“The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.”about
Because Wise Moves holds a substantial amount of information concerning artists who we work with and recommend for workshops in schools – some of which is sensitive – there is no doubt that we are subject to GDPR.
However, the amount of personal information that we hold concerning school staff is extremely limited and we suspect we would probably not need to register under the legislation that came into force on the 25th May 2018, were it not for the fact that we hold this information about artists.
Nevertheless in the interests of transparency we are providing the information required by the regulation in so far as it applies to members of staff in schools that we hold information about – and this includes information relating to either email addresses directed to individual named members of staff followed by the school address as well as other personal email addrart from email addresses, the only information we hold is the forename and surname of the member of staff, in some cases a mobile phone number and/or job description where that has been provided and details of any quotations requested by that individual and/or bookings subsequently made.
We use the information we store about individuals in order to notify them, by email, of the availability of workshops and upcoming dates relating to those workshops such as religious festivals and enrichment/arts weeks. We also provide information about the artists available to deliver the workshops, the fees charged by artists and by Wise Moves, special offers and details including dates of previous workshops for which we have provided quotes/bookings.
All the personal information we hold is held securely and details can be provided on demand at any time. We do our best to ensure that such information remains accurate but do rely quite heavily on members of staff notifying us of any changes.
There are a number of lawful bases for holding this information but the one which is most appropriate is “Legitimate Interest”. However, individuals where we hold their email address and use them for such purposes are, and always have been, entitled to ask us to unsubscribe them from this service with immediate effect at any time – as can schools where we email to the front office. It would, however, be reasonable for us to point out that in doing so individuals asking to be unsubscribed should always make clear the email address(es) which they are requesting to be unsubscribed as otherwise we will always unsubscribe only the email address they send their request from. We will also on receiving an unsubscribe request, delete any personal information held relating to that individual.
We have never and will never sell any data – personal or otherwise – to any third party. Currently Wise Moves has no sister companies (companies under the same direction and control) but may have in future. If that is the case and there is a legitimate common interest but not necessarily the same service or activity being proposed, in order to comply with GDPR, before doing so, we will notify the individuals in respect to whom we hold personal information and request permission to share their personal details as above identified.