EDA Wien Privacy Policy (updated: July 2020)
The English Dance Academy, Wien (also described in this policy as “EDA, Wien” or “EDA”) is committed to protecting any personal information you share with us.
We operate in accordance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), which replaces the Data Protection Directive 95/46/EC and came into effect on 25thMay 2018.
Your Rights:
It is the right of anyone required to submit personal data to EDA, Wien to understand what personal information we collect and why, how we use and store that information and how we dispose of that information should you leave the school, no longer use our services or should any of your details change.
We aim to operate fairly and with complete transparency meaning you can contact the Principal at any time to confirm what personal data we hold and to ask us to remove any information you do not wish for us to have. If you ask for your data to be removed, we will keep the minimum amount of information to ensure we adhere to your request. Please note however that we may have a lawful reason to hold or use the personal data in question, which does not require consent.
The majority of our communications will be via email. Your email address will never be displayed within a group email. In some circumstances it will be possible to change the way we contact you, however, please note this may result in important information being missed or delayed.
It is your right to choose what communications you wish to receive from us, i.e. only information as relevant to you as an individual or company. You can opt in or out of communication for marketing purposes (such as advertising of holiday workshops) at any time.
To view, update or remove any information please email englishdancewien@gmail.com. Requests for full details held by us will require proof of identity. Additional requests may incur an administration charge.
What personal information will we collect and why?
We will not collect any information other than what is lawfully relevant to registration as an EDA pupil or for participation in any EDA Wien related event (to include but not limited to: classes, rehearsals, exam sessions, performances, auditions, dance parties, workshops) with the child’s safety being of paramount importance.
Information required for enrolment and participation of classes:
- Child’s Full Name (so the child can be easily identified in class. This will appear on the class register so the child’s attendance can be recorded for safety reasons and to ensure correct invoicing of classes. (For Child Protection and Safeguarding reasons we will not be able to proceed with the enrolment of a child where the responsible parent does not consent to their child’s full-name appearing on the register.)
- Date of Birth (to ensure children are placed in the correct class and eligible for certain exams, events, competitions, workshops, auditions etc. where an age limit applies)
- Contact Name of Parent/Guardian (so we know the legally responsible adult who should be contacted in regard to the child’s participation in classes and events, for contacting in an emergency situation and who to issue the invoice for classes and additional events, such as exams and shows)
- At times we may require your address (sometimes it may be necessary to send letters and other information via post, such as exam certificates, uniform orders etc.) or if you have invited EDA to hold a party or private lesson at your home
- Telephone Number (in order to contact the responsible parent/guardian in relation to child’s participation in EDA classes and events and for emergency and medical situations that may arise in class – for instance if the child becomes unwell and we need to contact you to collect them from class early. For safety reasons this number will appear on the class register so the responsible parent/guardian can be contacted as soon as possible. (For Child Protection and Safeguarding reasons we will not be able to proceed with the enrolment of a child where the responsible parent does not consent to this number appearing on the register. For safety reasons parent contacts may be stored in the school mobile phone. This phone is accessible by the Principal only and password protected.)
- Additional Emergency Contact Name/s and Telephone Number/s (For the safety of the enrolled child, atleast one additional contact person should be appointed in the case of an emergency and we are unable to contact the main contact)
- Medical Information (to ensure the child is kept safe and healthy within class and so that relevant information can be shared with paramedics or medical professionals should an emergency situation arise. It is the parent/guardian’s responsibility to keep EDA informed and up to date with all relevant medical information, including injuries and both physical and psychological conditions. (For Child Protection and Safeguarding reasons we will not be able to proceed with the enrolment of a child where the responsible parent does not consent to medical information appearing on the register.)
If you are a company or person hiring us (for example for a school club or wedding dance choreography) we will only collect information relevant to the purpose of our business with you. The information we collect will depend on the service you require.
Who will we share your information with?
The school will ensure your personal details will always be treated in strict confidence and will not be passed on or sold to any other organisation or third party (including other members of the school) without your consent or without a legitimate reason as is lawful and relevant to your child’s enrolment (see below).
On occasion it may be necessary to disclose student information to a 3rdparty, for example for exams and events:
- Exams: EDA Wien is required to submit entering pupil’s names and date of births to the NATD
- Performance: Where licenses or license exemptions are required for a performance EDA Wien must submit pupil names, date of births, home address and the school attended to local councils in order to comply with Child Work Enforcement and Child Protection and Safeguarding regulations (Currently UK only)
- For Commonroom classes it is necessary to share some personal information with approved Commonroom team members only:
- Names of Pupils – As we are working closely with the team at commonroom and many children stay before or after lessons to play or take part in other events there and because the commonroom team members may assist in taking a child from the studio to their parent (ie if they need the toilet or want Mummy) we feel it is important that they also know the children’s names. Knowing the children’s names would also assist in helping to calm children and evacuate the building in case of an emergency or to help us deal with a child appropriately in the case of a medical emergency or injury.
