ACS PRIVACY POLICY

YOUR INFORMATION AT ACS
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How ACS Dance Centre collects, uses and protects personal information

ACS Dance Centre ("ACS", "we", "us" or "our") respects your privacy. This notice explains what personal information we collect, why we use it, who we may share it with, how long we keep it and the choices and rights available to you.

Organisation: ACS Dance Centre, a charitable incorporated organisation

Charity number: 1159627

Last updated: 6 September 2026

Version: 1.0

At a Glance

We use personal information to arrange and deliver dance education, classes, trials, teacher training, performances, examinations, outreach activities, studio services and purchases.

We collect additional information only where it is needed to keep people safe, make appropriate adjustments, meet legal duties or provide a service that has been requested.

We do not sell personal information. Promotional photographs, videos and electronic marketing are normally optional and are handled separately from essential service administration.

Questions or requests can be sent to admin@acsdance.uk.

For children and young people: We use information about you so that we can arrange your classes and activities, help you progress, contact your parent or carer and keep you safe. Your information belongs to you. You can ask us what we hold, tell us if something is wrong or speak to a trusted adult who can contact us for you.

Who we are and how to contact us

ACS Dance Centre is the data controller for the personal information covered by this notice. Our contact details are:

ACS Dance Centre, 66 Albert Road, Romford, Essex, RM1 2PP

Email: admin@acsdance.uk

Website: www.acsdance.uk

You can use these details to contact the person responsible for privacy matters at ACS. References in this notice to our privacy contact mean the person handling data protection matters on behalf of the charity.

Who this notice covers

This notice covers personal information about:

• children and young people who attend or enquire about ACS activities, together with their parents, carers and emergency contacts;

• adult students, teacher-training students, private-lesson clients and wedding-dance clients;

• people booking trials, classes, examinations, events, performances, studio hire, merchandise or other services;

• participants in charitable outreach, scholarship or funded programmes;

• supporters, donors, funders, event attendees and people who contact us; and

• visitors to our website, online shop and social-media pages.

Workforce information. Employees, job applicants, contracted teachers, volunteers and trustees may receive separate workforce privacy information. This public notice does not replace that information when ACS processes data in an employment, contracting or governance context.

The personal information we collect

Depending on how you interact with ACS, we may collect and use the following information:

Identity and contact information: names, titles, addresses, email addresses, telephone numbers and signatures.

Child and family information: a child's name, date of birth or age, parent or carer details, parental responsibility information and emergency contacts.

Class and learning information: class choices, availability, prior experience, assessed level, attendance, progress, examination entries and results, awards, performance or competition participation and communications with teachers.

Health, disability and access information: medical conditions, allergies, injuries, medication, disabilities, additional needs and adjustments that may be relevant to safe and inclusive participation.

Safeguarding and incident information: welfare concerns, disclosures, accident and incident reports, action taken, relevant communications and information needed to manage risk or meet safeguarding duties.

Images and recordings: photographs, video, audio, performance recordings and the consent choices connected with them.

Financial and transaction information: fees, invoices, payment status, transaction references, refunds, donations, Gift Aid information where applicable and limited payment information supplied by banks or payment providers. ACS does not normally receive or retain complete card details when a specialist payment provider processes the payment.

Booking, enquiry and correspondence information: trial requests, form responses, messages, complaints, feedback, survey responses and notes needed to respond or provide a service.

Marketing preferences: whether and how you have agreed to receive optional news, offers or promotional messages, together with any withdrawal or opt-out.

Website and technical information: IP address, device and browser information, pages viewed, approximate location, referral source, security logs and cookie or analytics information, where applicable.

Outreach and funding information: programme eligibility, attendance, referral information, outcomes and demographic or monitoring information where this is genuinely needed for a funded programme and explained at the point of collection.

We aim to collect only information that is relevant and proportionate. If a question is optional, we will make that clear where practical.

How we obtain personal information

We may obtain information:

• directly from you through an enquiry, booking, trial, enrolment, consent or payment form; by email, telephone, message or in person; or when you attend or purchase from ACS;

• from a parent, carer or another person with parental responsibility on behalf of a child;

• from ACS teachers, reception staff or authorised volunteers through attendance, progress, examination, incident or safeguarding records;

• from partner schools, referral organisations, local authorities, funders, venues, examination bodies or other organisations involved in delivering an agreed activity;

• from payment providers, banks, online-shop providers and booking or form platforms; and

• automatically when you use our website or online services, through server logs, cookies and similar technologies.

