The British Association of Teachers of Dancing

Privacy Policy

B.A.T.D. Privacy Policy

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our website, www.batd.co.uk, including any information you may provide through our site when you register as a new member, renewal of your BATD membership, purchase a product, sign up to our newsletter.

By providing us with your data, you warrant to us that you are over 16 years of age.

The British Association of Teachers of Dancing (BATD) is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

BATD

Email address: enquiries@batd.co.uk

Postal address:
Pavilion 8, Upper Level
Watermark Business Park
315 Govan Road
Glasgow
G51 2SE

Telephone number: 0141 427 3699

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at enquiries@batd.co.uk.

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

• Identity Data may include your first name, last name, username, and title.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Other Data may include date of membership payments, region, work area and BATD qualifications.
• Transaction Data may include details about your account and your payment history.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may include your username and password, purchases or orders, your school details & any other matter related to your membership with the BATD.
• Usage Data may include information about how you use our website, products and services.

Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms on our site (such as your membership registration or renewal) or by communicating with us by post, phone, email or otherwise, including when you:

• order our products or services;
• subscribe to our service (BATD membership) or publications;
• give us feedback.

• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy at www.batd.co.uk/cookies for further details.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

• Website analytics providers such as Google based outside the EU;

• Publicly available social media platforms such as Facebook, LinkedIn, Google+, Instagram, Twitter, based outside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as our accounting software based inside the EU. This data is not shared with anyone and is only used for conducting business with our existing clients, for example for the purposes of invoicing and receiving and/or sending payment.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• 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 ground for processing your personal data. You have the right to withdraw consent to receiving BATD membership updates via our email marketing platform at any time by emailing us at enquiries@batd.co.uk.

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us enquiries@batd.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing
To register you as a new member (a) Identity
(b) Contact		 Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and any charges relating to products or services provided by the BATD		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 (a) Performance of a contract with you
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 (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
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

Marketing communications

We never use a member’s information to contact them for ‘marketing purposes’. We only contact members with information that will benefit them, for example:

(i) Subscription Payment Reminders or
(ii) Changes / amendments to syllabi.
(iii) Information regarding Regional Meetings, Day of Dance, Festivals.
•   This email is only sent out to members in the relevant region.
(iv) Unforeseen Circumstances e.g Cancellation of an event.

We will get your express opt-in consent before we commence any email communication activity for the purposes as detailed above. By providing the B.A.T.D with an email address on your initial application form, you will be consenting to the association contacting you via this platform.

You can ask us to stop sending you email communication messages at any time by following the opt-out links on any of our email messages sent to you OR by emailing us at enquiries@batd.co.uk.  If you use the opt-out link you are only opting out of the mass e-mailer system, if you don’t wish us to have your e-mail address on file at all please contact Head Office directly via enquiries@batd.co.uk.

Where you opt out of receiving our email communications, this will not apply to personal data provided to us as a result of your continued membership of the BATD.

Change of purpose

We will only use your personal data for the purposes for which 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 you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at enquiries@batd.co.uk.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes of :

Specifically for teacher’s that own a dance school:

We may give out a teacher’s name, contact telephone number and / or email address to a person enquiring about a dance school in their local area. Again this information is given out solely to benefit the teacher as we would potentially be directing new business their way.

For teacher’s that do not want their contact information given out, we would ask that they specifically advise Head Office of this and in turn we can note this down in their record for future reference.

If a teacher is happy for us to give out specific pieces of contact information (for example they are happy for us to disclose their mobile number but not their home telephone number) we would again ask that they advise Head Office, specifically, which pieces of information can and cannot be given out. All Head Office staff have access to the notes on a BATD member’s record; this ensures continuity with the staff and how the information is handled.

Examiners:

Examiners are aware that their information will be passed onto a teacher that they are due to go and examine for – as above, if examiners wish only for specific pieces of contact information to be given out, this should be advised to Head Office and a note can be added to their record.

Third Parties

Service providers who provide IT and system administration services.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at enquiries@batd.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

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 such data. 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.

8. DATA RETENTION

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.

How do we store information?

We store information in both paper and digital formats. The paper copy protects the information held by the BATD from the potential risk of a technological failure with our computer system. The digital copy protects the information held by the BATD from physical damage e.g. Fire or water damage.

Application forms are kept on site for a maximum of 5 years and then the paperwork is transferred to Iron Mountain who then stores these files on our behalf.

• This includes the photographic ID of the candidate.
• In some circumstances, a medical letter may also be attached for a candidate.

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.

How long do we hold a record for and why?

