override those interests. An example of this is when we send you information about music lessons we know would be of interested.
We may also use your personal information in the following situations, which are likely to be rare:
1. In an emergency, it is in your Vital Interest to share your information when we have it recorded.
Change of purpose
We will only use your personal information for the purposes we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
Data Sharing
We may, on occasions, pass your Personal Information to an organisation outside of JAM exclusively to process on our behalf; these organisations are called Data Processors.
We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice.
We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid legal requests from the Courts or Law Enforcement.
The personal data we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA”).
It may also be processed by companies outside the EEA who work for one of our service providers or us.
If we do this, we ensure that your privacy rights are respected in line with this Policy and the same protection is given to your personal information as laid down by the DPJL.
Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Colleagues, Agents, Contractors and other third parties on a need to know basis.
They will only process your personal information on our strict instructions, and they are subject to a duty of confidentiality.
Details of these measures may be obtained from our Data Protection Manager (DPM).
We have put in place procedures to deal with any suspected data security breach and notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data Retention
All data is retained securely and only used for the purposes set out in the Law. Data is retained to comply with our statutory obligations and in accordance with our retention schedule. If you would like a copy of our retention schedule, please contact our DPM at mailto: principal@jerseyacademyofmusic.co.uk principal@jerseyacademyofmusic.co.uk
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 data. The purposes for which we process your data and whether we can achieve those purposes through other means and the applicable legal requirements.
You can request our Data Retention Schedule from our DPM if required.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of Access, Correction, Erasure, and Restriction
The personal information we hold about you must be accurate and current.
Please keep us informed if your information changes during your relationship with us.
Under certain circumstances, by law, you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This right enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This right enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal information. This right enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing your personal information where we rely on a legitimate interest (or those of a third party). There is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object to processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This right enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request the erasure of your personal information, object to the processing or request that we transfer a copy of your personal information to another party, contact our DPM at mailto: principal@jerseyacademyofmusic.co.uk principal@jerseyacademyofmusic.co.uk
You will not have to pay a fee to access your personal information (or exercise any other rights). However, we may charge a reasonable fee if your access request is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
How to request your information and what we may need from you
Use the Data Subject Access Request form, available on our Cookie Banner. If you have any questions about this process or any of your rights, contact our DPM at mailto: principal@jerseyacademyofmusic.co.uk principal@jerseyacademyofmusic.co.uk
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or exercise any of your other rights).
We will respond without undue delay, but within the 4 weeks allow in law upon satisfactory verification of your identity. If we need to extend this time we will inform you as soon as possible. We are allowed up to a further 8 weeks in certain circumstances.
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, contact our DPM
mailto:principal@jerseyacademyofmusic.co.uk principal@jerseyacademyofmusic.co.uk.
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.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.
We may also notify you in other ways from time to time about the processing of your personal information or requesting you to confirm the accuracy of the information we hold on you.
Complaints
We want the chance to resolve any complaints you have about how we process your information. You have the right to complain to the Jersey Office of the Information
Commisssioner about how we have used your data. The details for each of these contacts are:
Jersey Academy of Music – DPM
Chateau Vermont, Le Mont Sohier, St. Saviour, Jersey CI, JE2 7HA, UK.
Telephone +44 (0) 1534 720030 or email mailto:principal@jerseyacademyofmusic.co.uk principal@jerseyacademyofmusic.co.uk
Office of the Information Commissioner
2nd Floor, 5 Castle Street, St. Helier, Jersey JE2 3BT
Telephone +44 (0)1534 716530 or email HYPERLINK mailto:enquiries@jerseyoic.org
enquiries@jerseyoic.org