The Privacy Notice below describes how your data is collected and used (in relation to art sessions only).
In relation to my private tuition services (i.e. private tuition) please see https://farehamtutor.co.uk/privacy-notice/.
The Privacy Notice has been updated. I only update the Privacy Notice when I feel that wording could be improved to make things more transparent or where a new service is introduced on the website (or where the law changes).
Who I am (The Data Controller)
Adam Wardle, 43 Miller Drive, Fareham, Hampshire PO16 7LY
Who I hold information on
In relation to art sessions, personal data comes from:
People who contact me
People who visit my website
People who use contact me via my social media pages (Facebook. Twitter, etc.)
- People/Companies I use for business services (e.g. advertising)
How I receive your information
I could receive information via booking forms as well as when you contact me by email, etc.
You could also provide me information through the live chat service, one of my social media pages (Facebook, Twitter, etc.) or your use this website. See:
‘Information relating to the Live Chat service’;
‘Information relating to social media sites’
all of which are below.
What kind of information I may hold about you
For the majority of art session customers most information comes from the booking form (i.e. name, address, weeks being attended, etc.). Info may also be given if you email me or phone me.
Please note I also need to keep a record of who is physically present at sessions, leaves early, etc. in case of a fire, etc. (required by insurance as well as the hall for safety reasons).
Depending on how you pay me, your details can appear on my bank statements against your payments (e.g. if you pay by bank transfer your name/account details may appear on my statements).
I may hold other information from your use of the website (or external Social Media pages). Please see:
‘Information relating to the Live Chat service’; and
‘Information relating to social media sites’
all of which are below.
Why I collect this information
The personal data is necessary for me to:
deal with customer enquiries (e.g. someone emails about sessions, so I email back info);
comply with my legal obligations, for example tax (e.g. I write down your name and address on my accounts against a payment you make me as required by tax authorities); and
deal with enquiries in relation to payments
Where you wish for basic information about the services, I may be unable to do so without your basic contact details (e.g. an email).
Without a fully completed booking form I cannot provide you with art sessions.
The legal basis for processing your information
I need to process information for the following reasons:
The performance of the contract with you or for me to take steps for me to enter into a contract
This covers situations such as where someone makes an enquiry with a view to booking sessions, I may use their email address to email back with an offer (which hopefully leads to a contract).
This also covers situations such as where someone with an existing contract emails me about arrangements and I email back.
The perfomance is in compliance with a legal obligation, such as providing information to a tax or other authority
This covers situations, such as where I record personal details on my accounting records to show where payments have come from. Like any other business I am required by law to keep full detailed accounts. This includes providing details on who I receive payments from as well as details of any refunds I make.
HMRC requires me to retain details relating to payments received and refunds made to prove the authenticity of my accounts (for example correspondence in relation to refunds I make).
I also may need to provide copies of my bank statements to HMRC, which show payments from you (and payments made to you, for example, a refund).
Although it is unlikely, I may possibly need to provide evidence to HMRC of cancellations, contract terms or other correspondence between us if required by them. In this event this may involve showing emails from customers to HMRC.
- Regarding Coronavirus impact: Please note that HMRC has just announced that businesses making any claims relating to Coronavirus impact are required to retain evidence of Coronavirus impact. This does not make any difference to data being retained, but it means that HMRC may (possibly) ask for and require sight of customer correspondence, such as customer emails cancelling tuition because of the Coronavirus situation.
The performance is in relation to a legitimate interest:
I anticipate keeping customer reviews, so that their authenticity can be verified.
I anticipate storing correspondence relating to contracts (e.g. booking forms, email correspondence) in case of a later query or complaint.
I anticipate keeping live chat records and messages received via the service in case of a later query or complaint relating to what was said.
- If I wish to go to some countries, I may need to apply for an entry visa in advance (e.g. tourist visa). This may mean I may need to present some bank statements to the foreign embassy in advance of my trip and/or immigration officials on arrival to prove my financial standing and/or income. (Note: The reason for mentioning this is bank statements show the names of the people who paid me against payments made, which is personal data).
