Data Protection Policy

Stalybridge Music Academy needs to keep certain information on its employees, volunteers, music lesson service users and trustees to carry out its day to day operations, to meet its objectives and to comply with legal obligations. The organisation is committed to ensuring that any personal data will be dealt with in line with the Data Protection Act 1998. To comply with the law, personal information will be collected and used fairly, stored safely and not disclosed to any other person unlawfully.  The aim of this policy is to ensure that everyone handling personal data is fully aware of the requirements and acts in accordance with data protection procedures. This document also highlights key data protection procedures within the organisation. This policy covers (insert types of people as appropriate – employed staff, trustees, volunteers) In line with the Data Protection Act 1998 principles, (Music Academy) will ensure that personal data will:

• Be obtained fairly and lawfully and shall not be processed unless certain conditions are met

• Be obtained for a specific and lawful purpose

• Be adequate, relevant but not excessive

• Be accurate and kept up to date

• Not be held longer than necessary

• Be processed in accordance with the rights of data subjects

• Be subject to appropriate security measures

• Not to be transferred outside the European Economic Area (EEA)


The definition of ‘Processing’ is:

“obtaining, using, holding, amending, disclosing, destroying and deleting personal data. This includes some paper based personal data as well as that kept on computer.”


The Personal Data Guardianship Code suggests five key principles of good data governance on which best practice is based. The organisation will seek to abide by this code in relation to all the personal data it processes, i.e. 

• Accountability: those handling personal data follow publicised data principles to help gain public trust and safeguard personal data. 

• Visibility: Data subjects should have access to the information about themselves that an organisation holds. This includes the right to have incorrect personal data corrected and to know who has had access to this data. 

• Consent: The collection and use of personal data must be fair and lawful and in accordance with the DPA’s eight data protection principles. Personal data should only be used for the purposes agreed by the data subject. If personal data is to be shared with a third party or used for another purpose, the data subject’s consent should be explicitly obtained.

• Access: Everyone should have the right to know the roles and groups of people within an organisation who have access to their personal data and who has used this data. 

• Stewardship: Those collecting personal data have a duty of care to protect this data throughout the data life span.


Music Academy processes the following personal information: 

  • Name

  • Date of Birth

  • Address

  • Contact Telephone Number

  • Email Address

  • Next of Kin

  • Relevant Medical Conditions 

  • Bank Details


Personal information is kept in the following forms: 

  • Personnel File

  • Online Reference Files


Groups of people within the organisation who will process personal information are: 

  • IT Personnel

  • Directors

  • Administration

  • HR and Accounts Departments


Under the Data Protection Guardianship Code, overall responsibility for personal data rests with the governing body, this is Music Academy.


The governing body delegates tasks to the Data Controller. The Data Controller is responsible for:

  • Understanding and communicating obligations under the Act

  • Identifying potential problem areas or risks

  • Producing clear and effective procedures

  • Notifying and annually renewing notification to the Information Commissioner, plus notifying of any relevant interim changes


All who process personal information must ensure they not only understand but also act in line with this policy and the data protection principles. 


Breach of this policy will result in an investigatory procedure being implemented which may result in suspension and a formal Disciplinary Hearing.


To meet our responsibilities will:

• Ensure any personal data is collected in a fair and lawful way;

• Explain why it is needed at the start;

• Ensure that only the minimum amount of information needed is collected and used;

• Ensure the information used is up to date and accurate;

• Review the length of time information is held;

• Ensure it is kept safely;

• Ensure the rights people have in relation to their personal data can be exercised 


We will ensure that:

  • Everyone managing and handling personal information is trained to do so. 

  • Anyone wanting to make enquiries about handling personal information, whether a member of staff, volunteer or service user, knows what to do; 

  • Any disclosure of personal data will be in line with our procedures.

  • Queries about handling personal information will be dealt with swiftly and politely.


Training and raising awareness about the Data Protection Act and how it is followed in this organisation will take the following forms: 

  • On induction: 

  • General training/ raising awareness


Before personal information is collected, we will consider: 

  • Required Information

  • Personal Choices

  • Communication Choices


We will inform people whose information is gathered about the following: 

  • Data Storage

  • Data Access


We will take the following measures to ensure that personal information kept is accurate: 

  • Routine Checks of Data

  • Change of Circumstances/ Details Documentation


Personal sensitive information will not be used apart from the exact purpose for which permission was given. The organisation will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure. The following measures will be taken: 

  • Password Protection

  • Restricted Access

  • Data History Monitoring


Any unauthorised disclosure of personal data to a third party by a employee, contractor, volunteer, director, administrator, receptionist, ancillary staff or trustee may result in Disciplinary Procedure being activated. 


Anyone whose personal information we process has the right to know:

  • What information we hold and process on them

  • How to gain access to this information

  • How to keep it up to date

  • What we are doing to comply with the Act.


They also have the right to prevent processing of their personal data in some circumstances and the right to correct, rectify, block or erase information regarded as wrong.

Individuals have a right under the Act to access certain personal data being kept about them on computer and certain files.  Any person wishing to exercise this right should apply in writing to the Technical Director

  • We may make a charge of £10 on each occasion access is requested. 


The following information will be required before access is granted: 

  • Proof of identity x 2, one photographic or official and the second residential. 


Queries about handling personal information will be dealt with swiftly and politely.

We will aim to comply with requests for access to personal information as soon as possible, but will ensure it is provided within the 40 days required by the Act from receiving the written request and relevant fee. This policy will be reviewed yearly to ensure it remains up to date and compliant with the law.