Joco Dance and Theatre Arts LLP - GDPR and Child Protection Policies
GDPR stands for General Data Protection Regulation and replaces the Data Protection Directives previously in place. GDPR states that personal data should be ‘processed fairly and lawfully’ and ‘collected for specified, explicit and legitimate purposes’ and that an individual’s data is not processed without their knowledge and only processed with their ‘explicit’ consent. GDPR covers personal data relating to individuals. JOCO DANCE AND THEATRE ARTS LLP is registered with the ICO (Information Commissioners Office) and is committed to protecting the rights and freedoms of individuals with respect to the processing of all relevant personal data. The following rights are afforded:
1) The right to be informed: To carry out the services provided by JOCO DANCE AND THEATRE ARTS LLP, a certain amount of personal data is gathered regarding students, parents/guardians, visitors, and those working as teachers. To ensure the welfare of the students, administer classes, carry out examinations and stage performances such as the yearly show, JOCO DANCE AND THEATRE ARTS LLP needs to obtain and maintain up to date records of student details such as names, addresses, dates of birth and classes attended etc. To facilitate the above and in order to be able to liaise with parents/guardians or other relevant individuals we need to obtain and maintain details of named individuals who are responsible for the student, their telephone numbers, email addresses and home addresses. We also need to obtain and maintain records of any idiosyncratic information around students who have SEN or medical issues to enable us to ensure their welfare. We also may need to share this information under certain necessary circumstances, such as with chaperones and briefed helpers during a show performance or teachers providing tuition. All those with whom the information is shared will be aware of their responsibilities in regards to the said information. Regarding examinations and show performances, we share personal information regarding our students with the IDTA (International Dance Teachers’ Association) and Surrey County Council respectively. When in the possession of the above organisations, the information is protected by their relevant protocols.
JOCO DANCE AND THEATRE ARTS LLP is required to obtain and maintain data on teachers working with us such as names, addresses, email addresses, telephone numbers, dates of birth, National Insurance numbers, photographic ID such as passport and drivers’ licences and bank details. This information is also required for Disclosure and Barring Service checks (DBS) and proof of eligibility to work in the UK. DBS check numbers and date of issue are also held on such records.
2) The right of access: At any point an individual can make a request to obtain details of their data or data of any dependant held by JOCO DANCE AND THEATRE ARTS, and we will provide a response without undue delay and in any case within 1 month. JOCO DANCE AND THEATRE ARTS can refuse a request if we have a lawful obligation to do so, and we will inform the individual of the reasons for the refusal. The individual will have the right to complain to the ICO if they are not happy with the decision.
3) The right to erasure: You have the right to request the deletion of your data where there is no compelling reason for its continued use. However, JOCO DANCE AND THEATRE ARTS LLP, in certain circumstances, has an obligation to keep students’ and parents’/guardians’ details for a reasonable time. For example, records in relation to injuries, complaints and circumstances which may reasonably be thought to lead to an investigation. JOCO DANCE AND THEATRE ARTS LLP may retain these records indefinitely pending regular review. This data is archived securely electronically and/or physically and shredded after the legal retention period.
4) The right to restrict processing: Parents/guardians, students and teachers can object to JOCO DANCE AND THEATRE ARTS LLP processing their data at any stage and JOCO DANCE AND THEATRE ARTS LLP will cease to do so. The data will be stored but will not be used in any way.
5) The right to data portability: Parents/guardians may request that the data held by JOCO DANCE AND THEATRE ARTS LLP may be provided to them in a format which can be easily transferred to another party. JOCO DANCE AND THEATRE ARTS LLP will comply with such requests without undue delay and in any case within 1 month.
6) The right to object: Parents/guardians, students and teachers can object to their data being used for certain activities like marketing or research. JOCO DANCE AND THEATRE ARTS LLP will never provide personal data to third parties for research purposes, and any marketing will be restricted entirely to the activities of JOCO DANCE AND THEATRE ARTS LLP and opportunities therein.
7) The right not to be subject to automated decision-making including profiling: Marketing organisations use automated decision-making and profiling. JOCO DANCE AND THEATRE ARTS LLP does not use personal data for such purposes.
