Data Protection Policy
Trinity Laban Conservatoire of Music and Dance is committed to protecting the rights and freedoms of individuals in accordance with the provisions of the Data Protection Act (DPA) 1998 and the General Data Protection Regulation (GDPR) which became part of UK law on 25th May 2018.
The Data Protection Policy sets out requirements to which Conservatoire staff and student who process personal data must adhere, and explains the main purposes for which The Conservatoire processes the personal data of staff, students and persons who are neither staff nor students. The content is reviewed annually by the Data Protection Officer in consultation with relevant parties.
Data Subject Rights
Your rights under the General Data Protection Regulations (GDPR) (Last updated on 17th May 2018)
- Right of Access
- Subject Access Requests
- Data Portability
- Right to erasure
- Right to restrict processing
The General Data Protection Regulations give individuals (data subjects) the right to access their personal data in order to assure themselves that their data is being used lawfully and is not inaccurate.
Data subjects have the right to obtain:
- Confirmation that their data is being processed
- Access to their personal data
- Other supplementary information as described in Trinity Laban’s Privacy Statements
This information will be provided free of charge and within one month of Trinity Laban receiving a Subject Access Request (SAR) from an individual. If the request for information is manifestly unfounded or repetitive, Trinity Laban may decline to provide the information or to levy a fee for the provision of the information. The fee will be calculated by determining the administrative cost of providing the information. Where requests are complex or numerous Trinity Laban will reserve the right to extend the period of compliance by a further two months, and Trinity Laban will explain to the requestor why the extension is necessary.
How to submit a Subject Access Request
Trinity Laban is required to verify the identity of a person making a Subject Access Request (SAR) and has devised a short form in support of a SAR. The form can be found below. In order for Trinity Laban to locate your data it will be helpful if you can provide as much information as possible about the nature of your request.
If you believe the personal data held is inaccurate or incomplete you have the right to rectification. Please advise the Trinity Laban where you believe your personal data is inaccurate or incomplete.
The GDPR gives data subjects the right to data portability. The GDPR provides for individuals who wish to transfer their personal data from one IT environment to another. If you wish to exercise this right please contact the Trinity Laban in order to discuss your needs. Data will normally be provided in a CSV file and if you require your personal data to be transmitted to another service provider you will need to provide the appropriate technical data structure of the receiving organisation.
Right to Erasure
The right to be forgotten was established to enable a data subject to request the deletion or removal of personal data where there is no reason for it to be retained. However, the right to erasure does not provide an absolute right to be forgotten.
The circumstances under which individuals have a right to erasure include:
- Where personal data is no longer necessary for the purposes for which it was originally supplied
- Where the individual withdraws consent, consent having been the legal basis on which the personal data was provided
- Where individuals object to their data being processed and there is no overriding legitimate reason to continue processing
- Where personal data was processed unlawfully
- Where personal data has to be erased in order to comply with a legal requirement
- Trinity Laban will decline a request for erasure if it believes any of the following would be compromised:
- The right to freedom of expression and/or information
- The requirement to comply with a legal obligation for the performance of a public interest task or the exercise of official authority
- The archiving of data in the public interest or for statistical purposes
- The defence or exercise of a legal claim
Trinity Laban is required to restrict processing of personal data in the following circumstances:
- In cases where the data subject contests the accuracy of personal data, processing will be restricted whilst the veracity of the data is verified
- In cases where the data subject objects to the processing which was necessary for the performance of a public interest task or for other legitimate tasks, processing will be restricted whilst Trinity Laban considers whether its legitimate grounds override those of the individuals
- Where processing is unlawful and the data subject has requested restriction instead of erasure
- The data subject requests the data in pursuance of a legal claim but the TRINITY LABAN no longer requires the data
Trinity Laban will notify the data subject when a restriction on data processing has been lifted.