You give your consent:
I may ask you to sign a consent form to allow me to use images, etc on my website and social media accounts to promote sessions. You can refuse to sign the consent if you wish. The terms of that consent form (if any) will set out what is agreed between us. You may withdraw your consent to this at any time.
I may ask you to sign a consent form in relation to any health or disability information you may provide me. The terms of that consent form (if any) will set out what is agreed between us. You may withdraw your consent to this at any time.
I do not do mailing lists, etc.
I do not do mass marketing emails, etc.
Test and Trace
To support the NHS Test and Trace programme, I will be keeping a record of all visitors to the hall for art. The aim of the NHS Test and Trace programme event is stop the spread of Covid-19. The visitor record will include details of:
• your name
• your contact phone number
• the date of your visit
• your arrival time
• your departure time
I will only share your details with NHS Test and Trace, if asked by the service.
Each visitor record will be destroyed after 21 days have passed (i.e. on the 22nd day)*.
You can opt out of the Test and Trace system if you wish, but are strongly recommended not to do so.
* Please note that the Test and Trace visitor record is a separate record to the Visitor Record (see below) which is retained for a longer period.
A record of all visitors to art is kept, as this is required by the hall for their insurance purposes. This is being kept for up to six years and ten months.
Information relating to the Live Chat service
Key points about the Live Chat service:
Please be aware that I may see anything you type into the chat even before you press ‘enter’.
I am the only one who responds to queries on the live chat service.
All communication on the chat is over a 128bit Secure Socket Layer and all data is housed on encrypted servers.
When you make contact with me by way of potentially personal information, the service by default tells me your approximate location (i.e. approximate city/town) and browser type, but I will not use this to try to identify you as an individual.
I have disabled your IP address being shown on the chat.
You do not need to provide your contact details before starting a chat or during a conversation.
I will only ask you for an email, for example, if you wish me to send you an offer or wish me to contact you by email.
If I am offline/not available, I only ask for your email, so that I can provide you with a reply to your enquiry.
Tawk.to keeps a record of communications for me using a google cloud host, but I will remove them from the storage at the latest every 90 days.
Tawk.to complies with Google’s terms and model contract clauses that cover compliance with UK and EU data protection law.
Tawk.to’s Privacy Notice is on https://www.tawk.to/privacy-policy/
Please note that I am emailed a copy of conversations and messages at the end of every conversation/upon a message being sent. These email records will be held with me:
for up to one year (where you do not book an art sessions at all or enter into a contract with me); or
for up to six years and ten months (where you do book an art session (albeit at a later date) or enter into a contract with me)
These periods may be extended where required by law (e.g. a court order).
Information relating to social media sites
*The info below applies to any social media sites run by me at any time*
With the exception of private messages you send me through a social media account, my social media accounts are by their very nature public. Consequently when you submit any information, ‘like’ a page/article/comment or leave a comment, etc. on any of my social media accounts, by its very nature you are making that information/action you take public. Usually such information stays on my public social media pages indefinitely (e.g. liking a page, leaving a review, commenting on a post I make, etc.).
As the social media services are public anyone can look at them, so any information or action you make public will be available for anyone to see. I cannot control how other people use that information. In short, if you are not happy for anything you do on the social media accounts to be made public, please do not do it in the first place.
Retention periods in relation to social media accounts
The individual social media services will have their own Privacy Policies which you should be aware of. I have no control over their Privacy Notices and their retention of data.
As regards notification emails, these fall into two groups:
Email notifications I receive giving details of customer reviews I may keep indefinitely. This is under the legal ground of legitimate interest, as I may need to prove the authenticity of reviews in the future.
Other social media notification emails will be deleted by me within a maximum of one year (with the exception of where I am required to retain them by law (e.g. court order), in which case they will only be kept for so long as the law requires me to do so).
As regards private messages received through a social media account:
These will be deleted within a maximum of one year with two exceptions:
1. Where you book an art session within a year (or already have a contract with me), the message (and/or a copy of the message) may be kept by me for a maximum of six years and ten months. This is done under the ground of legitimate interest, as I may need to deal with queries or questions relating to what was said/agreed or to deal with a possible complaint.