Storage and use of personal information:
After receipt, all paper copies of student and teacher records are transferred to a secure electronic format. The paper copies are subsequently shredded, with the exception of some specific teacher related documents. These records are accessed when necessary by two select staff members, both of whom are aware of their obligations re the security of the data. These records are deleted when no longer needed (see above for relevant circumstances). Information gleaned from these documents is only shared where necessary with those who are required to be aware. For example, names of students with teachers, and telephone numbers of parents/guardians to facilitate contact when necessary regarding the welfare of the students. Electronic copies of such documents are kept securely, on a computer which is password protected and on two backup drives which are both password protected and encrypted. These are stored behind a locked door when not in use or in a building occupied by a responsible staff member.
In full compliance with the responsibilities dictated by data protection legislation, information will be shared where there is a “vital interest” with relevant authorities (such as Police or safeguarding organisations), or in relation to general safeguarding issues if they arise. All such instances will be fully compliant with relevant data protection legislation.
Additionally, JOCO DANCE AND THEATRE ARTS LLP stores personal data held in the form of photographs, video clips or as sound recordings unless parents/guardians have chosen not to opt in to allowing such media to be processed and/or shared. No names are stored with images in photo albums, displays, on the website or on JOCO DANCE AND THEATRE ARTS LLP’s social media presence.
If a parent/guardian has opted in to allow images and videos of their child(ren) to be shared on social media, said images and videos may be shared in relation to such instances as (but not limited to) show performances, highlighting achievements and general demonstrations of class activity. It must be noted, however, that JOCO DANCE AND THEATRE ARTS LLP is entirely unable to prevent third parties from identifying the images of the children in such circumstances as comments and/or posts etc. For example, if an unidentified image of a child is posted with a trophy, others may comment offering congratulations with the child’s name. The risk of this occurrence must be acceptable to the parent/guardian if they are to opt in to the aforementioned permission. JOCO DANCE AND THEATRE ARTS LLP is not responsible for third party posts on social media platforms, however we endeavour to police our social media platforms for any inappropriate comments/posts etc and take appropriate action.
If parents/guardians opt in to allowing JOCO DANCE AND THEATRE ARTS to process images/video/audio specifically in relation to the yearly show, they must accept the possibility that images of their child may be shared by third parties in relation to their children. For example, a parent may share an image of a group of dancers including their child, however inadvertently including other children. A plea to audience members not to share their own images on social media to attempt to prevent this will be made before every performance. If a parent/guardian opts NOT to allow JOCO DANCE AND THEATRE ARTS to process and share images/video/audio of their child on social media however DOES opt to allow processing of images/video/audio of their child in relation to the show, every effort will be made not to include said child in posts on our social media platforms. Parents/guardians must be aware that a DVD will be recorded, and professional photographs taken, at the time which will be available for other parents/guardians to purchase – it will not be possible to remove individual children from these formats. IT MUST BE NOTED THAT IF A PARENT/GUARDIAN OPTS OUT OF THE LATTER AUTHORISATION, THE CHILD IN QUESTION WILL NOT BE ABLE TO PERFORM IN THE SHOW.
Joco Dance and Theatre Arts LLP recognises its duty of care under the Children and Young Persons Act 1963, the Children (Performances and Activities) (England) Regulations 2014, the Children Act 1989 and 2004 and the Criminal Justice and Court Services Act 2000 (in Scotland Protection of Children (Scotland) Act 2003), Working Together to Safeguard Children 2018.
Child protection is at the very core of the values of Joco Dance and Theatre Arts LLP, and all those working for or with the partnership. Joco Dance and Theatre Arts LLP is fully committed to safeguarding the welfare of all children and young people involved with the partnership. It recognises its responsibility to take all reasonable steps to promote safe practice and to protect children from harm, abuse and exploitation. Joco Dance and Theatre Arts LLP acknowledges its duty to act appropriately to any allegations, reports or suspicions of abuse. Paid staff and volunteers will endeavour to work together to encourage the development of an ethos which embraces difference and diversity and respects the rights of children, young people and adults. Set out below are some of the principles by which Joco Dance and Theatre Arts ensure the welfare of all students.
Joco Dance and Theatre Arts LLP is a limited liability partnership with two appointed partners, Mrs Josephine Clarke and Mr Peter Clarke. Throughout the following document, they shall be referred to as “the partners”.
All students will be treated equally, and their dignity maintained. No form of unfair discrimination will be tolerated by Joco Dance and Theatre Arts LLP.
No form of bullying will be tolerated by Joco Dance and Theatre Arts LLP. If established, those found to be bullying others will be subject to appropriate sanctions.
