Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
Who are we?
Instrumentally Limited is the data controller. This means it decides how your personal data is processed and for what purposes.
How do we process your personal data?
Instrumentally Limited complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes:
• To enable us to provide music tuition services;
• To book music lessons and issue reminders;
• To maintain our own accounts and records (including the processing of payments);
• For examination entries;
• To inform you of news, events, and activities and changes in our service provision
What is the legal basis for processing your personal data?
• Explicit consent of the data subject so that we can keep you informed about news events and activities and services;
• Processing is necessary for carrying out our obligations for the provision of our services;
• Processing is necessary for proper record keeping in order to fulfil statutory requirements;
Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared within Instrumentally Limited in order to provide our service and meet statutory requirements.We will only share your data with third parties with your consent.
How long do we keep your personal data?
We keep data for a maximum of six years in order to comply with statutory requirements and otherwise for as long as it is necessary in order to provide our services.
Your personal data may be transferred to countries other than where you live, such as, for example, to servers in the U.S.
Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR. These include:
Privacy Shield. We transfer, in accordance with Article 45 of the GDPR, personal information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (each individually and jointly, the “Privacy Shield”), including Squarespace, Inc.
Standard data protection clauses. We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.
Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.
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 your personal data Instrumentally Limited holds about you;
• The right to request that tInstrumentally Limited holds corrects 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 for tInstrumentally Limited holds to retain such data;
• The right to withdraw your consent to the processing at any time
• 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 lodge a complaint with the Information Commissioners Office.