If you give us information about another adult, such as an emergency contact, please tell them that you have done so and direct them to this notice where it is reasonable to do so.

Why we use personal information and lawful bases

Data protection law requires us to have a lawful basis for each use of personal information. More than one basis may apply to the same activity. We rely on the following bases where appropriate.

Contract and steps before a contract

to respond to an adult's or parent's request, administer bookings and enrolment, provide paid classes or services, process purchases, collect fees and meet our agreed terms.

Legitimate interests

to operate a safe, effective and sustainable dance charity; organise classes, outreach, examinations, performances and events; administer a child's participation where the contract is with a parent or carer; communicate essential information; improve our services; protect our systems; prevent fraud; recover debts; and establish or defend legal claims. When this basis is used, we consider the impact on the individual and give particular weight to a child's interests, rights and reasonable expectations.

Legal obligation

to comply with safeguarding, health and safety, equality, accounting, tax, charity, insurance and other legal or regulatory duties.

Vital interests

in a genuine emergency where using or sharing information is necessary to protect someone's life and another lawful basis is not suitable.

Consent

for optional uses where you have a genuine choice, normally including identifiable promotional photographs or videos and certain electronic marketing. Consent can be withdrawn for future use at any time.

Our main purposes

responding to questions and recommending appropriate classes or services;

• booking and managing trials, enrolment, attendance, timetables, fees and accounts;

• teaching, assessing progress and administering examinations, qualifications, performances, events and competitions;

• making classes safe and accessible, responding to emergencies and managing accidents, incidents and safeguarding concerns;

• delivering outreach, scholarships, funded projects and reporting outcomes to funders, using anonymised or aggregated information where possible;

• providing private lessons, teacher training, studio hire, merchandise and event services;

• sending operational messages about classes, payments, closures, safety, examinations, costumes, shows or other services;

• sending optional marketing where permitted and respecting opt-outs;

• maintaining, securing and improving our website, records, facilities and services; and

• meeting legal, regulatory, insurance, audit and governance requirements and dealing with complaints or claims.

Health, disability and other sensitive information

Information about health, disability, racial or ethnic origin, religion and certain other matters is classed as special category data and receives extra protection. ACS is most likely to process health, disability and access information so that a person can participate safely and appropriate adjustments can be considered.

In addition to an ordinary lawful basis, we use an additional legal condition for special category information. Depending on the circumstances, this may be explicit consent; protection of vital interests in an emergency where the person cannot consent; establishment, exercise or defence of legal claims; or substantial public interest conditions permitted by the Data Protection Act 2018, including safeguarding children or individuals at risk.

Where equality or demographic information is requested for an outreach or funded programme, we will explain why it is needed and whether it is optional. We will use anonymous or aggregated reporting wherever this can meet the purpose.

Safeguarding information

ACS may need to record and share information about a safeguarding or welfare concern even where consent has not been given or has been withdrawn. We will do this only where there is a lawful and proportionate reason, such as protecting a child or person at risk, complying with a legal duty or supporting a safeguarding investigation. Information may be shared with the local authority, police, emergency services, a designated safeguarding professional or another relevant body. We will limit sharing to what is necessary and will not promise confidentiality where that could place someone at risk.

Children's personal information

Children merit particular protection. We design our collection and use of their information around their best interests, the nature of our service and their age and understanding. Trial and enrolment forms for a child should normally be completed by a parent or person with parental responsibility. We do not ask young children to create their own ACS account.

A child's data protection rights belong to the child. A parent or carer can usually help exercise those rights, but as a young person becomes able to understand and make their own decisions, we may give greater weight to their wishes. We may ask for evidence of identity or parental responsibility and will consider safety, confidentiality and the child's best interests before disclosing information.

Class suggestions and automated decisions

Our online trial process may use answers such as age, experience and preferred dance style to filter the timetable and display classes that appear suitable. This is a practical recommendation only. It does not make a decision with a legal or similarly significant effect, and it does not guarantee that a class is appropriate or available. You can ask ACS staff to review the suggestion or recommend an alternative. ACS does not otherwise use solely automated decision-making that has legal or similarly significant effects on people covered by this notice.

