Privacy Policy

Aerial Edge Data Protection & Privacy Policy

(updated May 2018)

Introduction

As necessary part of our operations, we must collect data about the people who we work with.

We have a responsibility to handle your information properly, however it is collected, recorded and used, and whether it be on paper, in computer records or by any other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with daily operations. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of our customers, including: clients, current and prospective students and people who may act on their behalf e.g parents. These are referred to in this policy as relevant individuals.

What do we mean by 'data'?

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.

“Special categories of personal data” is data which relates to an individual’s health, sexual orientation, race, ethnic origin, political opinion and religion.
“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

How we handle your data

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
  • processing will be fair, lawful and transparent
  • data be collected for specific, explicit, and legitimate purposes
  • data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
  • data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  • data is not kept for longer than is necessary for its given purpose
  • data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  • we will comply with the relevant GDPR procedures for international transferring of personal data

Types of data we collect

We keep several categories of personal data on our clients in order to carry out effective and efficient processes. We hold the data both on paper and within our computer systems. Specifically, we hold the following types of data:
  • Personal details such as name, address, phone numbers, email address provided when you sign up to our booking system or enquire about making a booking.
  • Personal details of your nominated emergency contact: the name and phone number/s that you provide us with on your paper or electronic disclaimer form.
  • Billing information.
  • Medical or health information relating to your training e.g previous injuries or first aid incidents
  • Medical/ First Aid incident reports.
  • Non medical incident reports including: disciplinary incidents e.g. bullying, sensitive information disclosures (these may be passed to child protection services in relevant cases)
  • Marketing preferences: e-newsletter contact permission.
  • Your photography permission preferences.
All of the above information is required for our operational activities. More information on those processing activities can be requested by contacting our General Manager.

How we use your data

We use the information you provide us with to ensure the safe and smooth running of our organisation:

  • Management and administration – to contact you about relevant changes to our business that may affect you (e.g venue or time changes or class cancellations) or to consult you on upcoming changes relating to any of you/ your child’s classes.
  • Individuals’ health data – to comply with health and safety or occupational health obligations towards our students and staff. Including disabled individuals, whether any reasonable adjustments are required to assist them in our classes.
In some instances we may need to or disclose information to a relevant person externally to our organisation. The circumstances leading to such disclosures include:
  • Assisting law enforcement or a relevant authority (e.g child protection) to prevent or detect crime or prosecute offenders.
These kinds of disclosures will only be made when strictly necessary for the purpose.

Third Party Processing

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.

The third party services that we use to process your data are:

  • Mindbody
  • Helpscout
  • Ringcentral
  • Mailchimp
  • Typeform
  • Google Drive
  • Zapier
  • Mailmunch
  • Contact Form 7
  • Eventbrite
  • Xero
  • Stripe
  • Slack
  • Facebook
  • Twitter
  • Instagram
  • Dropbox
  • Google Analytics

We have taken steps to ensure that your data is protected by a ‘data processing agreement’ where we engage third party services to process your data.

International Data Transfers

The Company may be required to transfer personal data to a country/countries outside of the EEA. Transfers may take place because our booking system and other software is hosted by companies located outside of the EEA. Where this occurs, the following safeguards are adopted (and we have endured that their systems are compliant with GDPR best practise.

Your Rights

You have the following rights in relation to the personal data we hold on you:

  • the right to be informed about the data we hold on you and what we do with it;
  • the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
  • the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  • the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  • the right to restrict the processing of the data;
  • the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  • the right to object to the inclusion of any information;
  • the right to regulate any automated decision-making and profiling of personal data.

Security and our responsibility to you

In order to protect your personal data, our staff who must process data as part of their role have been made aware of our policies on data protection.

All employees are instructed to store data of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them.

All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.

We have also appointed employees with responsibility for reviewing and auditing our data protection systems.

Lawful Bases of Processing

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.

Where no other lawful basis applies, we may seek to rely on your consent in order to process data.

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. You will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.

Accessing your data

To exercise your right to access any data we store on you, you should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.

To make a Subject Access Request, please contact our office.

What happens when there is a breach?

All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.