Privacy Policy

HCM Music College Privacy Policy May 2018

Definitions

Data controller​ – A controller determines the purposes and means of processing personal data.

Data processor​ – A processor is responsible for processing personal data on behalf of a controller

Data subject​ – Natural person

Personal data​ – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies. Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing ​- means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party​ – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

1. DATA PROTECTION

We comply with the principles of the Data Protection Act 1998 & the General Data Protection Regulations (GDPR) in the way we collect and use consumer information. Synergy Music Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. We have obtained your personal data directly from information supplied by filling in the online Enquiry forms or by corresponding with us by phone, email, post, or otherwise.

2. OUR SERVICES

We will only use your personal information to administer your account to provide the products and services you have requested from us. To give advice and information on services that you have requested from us.To maintain our own accounts and records.

3. DATA PROTECTION REGISTER

Data is only used for the purposes described in our entry on the Data Protection Register.

4. REQUIRED PERIOD

We only hold personal data for as long as is reasonably necessary, or in line with terms stated by the relevant examination boards we use, or our funding partner college. Once data is no longer needed it is deleted from our files

5. DATA STORAGE

All data is secured electronically, remotely, and securely.

6. OUR PROMISE

We never sell, rent or exchange personal information.

7. DATA SHARED WITH PARTNERS

Your personal data will be treated as strictly confidential. We won’t share your details with any third party other than relevant examination boards or colleges partners who in turn satisfy our requirements for data protection and storage within their own privacy policy. We do not transfer personal data outside the EEA​.

8. YOUR RIGHTS AND YOUR PERSONAL DATA

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

9. EMAIL OPTIONS

If you ​subscribe directly to any email service we may provide you will be asked whether or not you wish to receive such emails.

10. SPAM

In accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003, we never send bulk unsolicited emails, (popularly known as Spam) to email addresses.

11. EMAIL CONTENT

All emails sent by us will be clearly marked as originating from us and will contain relevant information to the service you have asked us to provide to you, such as lessons.

12. COOKIES

Our website uses “cookies” . Please note that these cookies do not contain or pass any personal, confidential or financial information or any other information that could be used to identify individual visitors or customers from our website. Please note that you are free to refuse cookies.

13. CONTACT US

If you have any questions relating to our Privacy Policy please email us at learn@h-c-m.co.uk