Photographs, video and audio

ACS may photograph or record classes, examinations, performances, outreach activities and events for teaching, assessment, safeguarding, record-keeping, publicity or celebration of our charitable work. We will explain the intended use and lawful basis. For identifiable promotional use, particularly involving children, we will normally ask for separate consent from the appropriate person. Refusing promotional consent will not prevent someone from receiving ordinary ACS services.

Consent can be withdrawn for future use by contacting us. Withdrawal does not make earlier lawful use invalid. We will take reasonable steps to stop new use and remove material from channels controlled by ACS where appropriate, but we may be unable to recall printed materials, copies already downloaded or content shared by other people. If a performance or event will be professionally recorded, live-streamed or sold, we will provide further information where needed.

Service messages and marketing

Essential service communications

Messages about a booking, class change, closure, payment, examination, costume, performance, safety matter or another service you use are operational communications rather than optional marketing. We send them where necessary for a contract or our legitimate interests in providing and administering the service.

Optional marketing

We may send news, offers or information about other ACS activities by email, text or another electronic channel where you have consented or where another permission under electronic marketing law applies. Every electronic marketing message will provide a clear way to opt out. You can also contact us at any time. We direct marketing about children's activities to parents or carers rather than deliberately marketing to young children.

Choosing not to receive marketing will not stop essential messages about a service you have booked. We may retain the minimum information needed on a suppression list so that we continue to respect an opt-out.

Who we share personal information with

We do not sell or rent personal information. We may share the minimum necessary information with the following recipients where relevant:

•authorised ACS employees, teachers, reception staff, trustees and volunteers who need it for their role and are subject to appropriate confidentiality expectations;

• specialist instructors, photographers, videographers, venues, event providers and other contractors helping us deliver an agreed activity;

• examining, awarding, training, competition and governing bodies, including organisations such as the Imperial Society of Teachers of Dancing (ISTD) or Acrobatic Arts where relevant;

• partner schools, referral bodies, local authorities, community partners and funders involved in outreach or funded programmes;

• website, email, cloud-storage, form, database, communications and IT-support providers, including the providers used to operate our Squarespace website, Google-based forms or services and internal pupil records;

• Shopify and relevant payment, banking, accounting, fraud-prevention and debt-recovery providers used for bookings, purchases, fees, donations or refunds;

• professional advisers and oversight bodies, including accountants, auditors, insurers, legal advisers, HM Revenue & Customs, the Charity Commission and the Information Commissioner's Office; and

• the police, courts, emergency services, local-authority safeguarding teams or other bodies where disclosure is necessary to protect someone, comply with law or establish, exercise or defend legal rights.

Some recipients act only on our instructions as processors. Others, such as an examination body, payment provider, regulator or safeguarding authority, may act as an independent controller and use information under their own privacy notice.

International transfers

Some technology and service providers used by ACS may store or access personal information outside the United Kingdom. Where UK data protection law treats this as a restricted international transfer, we will use an approved transfer mechanism, such as UK adequacy regulations, the UK International Data Transfer Agreement or the UK Addendum to approved contractual clauses, together with additional safeguards where appropriate. You may contact us for more information about safeguards relevant to your information.

How long we keep personal information

We keep identifiable information only for as long as it is reasonably needed for the purpose collected, including legal, safeguarding, accounting, insurance and dispute requirements. Our usual approach is set out below; a longer or shorter period may apply where the circumstances, a legal duty, an insurer, an examination body, a safeguarding need or an active complaint or claim requires it.

Usual retention periods

Enquiries and trial requests that do not proceed

normally up to 12 months after the last meaningful contact, unless you ask us to delete them sooner and no exception applies.

Current pupil, student, customer and hirer administration

for the duration of the relationship. Core enrolment, contract, attendance, transaction and relevant correspondence records may then be retained for up to six years where needed for accounts, complaints or legal claims.

Emergency, medical and access information

reviewed while the person participates and removed or anonymised when no longer needed. If it forms part of an accident, safeguarding or legal record, the relevant longer period applies.