The records we hold can be divided into 5 categories:

  • Current Members
  • Deceased
  • Last Paid
  • Correspondence Returned
  • Resigned

Current Members

We will hold the record for our currently paid up members as evidence that they hold a current and valid membership with the BATD.

Deceased

The information is simply moved to the ‘Deceased’ folder if one of our members passes away. Nothing further is done with their record.

Last Paid (within the last 10 years)

A BATD qualification remains valid for 10 years from the last time the individual pays their annual subscription. If a member chooses not to pay, for whatever reason, we hold their record which allows the member the opportunity to back pay / re-join the association, to keep their qualification valid with the BATD. We do not delete the record as it holds key information such as the qualification they hold, when they received their qualification, a breakdown of their account/payment history, and contact details – this eliminates duplicating information if we were to delete and recreate a record for every member that does not pay their membership each year.

Last Paid (Over 10 years)

A BATD qualification becomes null and void after a period of 10 years in which the member has not paid their annual subscription at any point. If a member, after a period of 10 years, wishes to re-join the BATD, they must do so by examination. We still hold records after the 10 year period as a point of reference for members who wish to re-join after such a time period. It allows us to clarify the exact time frame in which a member has not paid, which qualification(s) they held and when they received it and again, key contact information such as address and contact telephone numbers. We understand that over such a time frame, contact information may have changed, however at the point of re-joining through examination, this information can be updated on their record.

Correspondence Returned (Not currently paid up members)

This is records of people who we have sent information to via mail, and the post has been returned to us as the address is not correct and we have no other means of contacting them. Just like the above category, we hold onto this record as a point of reference for members who may contact us in the future, with the correct contact information and wish to pay their annual membership to become a current and valid BATD member.

Resigned

Members may choose to resign from the Association, however we will again hold onto these records as a point of reference if an individual contacts us wanting to re-join in the future
In some circumstances you can ask us to delete your data: see below for further information.

How do we ensure the data we hold is up to date?

Our records are based upon the information provided in an individual’s application form. If members call to pay their annual subscription over the phone, at this time we would ask if any contact details have changed. For those who do not contact the office directly to pay their annual subscription, there is an expectation that the member would contact Head Office to advise if and when any of their contact information was to change.

Incoming Mail – what data can be found in our mail?

When we receive mail into the office, the front page of each piece of post is scanned and stored in our computer system for 1 year. This allows us to track everything that is coming into the office and have a detailed record to refer back to if someone queries the date we received a certain piece of mail. After 1 year, the scanned copy is deleted.

Below we have listed the most common pieces of mail we receive into the office that contains member’s data. We have listed what we receive, what information is usually contained in the documents and why we would need this information.

Examination Results (Tests)

  • This would contain the teacher’s name and address, membership number, name of the dance school and the qualification that they hold.
    • We need this information to help ensure the invoice is sent to the correct member. We also take information such as the date of examination and name of the school to be printed on the pupil’s certificates.
  • This would also list the names of the children who sat each exam and their date of birth.
    • We need this information as a point of reference to help us identify which exams a particular child has sat in the past, in case it is ever queried by a teacher or parent.

Subscription Forms

It is optional for BATD members to post in a completed subscription form to Head Office (other payment options are available to them: they can pay online, bank transfer or phone the office and pay by credit / debit card). If they choose to, BATD members can post their subscription form into Head Office and either attach a cheque or the ‘Credit / Debit Card Payment’ form.

  • The Subscription Form contains the members: Name, address, DOB, home telephone number, mobile number, email address, membership number, the area in which they teach (if applicable) and the name of the school they teach at (if applicable).
    • Obtaining this information will allow us to check that our records matches the contact details that have been provided on the subscription form. Therefore, if there are any changes, our records can be updated to ensure all of the information we hold on our database is current and up to date.
  • The ‘Credit / Debit Card Payment’ Form contains: Amount to be paid, the payee’s name as it appears on the card, card type, validity date, expiry date, three digit security code, sixteen digit card number, name the payment is in respect of, the members address, telephone number and email address.
    • We require all of this information to allow us to process the subscription payment. We aim to process all payments within 7 days of receiving the card details, however during the busiest period of subscription payments (between January and March), payments may take longer to process.
    • Once a payment has been processed, the card details are automatically destroyed. We do not store Credit / Debit card details for any member.
    • Copies of student ID are also destroyed / deleted once the payment has been processed. We require this documentation in order to grant student members a reduced annual subscription rate.

