iD Talent collects and uses personal information about staff, clients, parents and other individuals who we work with. This information is gathered to enable iD Talent to provide talent agency services and other associated functions. In addition, there may be a legal requirement to collect and use information to ensure that the agency complies with its statutory obligations. We do not share this data with any third-party companies, except at the request of the Police, Local Authority, or Health Care professional. It is collected purely for the safety of our staff/clients.
Please note: Under new laws we are not able to demand contact details, however if minors (under 16 years) would like to attend any of our events/workshops and we are not given an emergency contact, a parent/carer will have to stay on the premises for the duration of the class for safety reasons. Also, this means we will not be able to send details of upcoming events/workshops.
This policy is intended to ensure that personal information is dealt with correctly and securely and in accordance with the GDPR 2018, and other related legislation. It will apply to information regardless of the way it is collected, used, recorded, stored and destroyed, and irrespective of whether it is held in paper files or electronically.
All staff involved with the collection, processing and disclosure of personal data will be aware of their duties and responsibilities by adhering to these guidelines.
What is Personal Information?
Personal information or data is defined as data which relates to a living individual who can be identified from that data, or other information held.
GDPR 2018 Principles
1. Lawfulness, fairness and transparency
Transparency: Tell the subject what data processing will be done. Fair: What is processed must match up with how it has been described. Lawful: Processing must meet the tests described in GDPR [article 5, clause 1(a)].
2. Purpose limitations
Personal data can only be obtained for “specified, explicit and legitimate purposes”[article 5, clause 1(b)]. Data can only be used for a specific processing purpose that the subject has been made aware of and no other, without further consent.
3. Data minimisation
Data collected on a subject should be “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed” [article 5, clause 1(c)]. In other words, no more than the minimum amount of data should be kept for specific processing.
Data must be “accurate and where necessary kept up to date” [article 5, clause 1(d)]. Baselining ensures good protection and protection against identity theft. Data holders should build rectification processes into data management / archiving activities for subject data.
5. Storage limitations
Regulator expects personal data is “kept in a form which permits identification of data subjects for no longer than necessary” [article 5, clause 1(e)]. In summary, data no longer required should be removed.
6. Integrity and confidentiality
Requires processors to handle data “in a manner [ensuring] appropriate security of the personal data including protection against unlawful processing or accidental loss, destruction or damage” [article 5, clause 1(f)].
The agency is committed to maintaining the above principles at all times. Therefore the agency will:
Inform individuals why the information is being collected when it is collected
Inform individuals when their information is shared, and why and with whom it was shared
Check the quality and the accuracy of the information it holds
Ensure that information is not retained for longer than is necessary
Ensure that when obsolete information is destroyed that it is done so appropriately and securely
Ensure that clear and robust safeguards are in place to protect personal information from loss, theft and unauthorised disclosure, irrespective of the format in which it is recorded
Share information with others only when it is legally appropriate to do so
Set out procedures to ensure compliance with the duty to respond to requests for access to personal information, known as Subject Access Requests
Ensure our staff are aware of and understand our policies and procedures
Complaints will be dealt with in accordance with the agency’s complaints policy.
This policy will be reviewed as it is deemed appropriate, but no less frequently than every 2 years. The policy review will be undertaken by the Managing Director or nominated representative.
If you have any enquires in relation to this policy, please contact Kimberly Davis who will also act as the contact point for any subject access requests.
Further advice and information is available from the agency, www.idtalentuk.com or telephone 020 3771 5680
Procedures for responding to subject access requests made under the GDPR 2018
We will request your consent to access of your information via email or contact form. Please update your settings and select how you would like to receive information about agency updates and workshop offerings (either Email or Telephone Call/Text).
The procedure in place to detect a personal data breach will be a thorough investigation following a report of an issue.
Right to delete information
At any point you can contact us to delete your information. If a minor is still attending classes/workshops other measures will need to be taken in order to ensure the safety of the participant. Please see opening statement.
Rights of access to information
There are two distinct rights of access to information held by schools about pupils.
1. Under the GDPR 2018 any individual has the right to make a request to access or delete the personal information held about them.
2. The right of those entitled to have access to our records are staff only. No data will be shared with third-parties except the Police, Local Authority, or Health Care professional.
These procedures relate to subject access requests made under the GDPR 2018.
Action of a subject access request
1. Requests for information must be made in writing; which includes email, and be addressed to (Kimberly Davis or allocated maternity cover staff). If the initial request does not clearly identify the information required, then further enquiries will be made.
2. The identity of the requestor must be established before the disclosure of any information, and checks should also be carried out regarding proof of relationship to the child. Evidence of identity can be established by requesting production of:
utility bills with the current address
Birth / Marriage certificate
Credit Card or Mortgage statement
This list is not exhaustive.
3. Any individual has the right of access to information held about them. However with children, this is dependent upon their capacity to understand (normally age 12 or above) and the nature of the request. The Director or Development Manager should discuss the request with the child and take their views into account when making a decision. A child with competency to understand can refuse to consent to the request for their records. Where the child is not deemed to be competent an individual with parental responsibility or guardian shall make the decision on behalf of the child.
4. The response time for subject access requests, once officially received, is 40 days (not working or school days but calendar days, irrespective of school holiday periods).
5. Third party information is that which has been provided by another, such as the Police, Local Authority, Health Care professional or another school. Before disclosing third party information consent should normally be obtained. There is still a need to adhere to the 40 day statutory timescale.
6. Any information which may cause serious harm to the physical or mental health or emotional condition of the student or another should not be disclosed, nor should information that would reveal that the child is at risk of abuse, or information relating to court proceedings.
7. If there are concerns over the disclosure of information then additional advice should be sought.
8. Where redaction (information blacked out/removed) has taken place then a full copy of the information provided should be retained in order to establish, if a complaint is made, what was redacted and why.
9. Information disclosed should be clear, thus any codes or technical terms will need to be clarified and explained. If information contained within the disclosure is difficult to read or illegible, then it should be retyped.
10. Information can be provided in person with a member of staff on hand to help and explain matters if requested or provided at face to face handover. The views of the applicant should be taken into account when considering the method of delivery. If postal systems have to be used, then registered/recorded mail must be used.
Complaints about the above procedures should be made to the Chairperson of the Governing Body who will decide whether it is appropriate for the complaint to be dealt with in accordance with the agency’s complaint procedure.
Complaints which are not appropriate to be dealt with through the agency’s complaint procedure can be dealt with by the local authority. Contact details of both will be provided with the disclosure information.
If you have any queries or concerns regarding these policies / procedures then please contact Kimberly Davis – Managing Director.