NKYO Privacy Policy

This consists of two separate policies: 

  1. Website, Internet and Social Media Data Protection & Privacy Policy

  2. Parent and Carer Data Protection & Privacy Policy

Both can be accessed from this page. 

NKYO Website, Internet and Social Media Data Protection & Privacy Policy

 

Introduction

 

This website, www.nkyo.org, is operated by Ilana Cravitz, who is registered with the Information Commissioner’s Office in the UK under registration number A8976952.

 

Data protection rules require all organisations to explain to individuals what personal data they collect and process during their work together. For NKYO data collection and storage, and privacy policy not related to this website please see the NKYO Parent and Carer Data Protection & Privacy Policy document.

The National Klezmer Youth Orkester (‘NKYO’) collects and processes personal data belonging to parents, carers, and the children in their care. We do this in order to organise and to provide our educational and related activities and resources. NKYO is committed to being transparent about how we collect and use personal data and to meeting our data protection obligations. This Privacy Policy aims to provide you with a clear explanation of the personal data that NKYO may hold about you and your child and the purposes for which

they are held, relating to our website and related activity.

 

It is important that the personal data we hold about you and your child are accurate and upto date. Please keep us informed if your personal data change during your relationship with us. You should read this page regularly, and if you no longer wish to be bound by the terms here, please no longer access or use the site.

 

Contact details for data protection purposes:

Data Officer: Ilana Cravitz, NKYO Director

 

Email: klezmeryouth@gmail.com

 

Website: https://www.nkyo.org

 

ICO Registration Number: A8976952

 

LAST UPDATED 19 July 2021

 

1. Legal Context

 

This policy applies to Ilana Cravitz, Director of the National Klezmer Youth Orkester (NKYO), henceforth referred to as NKYO in relation to management of this website: www.nkyo.org.

 

NKYO takes your data protection seriously and is committed to protecting your personal information. We aim to be clear and open about our data security practices. Where we ask you to provide us with any information by which you can be identified, you can be assured that it will only be used in accordance with this statement, and in line with the UK-GDPR (General Data Protection Regulation) and amended Data Protection Act 2018 that took effect on January 31, 2020.

2. Your Legal Protection

The law protects your right to privacy. According to the law we are only allowed to use personal information for legal reasons. These include:

  • When it is our legal duty

  • When you consent to it

  • When it is in our legitimate interest to do so.

 

By legitimate interest, we mean the interests of NKYO in operating and managing our organisation to enable us to provide an appropriate and safe service and a secure experience for our stakeholders.

 

NKYO has a legitimate interest in terms of the provision of learning and training activities, fundraising, business operations and 
organisational development purposes.

3. What data we collect

When you interact with us through our website we may collect personal data such as your name and email, when you provide this information via the contact form or by registering for the mailing list. We may also collect your IP address, and data that you provide to us through emails, and your social media interaction such as through Facebook, Twitter, Instagram,

YouTube or similar, and via Google analytics.

You are not obliged to provide information, but if you choose not to then it may be difficult for us to deliver some of our services to you on a practical level, and you may have limited access to information and news.

4. How we use your data

If you provide personal data for a certain reason, we may use it in connection with the reason for which it was provided. We may also use your personal data and other personally non-identifiable information collected through the website to help us improve the content and

functionality of the website, to better understand our users and to improve our services.

 

5. Use of cookies

This website uses cookies, which fall into four categories: 

  • Essential: to enable core functionality such as security, verification of identity and network management. These cookies cannot be disabled.

  • Marketing: used by third parties (e.g. Google, Facebook) to track advertising effectiveness, to provide a more relevant service and deliver better ads to suit your interests.

  • Functional: to collect data to remember the choices users have made. This gives the user a more personalised experience. 

  • Analytics: to help us to understand how visitors interact with our website, and to discover any errors.

 

The cookie pop-up box on this website gives you three options: 

 

  • "Cookie Settings": allows you to accept or decline any of the non-essential categories

  • "Decline All": disables all but Essential cookies

  • "Accept All": enables all cookies. 

 

In addition, you can remove cookies at any time by clearing the search history in your browser. 

 

6. Our privacy promise

  • We will keep your data safe and private

  • We not sell or rent your data

  • We will give you ways to manage and review your marketing choices at any time

  • We will not send you marketing or fundraising information by email or other electronic means of communication without your express opt-in consent.

7. What information do we collect about you?

We collect various types of personal information depending on your relationship with NKYO and the consents that you have given about the use of your information.

When you use our website, we collect the personal information that you provide to us, for example your name and your email address, as well as any other contact information you choose to provide us in connection with the delivery of services.

