Version – 05/18
1.2 We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data either when you visit our website (regardless of where you visit it from) and/or where we provide our services to you. This privacy notice tells you about your privacy rights and how the law protects you.
1.3 Please use the Glossary below to understand the meaning of some of the terms used in this privacy notice.
2. Purpose of this privacy notice
2.1 This privacy notice aims to give you information on how we collect and process your personal data.
2.2 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Tom O. Mitchell, trading as DrumWise is situated at The Studio, 5 Church Road, Otham, Kent ME15 8SQ. Tom O. Mitchell is the controller and responsible for your personal data (we will be referred to as “DrumWise”, “we”, “us” or “our” in this privacy notice).
4.1 If you have any queries about this privacy notice or how we process your personal data, you can contact us by email: firstname.lastname@example.org.
4.2 To request access to the personal data that we hold about you, you may contact us by email: email@example.com.
4.3 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. You can find out more about your rights under data protection legislation from the Information Commissioner’s Office website available at: www.ico.org.uk.
5. Changes to the Privacy notice and your duty to inform us of changes
5.1 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.
6. Third-party links
Our 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.
7. The data we collect about you
7.1 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).
7.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together 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 billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you.
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 this website.
Profile Data includes your username and password
Usage Data Details of your pervious qualifications, employment and educational history
Residence Data Information about your nationality and residency, and previous address if applicable
Health Data Information about medical, welfare or health conditions, including whether or not you have a learning disability or difficulty.
Equal Opportunity Data Information about your race and ethnicity
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
7.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
7.4 We collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religion, information about your health). We may also collect any information about criminal convictions and offences. We do so with your specific consent in order to provide our educational services or comply with a legal obligation.
8. How is your personal data collected?
8.1 We use different methods to collect data from and about you including through:
8.1.1 Direct interactions. You may give us your Identity, Contact, Financial, Residence, Health and Ethnicity Data by filling in forms such as our application form or enrolment forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
use this website;
when you fill out our forms or contact us in respect of our lessons, open days or wish to receive information or worksheets; or
create an account on our website (via Acuity) or subscribe to email marketing communications such as online newsletters.
We will collect this information predominantly via our websites forms, however we may contact you for clarification or further information if it is needed in order to provide you access to the services requested.
8.2 Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Technical Data from the following parties:
8.2.1 analytics providers such as Google based inside the EU; and
8.2.2 search information providers and credit providers based inside the EU.
8.2.3 From other organisations. Some information such as previous qualifications, or special needs, may be collected from other organisations such as the DfE, Local Education Authority or your previous school.
9. How we use your personal data
9.1 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:
9.1.1 Where we need to perform our educational services.
9.1.2 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. Our legitimate interests are in providing our educational services to you and in promoting or furthering our educational services.
9.1.3 Where we need to comply with a legal or regulatory obligation.
10. Purposes for which we will use your personal data
• account set up and administration | Legitimate Interest
•delivering marketing and events communication | Consent
•carrying out polls and surveys | Consent
•internal research and development purposes | Consent
•providing goods and services| Legitimate Interest
•legal obligations (eg prevention of fraud)| Consent
•meeting internal audit requirements| Consent
We are keen to communicate our activities, latest news and points of excellence with staff, students and supporters. We do this by providing information through a range of online and offline channels including publications, events, press releases, social media and email.
In order to do this we have a database that contains personal data collected by DrumWise during the course of our relationship with our staff, students and interested parties.
You will receive marketing communications from us if prior to 25 May 2018 you requested information from us or after 25 May agreed to such communications and, in each case, you have not opted out of receiving that marketing.
13. Opting Out
You can ask us 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 firstname.lastname@example.org.
We value our relationship with you and we use your personal data to personalise our communications, improve our services and ensure we work efficiently and effectively.
Unless you have requested otherwise, your data is accessible by such members of staff of DrumWise who need to know to provide the services for which you have consented.
Our marketing communications include the following (by mail, email, sms and telephone):
Sending DrumWise newsletters;
Promoting our services;
Notifying you of upcoming events;
Tools may be used to help us improve the effectiveness of our communications with you, including tracking whether the emails we send are opened and which links are clicked within a message.
Lastly, we use data to undertake analysis projects to ensure only effective and relevant communications are sent to you. A list of suppliers can be provided on request.
13. Change of Purpose
13.1 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.
13.2 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.
13.3 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.
14. Disclosures of Your Personal Data
14.1 We may have to share your personal data with the parties set out below for the purposes set out in paragraph 11 above.
14.1.1 Internal Third Parties as set out in the Glossary.
14.1.2 External Third Parties as set out in the Glossary.
14.1.3 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
14.2 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.
15. Data Security
15.1 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.
15.2 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.
16. Data Retention
16.1 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.
16.2 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.
16.3 Subject to any other notices that we may provide to you, we may retain your personal data for a period of six years after your association with us has come to an end. However, some information may be retained indefinitely by us in order to maintain your academic record for archiving purposes (or for the purposes of supporting your lifelong relationship with DrumWise).
16.4 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
16.5 In some circumstances you can ask us to delete your data (see below).
16.6 In some circumstances we may 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.
17. Your Legal Rights
17.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below after the Glossary please contact us.
17.2 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 may refuse to comply with your request in these circumstances.
17.3 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.
17.4 Time limit to respond
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.
18. Lawful Basis
Legitimate Interest means 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). 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.
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
19. Third Parties
Internal Third Parties
19.1 Other companies in the DrumWise group acting as joint controllers or processors.
External Third Parties
19.2 Service providers acting as processors based inside and outside the EEA who provide IT and system administration services.
19.3 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
19.4 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
19.5 Quality Assurance Agency for Higher Education acting as processor or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances or to whom it is necessary to provide information as part of our services.
YOUR LEGAL RIGHTS
19.6 You have the right to:
19.6.1 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.
19.6.2 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.
19.6.3 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.
19.6.4 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.
19.6.5 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
19.6.6 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.
If you would like more details about how we use and store your personal data, please contact us.