- Contact Details – In case of last minute class cancellations or a need to contact you in an emergency situation during class, commonroom may also have access to the telephone number and email address provided on your enrolment form. Commonroom will never contact you for direct marketing via contact details we have shared with them without first gaining your consent. All communications made through these details are for lawful and relevant reasons related to you or your child’s enrolment as an EDA pupil only.
- Teachers – Teachers have access to the following information for the purpose of attendance registers, to ensure they are planning and organising work for the correct age and ability and in order to be able to contact parents in case of an emergency:
- Names of Pupils
- Date of Birth
- Name and Contact Telephone of Parent and additional emergency contact
- Medical Information (as relevant to the pupil’s safety or would be necessary to inform paramedics)
The personal data shared with commonroom and our teachers is always transferred through encrypted methods (ie using Google Drive) and all information is viewed and stored on approved EDA, Wien and commonroom devices, which are encrypted and/or password protected, and accessible by approved team members only.
COVID-19 UPDATED USE OF INFORMATION:
Please be advised that during the ongoing coronavirus pandemic we have a legal obligation to record the attendance of any pupils and parents (staying within the venue) during our sessions.
It is understood that during this time it may be necessary for us to share contact information with the relevant authorities and governing officials for the purpose of track and tracing. We will never share information unnecessarily and only where it is lawful and in the interest of public safety to do so.
- For Invoicing and Accounting:
We currently use Zervant Software for our invoicing system. This requires us to store your customer names and email address within our web-based account.
Zervant is a European company and as such is compliant with the GDPR guidelines. We will regularly review this and at any time should the use of this service become non-compliant or we feel they are not doing enough to protect your data we will immediately change to a new invoicing and accounting system.
All information stored in Zervant is password protected and/or encrypted and accessible by the Principal only.
Our website domain (www.edawien.com) is provided by WordPress and hosted by Bluehost who also adhere to the GDPR guidelines. All information posted on and collected through our website (such as our online contact form) are protected by SSL encryption and are password protected. Our website has been tested by Cookiebot and is fully compliant with GDPR. Our cookie policy can be viewed by visiting the website.
Our email provider is Gmail (englishdancewien@gmail.com), a part of Google which strictly follows the GDPR.
All collected information is used and stored purely for what is relevant to your request or enrolment. All information is processed inline with the GDPR guidelines and deleted in the appropriate manner and time limit as relevant to the individual.
Social Media:
We rely heavily on our Facebook page (English Dance Academy, Wien) for promotion of our classes and events.
Our page is public and you do not have to be a member of Facebook to view it. By visiting our Facebook page or choosing to Like or Follow our page you are consenting to viewing the information that we post.
If you do not wish for our posts to appear on your news feed we recommend you visit Facebook settings and ensure that you only see the posts you want to see.
We will never tag or fully disclose a name or personal information about any child or parent within a post, photo or video and we will remove anything you are not happy with.
We will never share anything directly with you or invite you personally to an event in any manner that would be seen as direct marketing and for which we do not have prior consent.
Whilst we do not personally collect information about you through our Facebook page or record anything that you may comment on our page without permission, we can not control the information that may be collected by Facebook through its cookies settings and recommend you read their Privacy and Cookies policies to ensure you are comfortable with the information they may collect during your visit to us – such as IP address, geographical location etc.
From time to time we may post videos or links on our Facebook page that we feel are relevant to us as a dance school – such as a performance or song. Should you decide to follow that link you understand that EDA can not be held responsible for any personal information that may be collected via the site you are then taken to through cookies (for example, YouTube).
Please always bare in mind that any comment you make can be seen by anyone else that Follows or Likes our page and that they are able to reply to you.
We will never send our customers a private message via Facebook Messenger unless you have contacted us first through this method and are happy for us to contact you in this way. We will only ever contact you in regard to what is directly relevant to your enrolment or participation in our classes or events. You have the right to ask us to stop contacting you in this manner at any time.
Should you leave the school or your enquiry does not lead to enrolment we will not contact you further unless we have a legitimate reason to do so or you contact us. General chats will be kept so we have the relevant information incase of a future enquiry but you may delete or ask us to delete any chat you would like us to. Personal information collected through these chats will never be retained longer than necessary and all such information will continue to be handled in accordance with the GDPR and our privacy policy.