Children / Under 16s

The age of ‘data consent’ is 16. Therefore, where under-16s engage with NKYO, it is imperative that their parents/guardians provide the young person’s personal data, and consent to NKYO’s use of that data.

We do not knowingly collect or request personal information from children. If you are under 16, please do not try to register for our services or send any personal information about yourself to us. If it comes to our attention that we have collected personal information from a child, we will immediately delete that information.

 

Parents/carers of participants under 16, donors, supporters, members over 16 years

 

We may collect your name, address, email address, telephone number, residence details, debit or credit card details, feedback about an event, product, service and other information that you choose to provide to us.

We will then use this information to:

  • administer, operate and improve our musical, educational, and charitable activities

  • provide event tickets and other goods and services you have asked for

  • process donations

  • keep a record of your relationship with us

  • administer our various donor and supporter schemes

  • send you information according to your preferences about our events, learning, fundraising and social programmes, and policies. This may occasionally include news about the events and products (e.g. concerts & albums) from related organisations, funders and supporters.

  • conduct fundraising activities including fundraising, marketing and reporting project updates and outcomes to funders

  • ask you to participate in surveys and feedback

  • create a profile of your interests, preferences and donations or future donations, (using additional information already in the public domain) so that we can contact you in the most appropriate way and with the most relevant information and ensure our resources are used in the most effective and efficient manner

  • develop our understanding of members, audience, participants and donors through research and the creation of stakeholder segments

  • maintain an archive for NKYO – including alumni information

 

Current participants in our ensembles, workshops and other programmes and events

We may collect your name, address, email address, telephone numbers, date of birth, country of residence, any of the above details for your parent, guardian or next of kin, details of any disabilities, medical conditions or allergies, access needs, details of your current

schools, your feedback about our programmes and events, experiences of musical participants and other information that you choose to provide to us. We use the information to:

  • run, administer, develop and improve our learning and development programmes, events and ensembles

  • send you information by post, telephone – and if you have given your consent by email – about our educational, development and social programmes and events, our gigs, albums, educational, fundraising and social programmes, our website, policies

  • ask you to provide feedback and participate in surveys

8. Where does NKYO store personal information?

 

Data will be stored in a range of different places, including on your web registration form, within our mailing list provision service, on our computer system, and in our email system.

9. Security

 

We will ensure that the personal information that you provide will be held securely, that there are appropriate technical controls in place to protect it and that only relevant staff, volunteers and contractors have access to that information.

Unfortunately, the transmission of information via the internet to us is not risk free; we will do our best to protect your personal information once we receive it, but we cannot guarantee the security of your information as it is transmitted to our site and related servers. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

This website is hosted on the Wix.com platform. Your data submitted via this website may be stored by Wix.com on its secure servers in multiple locations around the world. For further details please see https://www.wix.com/about/privacy/#.

 

NKYO takes all reasonable steps to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration or destruction. However, internet and e-mail transmissions can be prone to error or security breaches. Please, therefore, take special

care when deciding which information to share via email or over the internet.

 

 

10. Social media links & privacy

 

Through this site, you can choose to access certain social media websites and services that are owned and/or controlled by third parties (including, but not limited to, Facebook, Twitter, YouTube and Instagram). When you elect to access and use these social media sites you

will be sharing your information (which will include personal information if you elect to share such information) with those social media sites (SMSs). This information will be governed by the privacy policies and terms of service of the SMSs and not by the policies and procedures

we describe here. When you log in to the SMSs from our site, we will collect relevant information necessary to enable us to access that SMS, however you will provide your login information (email address, password etc.), directly to the SMS. As part of such integration, the Social Media Service will provide NKYO with access to certain information that you have provided to those sites, and we will use, store and disclose such information in accordance with this Privacy Policy.

The manner in which the SMSs use, store and disclose your information is governed by the policies of the applicable SMS provider, and, as a result we shall not have any liability or responsibility for the privacy practices or other actions of SMSs that may be enabled within and/or otherwise accessible through this site.

11. Links to other websites

This website contains links to other, unaffiliated third party websites. Please note that NKYO is not responsible for the content or privacy and confidentiality practices of any third party websites. You must always carefully review the privacy and confidentiality policy of any

third party website that you may visit in order to understand how the operators of that website may collect, store and use your personal information.

12. Keeping your information up to date

We want to make sure that any personal information we hold about you is accurate and up to date. Please contact us on klezmeryouth@gmail.com to correct or remove information you think is inaccurate.

13. Sharing your information

 

NKYO will not rent or sell your information to any third party. We may share your information with third parties where we have a legal duty to do so, or to provide you with a high quality service.

