Date of issue: 16 May 2018
At PQA we take your privacy seriously and we are committed to respecting and protecting your privacy. This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we'll store and handle that data, and keep it safe.
It's likely that we'll need to update this Privacy Notice from time to time. We'll notify you of any significant changes, but you're welcome to come back and check it whenever you wish.
PQA LTD is the data controller of your personal information (collectively referred to as "PQA", "we", "us" or "our" in this Privacy Notice) and is made up of a number of different businesses including The Pauline Quirke Academy, Quirky Kidz, PQA Studios, Q Productions, Q Management, Quirky Youth Theatre and PQA Venues.
Registered in England and Wales with company number 06203984 of The Retreat, 406 Roding Lane South, Woodford Green, Essex, England, IG8 8EY
If you require further information about the way(s) PQA manages your personal data, you can contact our Data Protection Officer directly on firstname.lastname@example.org
What personal data we need and how we collect it
Personal data, or personal information, means any information about an individual that can identify them. It does not include data where the identity has been removed (anonymous data). We collect the minimum amount of personal information needed to complete a contract that we have with you.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes your first name, maiden name, last name, title, date of birth, credit/debit card information,
• Contact Data includes your postal address, email address and telephone numbers.
Where we need to collect personal information about you by law, or to fulfil our obligations to you and you fail to provide that information when requested, we may not be able to perform the contract we have or services we are trying to provide to you. In this case, we may have to stop providing you with the services, but we will notify you if this is the case at the time. For example, where you do not consent for your child to be recorded by PQA, we will contact you and discuss whether we can continue providing the services under the contract.
We collect your personal information by direct interactions with you. Mainly you will give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone and email.
How we use your personal data
The processing of your personal data is necessary for us to provide a service that you have requested under a contract we have with you. We rely on that contract as a legal basis on which we process your personal data. Under that contract we will provide your personal data to your local PQA Academy so that it can provide you with the services you have requested.
PQA processes personal data for certain legitimate business purposes which include, some or all, of the following:
• where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customer;
• to identify and prevent fraud;
• to enhance the security of our networks and information systems;
• to administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering
• to better understand how people, interact with our web sites, and
• to provide communication which we think will be of benefit and interest to you.
Otherwise, we rely on consent as the legal basis on which we process your personal information. We will seek your consent from time to time to continue to process your data by contacting you.
We only use your personal information to administer your account and to provide you information on the products and services you have requested from us. From time to time we will also invite you to participate in surveys which help us to improve what we do. We will never sell, distribute or lease your personal information to third parties.
Where and how we store your personal data
When you provide PQA with personal data, we will hold your information on our electronic database on servers physically located within the UK or the European Economic Area (the "EEA").
We will use appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss destruction or damage of your personal information. Your personal information is stored electronically on a database file which is password-protected and stored offline, behind up-to-date firewall and antivirus protection.
Access to personal information is limited to Principals and employees of PQA. These individuals have access to the personal information on the database to enable them to perform their contractual duties. We provide all Principals and employees of PQA with Data Protection Legislation training.
We have put in place procedures to deal with any suspected personal information breach. In the unlikely event that your personal information was accessible to third parties through a data breach, we would inform you as soon as we become aware of it and any applicable regulator where we are legally required to do so.
How long we will retain your personal data
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information we consider
- the amount, nature, sensitivity of the personal information,
- the potential risk of harm from unauthorised use or disclosure of your personal information;
- the purposes for which we process your personal information,
- whether we can achieve those purposes through other means,
- and the applicable legal requirements.
Your personal data stored on our database will be reviewed every six months and where appropriate we will delete your personal data.
If you complete our enquiry form, we will pass your personal data to the Principal of your chosen Academy to allow them to provide materials about PQA and to contact you to learn if you wish further information.
If you have contacted us and have requested that we keep your personal data on file for the purposes of receiving information from us, for example, about new academies opening, we will ensure that we confirm with you each time we contact you, that you are happy for your personal data to be stored by us for contact only. If you choose not to proceed with registering with us, we will remove all your stored data after 6 months.
Access to information
Data Protection Legislation gives you right to access the information we hold about you. Your right of access can be exercised in accordance with Data Protection Legislation. We will respond to any valid access request within 30 days (though if it is expected to take longer than 30 days, we will notify you and keep you updated on likely timescale) and we will make available your information in a format to be agreed. To obtain a copy of the personal information we hold about you please contact us in the manner set out at the end of this Privacy Notice.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights contained in this Privacy Notice). 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. In these instances, we will notify you.
Erasure or rectification of information
Data Protection Legislation gives you the right to ask us to erase information held about you if it is no longer necessary in relation to the purposes for which it was collected or processed. You also have the right to ask us to rectify inaccurate information we hold about you or to complete incomplete information about you.
Your right of erasure and/or rectification can be exercised in accordance with Data Protection Legislation. If you make a valid erasure or rectification request, we will take reasonable steps to erase or rectify your information so far as required by Data Protection Legislation. However, Data Protection Legislation allows us to retain and continue processing your information in certain circumstances and if any of those circumstances apply we may continue to hold and process your information (in accordance with this Privacy Notice) despite your request for us to erase it. Such circumstances include (but may not be limited to) where our continued holding and/or processing or your information is necessary:
• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation that requires processing of personal data by EU or member state law to which the controller is subject, or for the performance of a task carried out in the public interest, or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health;
• for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes in so far as the erasure of the information would be likely to render impossible or seriously impair the achievement of the objectives of the archiving purposes in the public interest, or the scientific and historical research purposes or the statistical purposes, and
• for the establishment, exercise or defence of legal claims.
Changes to our Privacy Notice and your duty to inform us of changes
This version was last updated on 16 May 2018.
The data protection law in the UK changes on 25 May 2018.
We will communicate to you any material changes to our Privacy Notice by posting to the addresses provided. This will ensure that you are always aware of the information we collect, how we use it and the circumstances under which we may disclose it.
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 relationship with us.
Your right to withdraw your consent or complain
You have the right to withdraw from us your consent to process your personal data at any time. Please bear in mind that if you object, this may affect our ability to complete a contract which we have with you. PQA will maintain an audit trail of consent given and consent withdrawn.
If you consider that we have failed to comply with this Privacy Notice and/or Data Protection Legislation in relation to the information which we hold or process, or you are not satisfied with our response, you have a right to make a compliant to the relevant UK supervisory authority for data protection issues at any time, which in the UK is the Information Commissioner's Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance in the manner which is set out at the end of the Privacy notice.
Our Data Protection Policy can be viewed from this link: PQA Data Protection Policy
If you have any requests or queries concerning your personal information or any queries about our practices, please call us on 0800 531 6282 or send us an email at email@example.com or write to us at the following address The Academy Queensmead Road, Loudwater, High Wycombe, Buckinghamshire, HP10 9XA