Accounting, payment, donation and Gift Aid records

normally six years after the end of the relevant financial year, or longer if law or a live enquiry requires.

Accident, injury and liability records

for the relevant legal and insurance claim period. Adult records are commonly required for at least three years; records involving a child may need to be retained until at least the child's 21st birthday, and longer where a claim or insurer requires.

Safeguarding records

for a period proportionate to the nature and seriousness of the concern and in line with applicable safeguarding guidance. This may extend into adulthood, including to a child's 25th birthday or longer where needed to protect individuals or manage allegations, investigations or legal claims.

Examination and qualification records

for the period required by the relevant examining or awarding body. Limited achievement information may be retained longer where it is needed to verify a qualification.

Photographs, video and audio

for as long as needed for the explained purpose and while the applicable permission remains valid. We review continued use periodically; archival performance material may be retained where this is lawful, proportionate and appropriately protected.

Marketing information

until you opt out, the purpose ends or we decide that you are no longer engaged. A minimal suppression record may be kept after opt-out.

Website, security and cookie information

for the periods explained in our Cookie Notice or by the relevant service, limited to what is necessary for security, functionality, analytics or the consent given.

Complaints, rights requests and legal matters

for as long as needed to resolve the matter and normally up to six years afterwards where necessary to demonstrate compliance or manage legal claims.

When a retention period ends, we securely delete the information, anonymise it so that it no longer identifies anyone, or restrict it where deletion must be delayed.

How we protect personal information

We use proportionate technical and organisational measures designed to protect information from accidental or unlawful loss, misuse, alteration, disclosure or access. These include limiting access according to role, confidentiality requirements, password and account controls, secure physical storage where paper records are used, appropriate supplier arrangements and staff awareness. No system is completely secure, but we review risks and improve controls where needed.

Please use care when sending sensitive information by ordinary email or messaging services and contact us if you would like to discuss a more suitable method.

Website, cookies and third-party services

Our website and online shop may use essential technologies needed for security, navigation, bookings, shopping baskets and other requested functions. Analytics, advertising or other non-essential cookies will be managed through the website's consent controls where consent is required. Our separate Cookie Notice will identify the cookies and similar technologies used on the finished website and explain how to change preferences.

Our website may link to Shopify, social-media platforms, maps, payment services, examination bodies or other independent websites. Those organisations may collect information under their own privacy notices. ACS is not responsible for the privacy practices of an independent third-party service.

If you do not provide information

Some information is necessary to enter into or perform a contract, meet a legal duty or provide a class safely. For example, we may need a participant's identity and age, an appropriate contact, relevant emergency information and payment details. If necessary information is not provided, we may be unable to offer a trial, enrol someone, make a safe adjustment, enter an examination or provide the requested service. Optional promotional-photo and marketing choices are not a condition of ordinary participation.

Your data protection rights

Depending on the circumstances and the lawful basis used, you may have the right to:

• be informed about how personal information is used;

• ask for access to your personal information and a copy of it;

• ask us to correct inaccurate or incomplete information;

• ask us to erase information in certain circumstances;

• ask us to restrict how information is used in certain circumstances;

• receive certain information in a portable format, where the right to data portability applies;

• object to processing based on legitimate interests and object at any time to direct marketing;

• withdraw consent at any time where consent is the basis or special-category condition; and

• complain to the Information Commissioner's Office.

These rights are not absolute and exemptions may apply. We may need to confirm identity and understand the request before responding. We do not usually charge a fee. To exercise a right, email admin@acsdance.uk or write to the address above. Please keep your information accurate and tell us when important details change.

YOUR RIGHT TO OBJECT: You have the right to object to our use of your personal information where we rely on legitimate interests. You also have an absolute right to object to direct marketing. Contact admin@acsdance.uk and tell us what you object to.

Questions and complaints

Please contact ACS first if you have a privacy question or concern. We will consider the issue and try to resolve it. You also have the right to complain to the UK regulator:

• Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

• Telephone: 0303 123 1113

• Website: ico.org.uk/make-a-complaint

Changes to this notice

We will review this notice when our services, systems or legal responsibilities change. The current version will be published on our website with its last-updated date. If a change is significant, we will take reasonable steps to draw it to the attention of affected people and seek fresh consent where the law requires it.