 

We may also share your information with funders, partners and suppliers where this is necessary for service or business operations. When we do so, where appropriate we will review their data protection policies and strive to obtain appropriate confidentiality and data

use undertakings to ensure appropriate protections for your data.

 

We may also share your personal data with our related companies for purposes consistent with this Privacy Policy. We, like many organisations, sometimes hire other companies to perform certain business-related functions. Examples of such functions include mailing

information, maintaining databases and processing payments. When we employ a company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

 

Except as set out above, and unless obliged to do so by law, we will not share your information with third parties (including for their marketing purposes) without your express consent.

14. Exclusions

 

This policy applies to information that we collect through this site. It does not apply to unsolicited information that you provide. This may include information posted to another area of the site, comments left in public forums or on social media sites. All unsolicited information

and comment shall be deemed to be non-confidential and NKYO shall be free to reproduce, disclose, use and distribute any of this information to others without limitation or attribution.

 

NKYO may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of NKYO, (iii) act in urgent circumstances to protect the personal safety of

users of the website or the public, or (iv) protect against legal liability.

 

 

15. Your rights

 

The law gives you important rights over how NKYO uses your personal information. These are:

  • the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this Privacy Policy

  • the right of access. You have the right to access the data that we hold and to receive a copy of your data and information about where it was sourced. To do so, you should make what is known as a subject access request. You can contact NKYO at the address at the beginning of this policy if you wish to do this. The Information Commissioner’s Office (ICO) publishes information on Subject Access Requests which may be of help to you – see https://ico.org.uk/your-data-matters/your-right-ofaccess/

  • the right for any inaccuracies in the data NKYO holds about you to be corrected

  • the right to ask BF for your data to be erased, for example if you believe there is no longer any need for your data to be held for its original purpose, or if you decide to withdraw any consent that you have given for your data to be processed

  • the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct

  • the right to portability. You may transfer the data that we hold on you to another organisation for your own purposes

  • you may have the right to object to the way we use your data if you do not agree that we are using it for our legitimate interests

  • the right to regulate any automated decision-making and profiling of personal data

 

Reviewing your personal data

 

You have the right to request a copy of the information that we hold about you at any time. If you would like a copy of some or all of your personal information, you can email klezmeryouth@gmail.com. We will not charge you for this service unless the request is ‘manifestly unfounded or excessive or repetitive’.

 

You can also use www.tapmydata.com to find out what personal data organisations hold about you.

 

Unsubscribe

You can choose at any time to unsubscribe from marketing and fundraising communications by simply clicking the ‘unsubscribe’ link found in all of our marketing emails.

 

Stop processing

You also have a right to ask us to stop processing your personal data if your consent is required for that processing. To request this simply email klezmeryouth@gmail.com.

 

Right to Erasure

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

 

Inaccurate Information

You can ask us to restrict the use of your personal information if:

  • it is inaccurate

  • it has been used unlawfully but you don’t want us to delete it

  • it is not relevant any more, but you want us to keep it for use in legal claims

  • you have already asked us to stop using your data but you are waiting for a response from us

 

 

16.  How long do we keep your personal information?

 

Participant records and records of parents of participants are retained for 3 years following their last known participation in an NKYO activity. We retain this personal information in order to be able to write to you with information about future NKYO events and activities, and updates about NKYO, which we believe you may find of interest. After 3 years, we will contact you to ask you whether you wish us to continue to retain this personal information for these purposes. Should your child turn 18 before the end of this 3 year period, we will

contact you at that time to ascertain your wishes.

  • Individual donor records are kept for 7 years after the last donation

  • After leaving any NKYO professional development and emerging artist programmes, alumni will be invited to join the NKYO alumni archives

  • Mailing list recipients and other contacts records are kept for 3 years from the

  • last contact

  • Financial records are kept for 7 years after the end of the financial year to which each pertains

  • If you have subscribed to our mailing list but later unsubscribe, no furthermarketing materials will be sent, however we may still hold your personal data on file for the purposes of doing business with you. If you would like your personal information to be completely removed from our database you can request this at any time

 

17. Register a complaint

 

If you wish to complain about any aspect of our date protection or privacy, you can do so by writing to the NKYO Director at klezmeryouth@gmail.com.

 

If you are not satisfied with the response, you can register a complaint about our handling of your personal data with the Information Commissioner’s Office (ICO). The ICO is the UK’s supervisory authority for data protection.

