A NOTE TO PARENTS/GUARDIANS
Where you are a parent or guardian and you are signing up to this policy on behalf of a Stagebox Member Child, we ask that you take the time to explain how their personal data will be used in a manner that you consider appropriate given your Child’s age and abilities. Though legally in the U.K. children from the age of 13 can give valid consent to the processing of their personal data, we ask that parents or guardians sign this policy on behalf of all children up to the age of 18 years.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
Full name of legal entity: STAGEBOX MUSICAL THEATRE WORKSHOP (NORTH) LIMITED
Company number: 09421415
Email address: firstname.lastname@example.org
Postal (and registered company) address: 167 Southborough Lane, Bickley, Bromley, Kent, England, BR2 8AP
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes home address, email address and telephone numbers.
- Diary Data – details of your availability or other timetable information relating to when you have time free or availability to perform generally.
- Guardian Data includes name and contact details of a relevant parent, legal guardian or other similar persons to be used as emergency contacts (delivery address, email address and telephone number).
- Bursary Data includes information submitted by you directly as part of a bursary form that we may make available to you from time to time. This form will include information relating to your personal, living and financial status including any financial support you may be in receipt of. This information can vary depending upon your circumstances, but it will be clear to you what information you provide when completing the form.
- Billing Data includes your name or other identifiers, payment reference and the existence of payments received and other limited data provided to us by PayPal that we use just to check if you are up to date with payments or not.
- Agent Data includes agent’s name and contact number.
- School Data includes school name, address, headteacher’s details (name).
- Qualifications Data includes training and experience data and details of professional credits and similar or related experience (where applicable).
- Production Company Data – Special Category Data: this can include birth certificate, school letter, medical enquiry form, food allergies/food preference sheet and other health and fitness-related information such as measurements including height, weight and other genetic identifiers such as, but not limited to, eye and hair colour.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Usage Data includes information about how you use our website and our other products and services.
SPECIAL CATEGORIES OF PERSONAL DATA (PRODUCTION COMPANY DATA)
We do collect Special Categories of Personal Data about you and this kind of data generally includes and covers 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 won’t collect the above data about you where we can avoid it and we would prefer that you limit the amount of Special Category data that you provide to us.
The Special Categories of personal data that we may collect (or that you might tell us about for a good reason) as part of the services we provide are as follows:
- Ethnic origin (not always required);
- Religion (not always required);
- Height, weight and other physical measurements;
- Medical/ Health data (including details of food allergies and any other relevant medical data, whether physical or mental); and
- Any of the above information that you provide in support of, or relating to, the Bursary Data you may provide to us from time to time.
This data is required in order to understand your needs and provide you and relevant Production Companies with a better service and to protect your safety. We would ask that you consider how much information we need, and you should not disclose any of this sort of information unless you are comfortable in doing so. Please contact us if you have any concerns at all about why we need or how we use this kind of data.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. If you refuse to provide any data that may be requested by a Production Company, you understand that this might mean that you or your child, where applicable, may not be cast for a particular role. In that case, we may not be able to continue working with you, but we will let you know at the time if this is the case.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us any of the above data categories by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
- register for or take part in a Stagebox audition workshop, or one of our training programmes;
- register an interest or sign up on our website;
- make a bursary application;
- subscribe to our publications;
- request marketing or other information about our services be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. See the Glossary below in Section 10 of this Policy, we will receive personal data about you from various third parties.
- Production Company Data and School Data from your education establishment where you instruct your School or other education providers to provide information to Stagebox directly.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have given your express consent.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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 obligation, such as the duty to act in “loco-parentis” where that is appropriate.
- Where we have to act to protect your or any other Stagebox Member’s vital interests in a situation where you are unable to give consent such as a potential medical emergency or other similar situation.
Generally, we do not rely on consent as a legal basis for processing your personal data (except for the Production Company Data) although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent or otherwise opt-out of marketing at any time by contacting us.
We will ask for you to give your consent so that we can make your special categories of personal data (Production Company Data) available to other third parties.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that 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 contact us 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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We don’t use any cookies, we have other methods of being able to record when you have signed up on our website and we only process that data as set out in this policy.
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. CLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- Production Companies who sign up to the Stagebox service. These are businesses who Stagebox have an agreement with to cast for general or specific roles and performances.
- Third parties who you reference in your Bursary Data in order to verify the information you have provided.
- External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where we disclose any of your personal data to a Production Company, we ensure that we have a written contract in place with that Production Company which protects your personal data to the extent legally required under UK law.
When we share any of your personal data with Production Companies, we always try to limit the amount of personal data that we share to the minimum required to achieve the purpose of assisting with casting for that specific Production Company. Where a Production Company requires any personal data which might be considered to be a Special Category of personal data, we provide this by request only because this data is considered to be of higher risk than other personal data and we don’t think it is required to provide this at the outset to Production Companies on every occasion.
We will normally endeavour to inform you when and what information we have disclosed or are disclosing to a Particular Production Company, but you can ask us to confirm this at any time by contacting us.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside of the United Kingdom without your prior express written consent and we ask that our Production Company customers keep your personal data in the UK too unless they tell you otherwise.
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. 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
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements. We may delete any of your data that we reasonably consider is either no longer accurate or no longer necessary, without notice to you at any time. You should inform us as soon as possible if your position changes or if your personal data becomes or is likely to become inaccurate or outdated for any reason.
By law, we have to keep basic information about our customers (including Contact and Identity, Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- 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.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
NO FEE USUALLY REQUIRED
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 could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Consent must be specific, clear and unambiguous. We ask for your general consent to provide the information you provide to us on to third party Production Companies when requested. You can withdraw your consent for this purpose at any time, but that would prevent us from being able to provide our services. This will usually be presented to you in the form of an unticked checkbox, but it might be a button where were have made it clear that it involves consent to proceed.
Legitimate Interest means, in most cases, the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Legitimate Interests can also include those of society in general or the environment. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
EXTERNAL THIRD PARTIES
- Production Companies who you request or require Stagebox to communicate with.
- Children’s casting and similar agency services upon specific request by you in advance where you request that we provide information to those third parties.
- Providers of secure payment services: PayPal (Europe) S.à r.l. et Cie, S.C.A. is duly licenced as a Luxembourg credit institution in the sense of Article 2 of the law of 5 April 1993 on the financial sector as amended and is under the prudential supervision of the Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier, with registered office in L-1150 Luxembourg.
- Third parties who you cite as references as part of a Bursary application, in your Bursary Data, or as we otherwise require to contact in order to verify parts of your Bursary Application for the strict purpose of considering your Bursary.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.