Photos and Video:
All photos and videos published on social media or the EDA website will be handled in accordance with our photographic policy. This means we will never post media without permission and furthermore we will never name a child or provide any personal details without obtaining parental consent. We will remove or edit any media containing images of your child that you ask us to.
All social media sites and website providers are also required to strictly adhere to the GDPR guidelines and as such, all personal information stored, collected or processed there will be handled with the upmost security and accessible to necessary persons only.
All photos are stored by us on encrypted and password protected approved devices and accessible to the Principal only. We retain images for our own archives and memories only and may continue to use images taken during your enrolment after you have left the school. It is your right to ask us to remove or delete images where you or your child can be depicted at any time. We will endeavour to comply with this as far as is lawfully and legitimately possible.
In some cases it may be impossible to guarantee deletion of all images – for instance where you have given consent for your child to appear on a flyer and those flyers have been handed out to the public. Although we will always ask for consent before using such images and no child will ever be named we would ask you to carefully consider all circumstances before giving or withholding consent.
Accurate Information:
Our aim is to keep all information up to date and as accurate as possible and we therefore kindly ask your assistance in this matter by ensuring you always inform the Principal of any changes to important details such as names, contact details (telephone number, emergency contact, address, email address), medical conditions/injuries and any other information that could be relevant to the admin team and teachers (for example, a bereavement or school related incident that could affect the child physically or emotionally in class and requires extra care by the teacher).
How will your information be stored securely?
All electronic information is retained on EDA approved devices (and for Commonroom classes – Commonroom approved devices) only and password protected and/or encrypted.
We use Google Drive to store (and share) certain information on the above mentioned devices and for the creation and storage of electronic enrolment/information forms.
All information stored or collected through Google Drive (for example Google Sheets, Google Forms, Google Notes) is handled in the strictest of confidence by the Principal (and for commonroom classes – approved Commonroom team members, as detailed above) only. Google Drive is also fully GDPR compliant and therefore all data is held and transferred in accordance with the new regulations.
Any paper enrolment forms are handled with the upmost security and locked away where they can be accessed by the EDA Principal only.
Paper class registers contain the first name of the child only in order to check attendance and ensure all children are easily accounted for should an emergency situation occur.
All other relevant information that may be required during classes, ie for registration and attendance, is stored and shared securely on an approved EDA device which is password protected and encrypted and accessible only to the Principal and approved team members, ie teachers.
For example, for the safety of the children we retain an emergency contact telephone number and relevant medical information during classes. This information will be handled by the EDA Principal and, where necessary, appropriate EDA team members (ie teachers during classes or for Commonroom classes – approved Commonroom team members) only.
Medical information will only ever be shared in the case of an emergency, ie to inform the attending paramedics of a relevant injury or allergy. It is your job to inform us immediately and in full of any new medical conditions/injuries and any changes to pre-existing conditions. This includes physical and psychological conditions.
What happens to your information if you leave EDA Wien?
When a pupil leaves the school all personal information (paper and electronic) is retained for 1 year in case of return.
After this time all personal information is deleted and/or destroyed, except where fees remain outstanding or parents have asked to remain on the mailing list.
Names are retained on past registers for 6 years (for the purposes of our tax returns) and invoices remain in the system. These are accessible by the Principal only and an auditor/accountant where required. All such information continues to be held in accordance with the GDPR.
Parental Permission and Independent Pupils:
Following GDPR regulations as pertain to Austria, parental permission is required in all cases for enrolling (and enrolled) pupils under the age of 14. EDA, Wien may continue to require parental knowledge and consent in some situations until the pupil is 16 years of age or older (for example, where a parent is still responsible for paying fees).
Pupils between the ages of 13 and 16 will only be invoiced or contacted directly with parental consent. Pupils below the age of 13 can not be contacted or invoiced personally regardless of consent.
Personal contact details (ie mobile phone numbers and email addresses) of pupils will not be accepted as the sole form of communication of EDA information until the pupil reaches 16 years of age. At this point it will be the pupil and parent/s’ decision whether the parent should also continue to be contacted and/or invoiced. Where the pupil is to take over full responsibility of their enrolment a new Independent Enrolment Form will need to be completed. The data on that form will be handled in the manner as dictated above. All irrelevant parental information will be deleted/destroyed in accordance with the GDPR guidelines.
Responsibilities of the Principal and Teachers at EDA Wien:
It is the aim of the school that all appropriate team members are properly trained, fully informed of their responsibilities under the GDPR and are aware of their personal liabilities and all policies related to the processing of customer data.
This Notice:
We will update this notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
Contact:
If you have any questions or concerns related to privacy, please do not hesitate to contact the Principal, Mrs Katy Atzberger at englishdancewien@gmail.com