Professional Application Forms

The information contained in a Professional Application Form is as follows: Title, Name, Date of Birth, Address, Telephone (Daytime / Evening), Occupation, Email Address, Level and Branch of Examination wishing to be sat, Member of any other Associations, Name of Teacher & Address, Place of Examination (Address), 2 Character References – Name & Address and the Candidate’s Signature. Candidates are also expected to send in a copy of photographic ID alongside their application form.

Examples of Photographic ID that we accept include: Passport or Driving Licence.

We require this piece of documentation in order to confirm the identity of the candidate sitting the exam. The photographic ID is then destroyed after the examination has taken place.

Due Diligence Check

We would receive a document from Due Diligence Checking which would be a breakdown of a criminal record check for a BATD member. At the BATD we recommend that teachers have a PVG / criminal record check done every two years.

The document we receive from DDC contains: Members name, address, whether or not the candidate has any criminal convictions (if they do, the convictions are not specified) and their disclosure identity number. We advise our members that we have received this document and if they wish we can supply a certificate as evidence for them to hold on record (there is a fee for this to be done, however this is advised in the letter we send to our members advising we have received their Due Diligence Check).

The document we receive from Due Diligence Checking is stored in the office for a two year period and destroyed thereafter. If a member was to contact us after a two year period, requesting a certificate as evidence we would advise that they would need to go through the process of having a new Due Diligence Check done.

Examiners – We receive a number of documents specifically from examiners that will contain personal data, however this information is necessary to ensure that our payments to examiners are processed correctly, as well as having evidence of a clear and current PVG. From examiners we will receive:

Claim Forms – this will detail an examiners earnings from a specific examination session.

PAYE Form – this will have the examiners Tax Reference Code on it.

PVG Document – this will have their name, address, PVG personal ID number and will disclose information from the criminal conviction record check.

Medical Letter – we receive medical letters for candidates sitting both professional and amateur exams. We require such a letter as evidence for any candidate that may have a physical or mental disability that may affect their ability when being examined.

Professional Exams – The medical letter is sent along with the application form to the examiner to ensure they are aware of the candidate’s circumstances. When the application form and result is posted back into the office by the examiner, the medical letter is destroyed.

Amateur Exams – A copy of the medical letter is sent to the examiner, to again advise them of the candidate’s circumstances. The CDMT requires the BATD to hold the original copy on site.

Scholarships

The information held by the B.A.T.D. regarding Scholarship Events does not directly impact any of our B.A.T.D. members, however it may concern their pupils thus the requirement for us to disclose the information we hold. The parent / guardian of the nominated candidate will grant permission for the B.A.T.D. to hold the candidates information by signing the waiver form provided to them. For any parent / guardian that has concerns about how their child’s information is processed or stored, they can contact Head Office directly at enquiries@batd.co.uk or speak to the candidate’s teacher, who in turn can contact a member of Head Office staff.

We receive the following documentation for Scholarship events:

Acceptance Form

Includes: Child’s Name / Dance School / DOB

We need this information to help us identify the correct pupil, and we need their DOB to ensure the pupil is eligible to compete in the Scholarship event (as there are age restrictions).

Waiver Form

Includes: Name / Address / Dance School / Parents Signature / Relationship to child

Again helps us to identify the correct pupil and which parent has granted permission for their child to take part. We need this document as a formal contract to protect the BATD from claims or damages.

This is signed by the parents and permits their child to participate in all BATD programmes / activities including photographs, written articles, public performances, live streaming videos and filming, or any such activity in which their child may appear for promotional, educational or instructional purposes.

The waiver form also releases the BATD from all claims and damages that may arise from a child participating in the event.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at enquiries@batd.co.uk
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Request for information – what do we provide?

If a BATD member was to contact Head Office and request a copy of the information we hold for them, initially we would provide:

  • A copy of their record – this would simply be a copy of the information they provided on their application.
  • A copy of their account history – this is a breakdown of their payment history (membership subscription payments only, not invoices). It details the date paid, the amount paid and a copy of the receipt number (this shows us the method of payment whether it was by cheque, cash, card payment, online payment or bank transfer).
  • A copy of their qualifications – this would detail the branch of dance they hold their qualification in, the level of qualification (associate, membership or fellowship), their membership number and the date their qualification was awarded.

Initially, for anyone requesting information, we would provide our members with the information that they initially provided to Head Office on their application form. The three points above are pieces of information held for EVERY BATD member, therefore, stating this is the information we would provide at a ‘request for information’ would allow us to be transparent with all of our members regarding the information we would supply.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.batd.co.uk/cookies.