The Royal Academy of Music Junior department respects your privacy and is committed to protecting your personal data. This privacy notice sets out how the Royal Academy of Music Junior department processes the personal data of students who are currently enrolled on a programme of study under the umbrella of Junior Academy; the First String Experience, First Guitar Experience, Primary Academy, Junior Jazz and Junior Academy. This privacy notice should be read in conjunction with the privacy notice for enquirers and applicants and any other privacy or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you understand how and why we are using your data. We want to be as transparent as possible in the way in which we use your information so that you can be confident in providing the information to us and be clear on why we need certain information.

Contact Details

Royal Academy of Music
Marylebone Road
London
NW1 5HT
Data protection registration number: Z4819206
Data Protection Officer: dpo@ram.ac.uk

Changes to the Privacy Notice and your duty to inform us of changes

This privacy notice may be varied from time to time, where necessary and possible we will notify you of any changes.

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 child’s duration of their course.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that child, young person or adult can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, record and transfer different kinds of personal data about you which we have grouped together as follows:

Includes your dates of enrolment, your teacher reports, any prizes that you were awarded and any other information relevant to your progress. Note that we are within our rights to refuse to delete this and to keep it indefinitely.

Includes first name, maiden name, married name, last name or similar identifier, marital status, title.

Includes the uploaded passport photo for the purpose of validating your identity submitted as part of the audition process.

Includes both parent/guardian’s home address, email address and telephone numbers and the student’s school contact details and the student’s email address.

Includes family and social circumstances, bursary information, education and biographical information, competitions and prizes. Details of any procedures that you have engaged with during the duration of your course such as complaints, appeals and disciplinary processes.

Includes bank account and/or payment card details and details of any transactions with the Academy, such as fee payments.

Includes CCTV footage captured in and around Academy premises, any commissioned or captured photographs and video footage with your consent for the purposes of marketing, publicity and assessment and any audio recordings made in the main halls.

We also collect and use Special Category personal data of students including racial or ethnic origin, Special Education Needs data (including mental health data) and medical information. When collecting the data we will be completely transparent about the purpose for its collection and link it back to this privacy notice.

In cases where we need to collect personal data by law, or in order to provide educational services to you and you fail to provide that data when requested, we may not be able to provide access to those educational services. In this case and if we are aware of it, we will contact you with a view to resolving the issue and continuing our course offer to you.

How is your personal data collected?

We use different methods to collect data from and about you:

  • Personal data and sensitive personal data/special category data is obtained directly from you, usually during the enrolment process by the Junior Academy administration team.
  • From time to time we may also collect data from a third party organisation involved in the services provided by the Academy that has obtained the information in the first instance.
  • Image data may be collected at any time during your enrolment at the Academy.

How we use your personal data

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:

  • 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.
  • Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

When we collect and use special category data as part of the audition and enrolment process this information is stored on your student record.

Purposes for which we will use your personal data

We have set out below a description of the main ways we plan to use your personal data, and which legal basis/bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

1. Audition application

Type of data:

  • Identity
  • Contact
  • Contextual

Lawful basis for processing:

  • Legitimate interest

Further information and retention period:

  • Successful applicants’ audition forms and feedback will be added to their Student Record. Unsuccessful applicants’ audition forms and feedback will be kept for 2 years in case of appeals.

2. Student enrolment including the creating and ongoing maintenance of your student record.

Type of data:

  • Identity
  • Contact

Lawful basis for processing:

  • Legitimate interest

Further information and retention period:

  • Student Records will be maintained until the students’ end of study on a Junior Academy programme and their contact information will automatically be transferred to our Alumni Database

3. To process and deliver educational services directly relating to your studentship including:

  • Timetabling
  • Assessment and monitoring of progress
  • Managing fee payments
  • Bursary administration
  • Scholarship information
  • Photo/video consent information

Type of data:

  • Identity
  • Contact
  • Financial

Lawful basis for processing:

  • Legitimate interest

Further information and retention period:

  • Duration of studentship

4. Security

Type of data:

  • Image/CCTV footage

Lawful basis for processing:

  • Public task

Further information and retention period:

  • 30 days unless retained as part of an internal investigation or legal process

5. To capture your image in video footage or photographs for the purpose of promoting the Academy.

Type of data:

  • Identity (video/photographic image)

Lawful basis for processing:

  • Consent

Further information and retention period:

  • Video footage and/or photographs may be held in perpetuity as part of the Academy’s historic archive

6. To maintain an archive of your student record

Type of data:

  • Basic studentship

Lawful basis for processing:

  • Legitimate interest

Further information and retention period:

  • Retained in perpetuity

Purposes for which we will share your personal data outside of the Academy

1. Sending photographs to external organisations for PR/marketing purposes or to third party organisations (e.g. production imagery).

Type of data:

  • Identity (video/photographic image)

Lawful basis for processing:

  • Legitimate interest

Further information and retention period:

  • The period of the processing activity (sharing of data)

2. To maintain your electronic student record via our student records system (Maestro).

Lawful basis for processing:

  • Legitimate interest

Further information and retention period:

  • Retained in perpetuity.

3. Maintaining relationships with donors/funding organisations/trusts and foundations who may be supporting your studies.

Type of data:

  • Identity
  • Contact
  • Contextual

Lawful basis for processing:

  • Legitimate interest

Further information and retention period:

  • This applies to successful bursary applicants where reports on students’ progress are required to continue funding. Reports will be kept for a period of 2 years

Safeguarding, pastoral care and student welfare

Under safeguarding, pastoral care and student welfare, Junior Academy and all courses under its umbrella will keep a record of:

  • Any safeguarding issues, risks or events that arise attached to each relevant student.
  • Any diagnosed Special Educational needs and/or disabilities to inform any additional support or different learning approaches needed.
  • Notes on pastoral care provided by the management and teaching staff attached to each relevant student.
  • Details of any personal circumstances which has an impact on your learning.
  • Identity data required for a Body of Persons Approval (BOPA) application when applying to a Local Authority for permission to hold external concerts.

This information will be managed by the Director of Junior Academy and will be shared with the administration staff and individual students’ teachers should it be deemed necessary. It will be kept on file for 10 years from the incident noted.

Change of purpose

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 obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

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.

Disclosures of your personal data

The Royal Academy of Music employs the services of 3rd party photographers or videographers to shoot or record events. Please note that these individuals/organisations may hold the right to retain the images taken. Details on the organisations who may hold your images are available upon request.

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.

Data security

We have 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 and other third parties who have a business need to know. They will only process your personal data on our instruction and they are subject to a duty of confidentiality.

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.

We benchmark the adequacy of our data systems and the supplier that are in place and where applicable data privacy impacts assessments have been conducted.

Data retention – how long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Please refer to the information in the table above for information on retention periods.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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.

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 for further information in relation to your request to speed up our response.

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.

Glossary

Legal Basis

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 may 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.

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.

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

  • Service provides acting as processors based in the EU who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Action you can take

If you wish to exercise any of the rights set out below, please contact us.

You have the right to:

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.

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.

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.

Object to processing of your personal data where we are relying in 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 your 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.

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.

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 as part of your enrolment process.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us to raise any concerns in the first instance.