We process personal information supplied by our clients and to those interested in our services. We are committed to complying with our legal obligations in respect of data protection and privacy. This statement sets out the principles we apply when processing personal data. This statement describes the types of personal data we may collect about you. This statement also describes what we do with any data we collect about you, how we will keep it secure and the legal bases on which we rely for processing your data. This statement also informs you of your rights and how you can contact us.
1 About Us
Hull Piano School is operated by Hofnote Educational Ltd. We provide Music Education and resources based in our office in Spring Bank, Hull HU3 1AG. Lester Hough is the Data Controller for the purposes of current data protection legislation and can be contacted at the above address, or by messaging Lester Hough on 07577478998 and asking for a callback.
2 What personal data do we collect from you?
Personal data is information relating to an identifiable individual. We collect data that we need to provide our services to you as follows:
. 2.1 From telephone enquiries, we may collect contact information, your name and general details of the prospective client such as age, previous accomplishments and available times for tuition.
. 2.2 From clients who engage us to teach the piano, we retain information to be able to contact them, including names, email address, telephone number and approximate ages or dates of birth as appropriate.
. 2.3 We keep details of your payments.
. 2.4 For clients who authorise us, we use a cloud-based system for electronic practice log books.
3 Where do we collect the data from?
Personal data is collected from you
. 3.1 from initial contact or from further interactions. You will always know you are giving us information.
. 3.2 For clients using electronic practice logbooks, we keep comments which you add onto the logbook. This is an interactive system to make notes for lessons and draw your attention to third-party resources such as performances on Youtube.
. 3.3 Payment information is collected either through the cash receipt booklet or through the bank reference if paid through the bank by Standing Order or BACS payments. (This includes payment made by smartphone)
4 What is our lawful basis for processing your data?
We only process personal data where we have a lawful basis for doing so. We may collect and process data when:
. 4.1 it is necessary for the performance of our contracts with you;
. 4.2 it is necessary for the purposes of our legitimate interests as a business. In these cases, we will do so in a way which might reasonably be expected from our relationship with you, and which does not impact materially on your fundamental rights, freedom and interests. We will not process your personal data on this basis if we believe your rights override ours. Instead, we may seek your specific consent, and/or another legal basis;
. 4.3 it is necessary for compliance with legal obligations;
. 4.4 we have your consent to do so, for example in relation to marketing by electronic means.
Please see below for more detailed information about how we will use your data and on what basis. If you have any concerns about our data processing please contact us: see Contact. Please also see Your rights, below.
5 How will we use your personal data?
We will use your data in the following ways
. 5.1 to perform the contract we have with you to provide piano tuition, or to respond to any enquiries you make in this connection before we enter into a contract. The lawful basis for this processing is performance of a contract.
. 5.1.1.The contract is based on acceptance of our conditions and provides ongoing lessons for a set monthly fee. You agree the terms of the contract when you arrange to start learning with us. The contract may be with you for yourself or for a dependent.
. 5.1.2 A contract is also formed when you agree to be entered into an exam or competition following discussion with you. We use your data to prepare such entries.
. 5.2 For those who chose to use an electronic practice logbook, we will use this medium to advise you of other services and facilities which will enhance your learning. You agree to this when you select to use this type of logbook. This is included in your contract to give you the best possible tuition and not for marketing purposes even if it may occasionally bring your attention to a subscriber service such as additional practice resources or music download sites. There is no financial or contractual link with anything we draw your attention to. The only objective is to optimise your learning.
. 5.3 to reply to enquiries, complaints or suggestions. We need the information you supply to enable us to respond. The lawful basis for this processing is performance of a contract with you or because you have asked us to take specific steps before entering into a contract in respect of these activities and services;
. 5.4 to send you communications required by law or which are necessary to inform you about changes to the services we provide you, for example, updates to this Privacy Statement and any information legally required which relates to any contracts between us. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. This processing is necessary for us to comply with our legal obligations.
. 5.6 to protect our business financially and to protect our business from fraud or illegal activity. This processing is necessary for our legitimate interests by ensuring the proper management of our business and financial risks.
. 5.7 at the request of a client, we will communicate with other professionals such as schools to confirm client appointments in school time and student achievements.
. 5.8 We will not email you with marketing materials.
6 Who do we share your data with?
We may also share your data with third parties.
If this is necessary, we will provide only the information they need to perform the services we require. They will only use the data for the purposes we specify. We require third parties to maintain appropriate security to protect information from unauthorised access or processing. In some circumstances, we may need to share your personal data with other third parties (including legal or other advisers, regulatory authorities, courts and government agencies) to enable us to enforce our legal rights, or where such disclosure may be permitted or required by law. Unless we tell you otherwise, your data will not be processed outside the EEA. In particular we share your data with;
. 6.1 cloud–based back-up to support the efficient running of our business.
. 6.2 Auditors and accountants (currently Newsham and Co)
. 6.3 Cloud-based accounting software ( Xero https://www.xero.com/uk/about/terms/privacy/)
. 6.4 Examining Boards including
. 6.4.1 ABRSM https://us.abrsm.org/en/policies/website-privacy-policy/)
. 6.4.2 Trinity College London (https://www.trinitycollege.com/site/?id=3673)
. 6.5 Festival organisers (including Cottingham Methodist Church Music Festival, Hornsea Music Festival)
. 6.6 Cloud-based notebooks (including Evernote (https://evernote.com/privacy) OneDrive (Microsoft application https://privacy.microsoft.com/en-us/privacystatement)
. 6.7 On the specific request of individual clients, we will share data with other professionals such as schools to ensure students are excused school for exams and competition.
7 How long will we keep your data?
We will only keep personal data for as long as is necessary to provide our services, or for as long as we reasonably need to keep the information for the lawful business purposes or to comply with a statutory or other legal requirements.
8 Data Security
We will take appropriate technical [and organisational] measures to protect the personal data we transmit, store or otherwise process against accidental or unlawful destruction, loss, alteration or unauthorised disclosure or access. Our computers and mobile devices are password protected.
9 Your rights
You may exercise your rights by contacting us using the details in Contact, below. We aim to handle any requests within a reasonable period and, in any event, within one calendar month of the original request.
. 9.1 Right to information and access – You have the right to be informed about what personal data we collect about you, why, on what lawful basis and what your rights are. This Privacy Statement is the key document we use to inform you about this. You also have a right to request access to the information that we hold about you, and to receive a copy of this information, along with other information which is generally contained in this Privacy Statement.
. 9.2 Right to rectification – You have the right to request that inaccurate personal data be rectified, or completed if it is incomplete.
. 9.3 Right to erasure and restriction – You have the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances. When responding to such requests, we will tell you how such restrictions or deletions may affect our ability to fulfil our contracts with you or otherwise affect your interests.
. 9.4 Right to object – You have the right to object to our using your information for direct marketing. You can also ask us to stop using your information, where we are processing it on the basis of our legitimate interest. We will do so unless we believe we have a legitimate overriding justification to continue processing your personal data.
. 9.5 Right to withdraw consent. If you have given us any specific consent to use your personal data, you have the right to withdraw it at any time. If you wish to tell us that you are withdrawing your consent, please email us at email@example.com
If you are unhappy with the way we process your personal data, please contact us using the information provided below. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO): Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; Tel: 0303 123 1113 or 01625 545 745 https://ico.org.uk/global/contact-us/
In the first instance please contact Lester Hough during the course of normal communication or by text to 07577478998 or email to firstname.lastname@example.org
We may change this privacy statement from time to time. We will post updates to this privacy statement on our website, and where appropriate, we may notify you by text or email. Please check our website to stay up to date
Last edited May 2018