2. Where I am required to retain the private message for longer by law (e.g. court order).
Tax Deductible Expenses
This is unlikely to be of relevance to customers, but is included here for completeness. I am required by law to keep evidence of tax deductible expenses. I retain such documents for up to six years and ten months (unless required by law to retain them for longer e.g. court order, in which case I would not keep them longer than required by law).
Foreign Visa Applications
If I wish to go to some countries, I may need to apply for an entry visa in advance (e.g. tourist visa). This may mean I may need to present some bank statements to the foreign embassy in advance of my trip and/or immigration officials on arrival to prove my financial standing and/or income. (Note: The reason for mentioning this is bank statements show the names of the people who paid me against payments made, which is personal data). This is under the ground of legitimate interest.
How long I will retain your information
For details on the retention of i) live chat data and ii) my social media accounts and iii) records of tax deductible expenses please see the relevant sections above, but this section sets out the retention limits of all other data.
Where you do not enter into a contract with me, data (e.g. emails, etc.) in relation to your enquiry may be kept for up to one year from the date when you last contact me.
Where you do book an art session or enter into a contract with me, albeit at a later date, data (e.g. email enquiries, email correspondence, booking forms, accounts records, etc.) may be kept for a maximum of six years and ten months with the exception of:
As regards customer reviews, I keep these indefinitely to prove the authenticity of these in the future.
Where required by law
This would cover the situation where I am required to keep documentation because of, for example, a court order.
- Where you have consented to a longer period
- This would cover the situation where you expressly agree (in writing) to longer retention
My site does not use any unnecessary cookies, so the Cookies section is short.
Up to and including 1st June 2020 visitors to the site were asked their Cookie Preferences. A log of this with IP address was being kept to comply with the law. This will be kept for as long as the law requires. (At that time you would have been given the choice whether to accept or decline cookies by a banner when you first used the site).
Links to external Sites
If you click on links to certain services or external sites, you will be using their services and be subject to their Privacy Policies. These are the live chat, links to Facebook, Twitter, etc.
On my website I use analytics which tells me whether you are a new or existing visitor to the website, your IP address, where in the world you are visiting from, how long you spend on the website, your browser and operating system as well as how you reached the website. This information is used to make sure that my website is attracting the right visitors (e.g. I want to see that all my visitors come from the UK and found my site by searching for terms that are relevant to my services), but I have no interest whatsoever in trying to identify any particular website user. I only want to make sure that my website visitors as a whole are the ones I want visiting my site.
Please note that I use a program on my website which allows me to block IP addresses of people who try to access unauthorised parts of my website. This is done to prevent unauthorised access to my website and to maintain the integrity of the site. I will not use the data to try to find out the identity of any particular user. Where attempts to do malicious activity is detected by the program, the IP address may be reported to an external database to prevent future unauthorised activities on this and other websites. I just want to stop people with malicious intentions from being prevented access to parts of this and other websites when they are not allowed to. If you are a legitimate user of the site, this should not affect you at all.
Security measures in place
– On 5th October 2018 my website was changed from http to https
– Offline storage
Links to other sites
Where my website has links to other websites, those sites are not covered by this Privacy Notice. (I cannot control what data an independent third party holds and how long they hold it for). In this scenario this Privacy Notice only governs data held by me (i.e. in my control).
Future changes to this privacy notice
It is possible that I will need to update this privacy notice in the future. In that event, I will update the Privacy Notice on this website. (Please be reassured that I will not increase time limits for retention of data retrospectively). Please look regularly for updates here, so that you are up to date on what information is collected and how it is used.
You have the right to:
request your personal data;
object to processing of personal data that is likely to cause, or is causing, damage or distress;
have inaccurate personal data rectified;
withdraw consent at any time (where consent is the legal ground for retaining data);
request your information to be deleted or destroyed (in certain circumstances); and
claim compensation for damages caused by a breach of the Data Protection Regulations
If you are not happy with how your personal information is used, I would ask that you contact me on email@example.com, but you have the right to complain to the Information Commissioner’s Office at www.ico.org.co.uk.
If you wish to contact me with any questions, feel free to contact me on firstname.lastname@example.org.
Now that you have read the Privacy Notice, maybe take a look at details of the Art Sessions I am running in Warsash by clicking here.