Privacy Notice

Music Service Customers and Website Users

Swindon Music Service is committed to ensuring that your privacy is protected. Should we obtain your personal information, then you can be assured that it will only be used in accordance with this privacy notice and current data privacy legislation. If you have any questions about this notice, please contact us using the details in section 13 below .

Swindon Music Service may change this notice by updating this page. You should check this page from time to time to ensure that you are happy with the changes. If we update this notice in a way that significantly changes how we use your personal information, we will bring these changes to your attention where reasonably possible.

Please read this notice carefully as it provides information about the different types of personal information that we collect and how we will use it, including where it is collected via our website.

1. When we collect information about you
2. What information we collect
3. What we do with the information we collect
4. When we will get in touch and unsubscribing
5. How long we keep your personal information
6. How we use cookies
7. Lawful processing
8. Sharing your personal information
9. Security
10. Your rights
11. International data transfers
12. Links to other websites
13. Contact us

We may obtain personal information relating to you from a number of sources including:

• When you give it to us directly – for example, when you complete an application form or communicate with us (by email or on paper).
• When we obtain it indirectly – your personal information may have been shared with us by third parties. To the extent we have not done so already we will notify you when we receive personal information about you from them, and tell you how and why we intend to use it.
• When you visit our website – when you visit the website, we automatically collect some technical information, including IP address, the device and browser used to connect, and about your visit to the website including via cookies (see section 6 below).

If you are a Swindon Music Service customer, we may collect the following information:

• Name and contact information for pupil and parent/carer (as appropriate)
• Dietary, medical, SEN/D and demographic information
• Financial details relating to the bill payer and invoicing, including bursary and benefit details where relevant
• Musical progression details, including instrument and teacher, pupil reports, exam results
• Marketing permission, photo and media permissions, offsite and other course permissions, plus others where necessary (see newsletters, section 4 below)
• Any other information collected in accordance with section 1 above

If you are a visitor to the website, or sign up to our newsletter, we may collect the following information:

• Name and job title
• Contact information including email address
• Demographic information such as postcode, preferences and interests
• Other information relevant to customer surveys and/or offers

• Any other information collected in accordance with section 1 above

Special Categories of Data

We require your personal information to understand your needs and provide you with a better service, and for the following purposes:

• To provide you with the information or services you have requested, and communicate with you in general
• Internal record keeping and reporting to the Department for Education via Arts Council England
• To analyse, evaluate and improve our work and services
• To provide updates on and to promote our work and services (and to ensure we are not contacting people who have told us not to)
• To share information about musical activity in and around Swindon
• For internal record keeping and reporting and other administrative tasks such as keeping track of activities and ensuring feedback has been addressed
• To satisfy legal obligations which are binding on us
• To protect those involved in our services, including customers
• For research purposes
• For the prevention of fraud or misuse of services
• For the establishment, defence or enforcement of legal claims

Individuals can opt in to marketing newsletters from the Newsletters area of the website or by ticking the marketing consent box on any application form, and by supplying their name and email address. Other data may be collected as part of online competitions or surveys. Other communications with you may be administrative (for example in relation to the service we are providing to you).

You can unsubscribe from email newsletters at any time by clicking on the Unsubscribe link in an email or by emailing: pclark@smscio.co.uk

We will keep your personal information only for as long as required in connection with the purposes for which it was collected and/ or is used. As a general rule, unless still required in connection with those purposes, we remove your personal information from our records 7 years after the date on which our relationship with you ends.

However, in some circumstances we may keep your personal information for longer, for instance where we are required to do so in accordance with legal or regulatory requirements such as tax and accounting, or so that we have a record of your dealings with us in the event of any complaints or challenges.

If you would like further information about this, please contact us using the details at section 13 below.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

We are required to rely on one or more lawful grounds to collect and use your personal information. We consider the following grounds to be relevant:

• Legitimate Interests. Where the law allows us to use your personal information for our or a third party’s legitimate interests, and our use of your personal information is fair, balanced and does not unduly impact your rights.

We rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent. We will rely on the legitimate interest ground to communicate with you in most instances.

• Consent. Where we ask for your consent to the use of your personal information for a specific purpose. For example, when you sign up to a newsletter. You always have the right to withdraw your consent.
• Contract. Where it is necessary to use your personal information to fulfil a contract with you or take steps at your request prior to entering into one. For example, to provide a customer with our music services.
• Legal Obligation. Where the processing of your personal information is necessary for us to comply with a legal obligation.
• Vital Interests. Where the processing of your personal information is necessary to protect yours or another person’s vital interests.

The personal information we hold about you will be provided to our staff and volunteers who require it for our work. We may also disclose your personal information to selected third party processors (for example, the company which provides support for the website) for the purpose set out in this notice. The third party in question will be required to use any personal information they receive in accordance with our instructions.

Please note that we also share personal information with the Arts Council England for the purpose of reporting as a condition of funding we receive from them. Due to our funding arrangements, we are required to share this information with the Arts Council via Swindon Borough Council.

We reserve the right to disclose your personal information to third parties:

• in the event that we buy or sell any business or assets, in which case we may disclose your personal information to the proposed buyer or seller of such business or assets;
• if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
• with our professional advisors e.g. lawyers, where necessary to protect our interests;
• if we are under any legal or regulatory obligation to do so; and
• in connection with any legal proceedings or prospective legal proceedings, to establish, exercise or defend our legal rights.

We are committed to ensuring that your personal information is secure. In order to prevent unauthorised access or disclosure, we have put in place organisational and technical measures including suitable physical, electronic and managerial procedures to safeguard and secure the personal information we control.

Subject Access Requests

You may request details of the personal information which we hold about you. If you would like a copy of the personal information held on you please write to Swindon Music Service, The Platform, Faringdon Road, Swindon, SN1 5BJ or pclark@smscio.co.uk providing proof of identification.

Corrections

If you believe that any personal information we are holding on you is incorrect or incomplete, please write to or email us at the above address. We will promptly correct any information found to be incorrect.

Right to Object

You have the right to object to our processing of your personal information where we are (i) processing on the basis of legitimate interests (see section 7 above), (ii) using your personal information for direct marketing or (iii) using your personal information for statistical purposes.

Right to Data Portability

Where we are processing your personal information that you have provided directly to us, either (i) relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are a party, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a commonly used machine-readable format.

We do not currently undertake any automated decision making using your personal information.

Right to Restrict Processing

You can ask us to restrict the processing of your personal information (i.e. just to store it but do nothing more) if there is disagreement about its accuracy or legitimate use.

Right to be Forgotten

You may request that personal information relating to you be removed from our records. If you would like to request erasure from our records, please write to or email us at the above address, providing proof of identification. In some cases we will keep limited personal information to suppress further communications with you, rather than delete it entirely, so we can comply with your communication preferences. In some cases we will not be able to erase some or all of your details, for example if they need to be retained for legal reasons.

You also have the right to complain to the UK Information Commissioner’s Office. Information on how to do this is available at http://ico.org.uk/complaints.

As we sometimes use third parties to process personal information, it is possible that your personal information will be transferred to and stored in a location outside the UK of the European Economic Area (EEA).

Please note that certain countries outside of the UK or EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred, stored or otherwise processed outside the UK or EEA in a country which does not offer an equivalent standard of protection, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards to protect your personal information. For instance we may use cloud providers to store personal information who have servers in the US and are signed up to the Privacy Shield. If you have any questions about the transfer of your personal information, please contact us using the details at section 13 below.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we are not responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy notice. You should exercise caution and look at the privacy notice applicable to the website in question.

If you have any questions about how we use your personal information and how we comply with our responsibilities, please contact us as follows:

• Email: pclark@smscio.co.uk
• Call: 07799143828
• Write: The Platform, Faringdon Road, Swindon SN1 5BJ