Any and all suspicions and/or allegations of abuse will be taken seriously, responded to swiftly and dealt with appropriately. The partners will refer relevant child protection concerns to the statutory child protection agencies (i.e. Police and/or Children’s Social Care).
The wellbeing and safety of students takes precedence over all other factors and aims in regards to tuition.
No energetic instruction will be given without pupils undergoing a “warm-up” session, and after an energetic session completing a “warm-down” session.
Joco Dance and Theatre Arts LLP hold details of a primary contact for each student, who is usually be a parent/guardian/carer for said student. It is with this primary contact only that Joco Dance and Theatre Arts LLP liaise with in regards to said student. Any other individuals wishing to liaise with Joco Dance and Theatre Arts LLP in regards to said student, the primary contact would need to confirm, in writing, that permission is given to do so.
All students attending each class will be detailed on a register which will be on the premises throughout the class. They will be counted in at the beginning, and counted out at the end, to ensure they are accounted for throughout their time on the premises.
No student will be allowed to leave the premises until collected by a parent, guardian or other adult authorised to do so by a parent or guardian unless of an age to do so. A member of staff will remain on the premises until all pupils have left.
No student will be photographed or videoed without the consent of the primary contact.
A register of all students and emergency contact details will be available to staff at all times to ensure the welfare of the students.
All staff at Joco Dance and Theatre Arts LLP understand their legal and moral responsibility to protect students from harm, abuse and exploitation.
All staff understand their duty to report concerns that arise about a child or young person to the partners for appropriate action.
Enhanced DBS checks are carried out on all staff, the results of which are made available to the partners for recruitment decisions.
Apart from in exceptional circumstances agreed with both partners, no staff will make or maintain contact with any student on social media or equivalent platforms.
Only suitably qualified individuals will be employed in a teaching capacity while any other individual engaged to assist with teaching will only work under the supervision of a qualified member of staff.
All instruction will be geared to the previous experience and abilities of the student(s) and no student will be required to perform movements beyond their capabilities.
Teachers will avoid any unnecessary physical contact with pupils. However, parents should understand that some aspects of teaching involve some proportionate and appropriate contact.
If and only when required, teachers will offer proportionate physical comfort to students who are distressed or upset during classes. Staff will seek the consent of the child prior to any physical contact and the purpose of the contact shall be made clear.
The partners will ensure that all members of staff are properly insured against incidents involving public liability and professional negligence insurance.
At all times, all staff will endeavour to keep the highest standards of instruction and behaviour. The partners retain the right to discharge from the school any pupil who persistently disrupts the tuition or takes part in or instigates other anti-social behaviour.
In the event of activities “off premises”, staff will regard themselves as being in “loco parentis” and, so far as applicable and within their control, apply the preceding and subsequent guidelines.
Joco Dance and Theatre Arts LLP will liaise with venues utilised used to ensure they are free of hazards and fit for use for the purposes of the classes.
At all classes a fully equipped first aid kit will be available if, and when, required.
The Principal of Joco Dance and Theatre Arts, Josephine Clarke, is the partnership’s dedicated Child Protection/Welfare/Safeguarding Officer and is in charge of ensuring that the safeguarding policy and procedures are adhered to. She can be contacted on email@example.com or 07425162277.
In implementing this child protection policy Joco Dance and Theatre Arts LLP will:
- Communicate to all workers/members their legal and moral responsibility to protect children and young people from harm, abuse and exploitation.
- Communicate to all workers/members/volunteers/members their responsibility to work to the standards that are detailed in the Surrey Safeguarding Children Board and the need to work at all times towards maintaining high standards of practice in protection of children.
- Ensure that all workers/members understand their duty to report concerns that arise about a child or young person, or a worker’s conduct towards a child/young person, to the organisation’s named person for child protection.
- Ensure that the organisations named person for child protection understands his/her responsibility to refer any child protection concerns to the statutory child protection agencies (i.e. Police and/or Children’s Social Care).
- Ensure that any procedures relating to the conduct of workers/members are implemented in a consistent and equitable manner.
- Facilitate opportunities for children and young people to express their ideas and views on a wide range of issues in connection with the service they are provided with and to have access to the organisation’s Complaints Procedure.
- Facilitate involvement of parents or carers in the work of the organisation and to make child protection policies and procedures available to them.
This policy will be regularly monitored by the partners and will be subject to annual review.