18 Questions and complaints about this privacy & data protection policy

 

If you have any questions or concerns regarding our privacy and data protection policies, please send a detailed message to klezmeryouth@gmail.com. We would appreciate the opportunity to understand and correct any concerns you have. If, in the light of our

responses, you believe that NKYO has not complied with your data protection rights, you can complain to the Information Commissioner. Their contact details can be found on their website www.ico.org.uk

19 Changes to our policy

 

We reserve the right to change or modify this policy at any time. If we do so we will post the changes on this page and indicate the date on which the policy was last updated at the top of this page.

 
 

NKYO Parent and Carer Data Protection & Privacy Policy

Introduction

 

Data protection rules require all organisations to explain to individuals what personal data they collect and process during their work together. 

The National Klezmer Youth Orkester (NKYO) collects and processes personal data belonging to parents, carers, and the children in their care. We do this in order to organise and to provide our charitable activities. NKYO is committed to being transparent about how we collect and use personal data and to meeting our data protection obligations. This Privacy Policy aims to provide you with a clear explanation of the personal data that NKYO may hold about you and your child and the purposes for which they are held. 

It is important that the personal data we hold about you and your child are accurate and up to date. Please keep us informed if your personal data change during your relationship with us. 

Contact details for data protection purposes 

Data Officer: Ilana Cravitz, NKYO Director

Email: klezmeryouth@gmail.com  

 

Website: https://www.nkyo.org

 

ICO Registration Number: A8976952

LAST UPDATED 19 July 2021

 

1. How NKYO aims to protect children’s data

 

Children have the same rights as adults with regards to the use of their personal information. However, every child is different, particularly when it comes to make informed decisions about the use of their personal data. 

NKYO considers that it is appropriate for parents and carers to make decisions about the use of their child’s personal data until they are sixteen years old. Once 16, we expect to inform a child about the use of their personal data directly and by providing a separate privacy policy to them. 

The exception to this is when we ask for specific consent to use photographs or video which feature your child’s image. This is explained more fully later in this Privacy Policy. In certain circumstances the law provides for a child to be able to give informed consent from the age of 13 years. 

2. Types of personal information that NKYO may collect about you and your child 

 

We may collect, store and use some of the following information about you and your child. Please bear in mind that this does not mean that we actually will collect every item listed. 

 

Parents and carers: 

  • personal contact details such as your name, title, address, telephone number, personal email addresses, date of birth, gender

  • the name of your child and the name/ages of siblings

  • emergency contact information for you and one other contact for your child

  • your nationality (only where legally necessary)

  • equal opportunities monitoring information, with consent, including information about your ethnic origin 

 

Children: 

  • personal contact details such as their name, address, telephone number, date of birth, schooling

  • name of parents or carers, their contact details and emergency contact information 

  • GP’s name 

  • nationality (only where legally necessary)

  • the NKYO session or activity the child registers to attend 

  • instrument, standard attained and teaching arrangements [teachers should only be named if permission has been granted for this to be shared] 

  • information about the child’s health and well-being 

  • equal opportunities monitoring information, with consent, including information about your ethnic origin

 

Exceptionally, NKYO may also collect personal information provided in connection with any safeguarding matter or concern.

 

 

3. Where does NKYO collect and store personal data? 

 

NKYO may collect the information listed above in a variety of ways. For example, data might be collected when you register your child to attend an NKYO session or activity, or though subsequent correspondence or contact with you or your child. 

 

Data will be stored in a range of different places, including on your registration form, our closed CRM (Customer Relationship Management system), on our computer system, and in our email system. 

 

Health form information is stored separately on the NKYO secure Google Drive and destroyed once the activity for which your child has registered has concluded.

 

See the NKYO Website, Internet and Social Media Data Protection & Privacy Policy details of how we collect and store information related to these media.

4. Our reasons and lawful basis for processing your and your child’s data 

NKYO has a legitimate interest in processing your or your child’s personal data in order to: 

  • register your child for an NKYO session or activity

  • plan and carry out NKYO sessions and activities

  • request and compile feedback on NKYO activities

  • maintain accurate and up-to-date records and contact details (including details of who to contact in the event of an emergency) 

  • maintain effective processes, such as safeguarding

  • use certain photographs or videos which may feature your child – this is explained in more detail below

  • carry out analysis of the value and benefits of NKYO activities

  • respond to and defend against any legal claims 

 

NKYO may also need to process your or your child’s data to comply with legal obligations, such as health and safety and safeguarding.

 

You do not have to give your or your child’s personal information to NKYO. However, if you decide not to, it is unlikely that we will be able to provide a place at an NKYO session for your child. 

In some circumstances we may ask for your consent to allow us to process certain particularly sensitive data. In such cases we will provide you with sufficient information about how the data will be used for you to make a choice about whether to provide your consent. You will have full control over your decision to give or withhold consent, and there will be no consequences if you choose not to consent.

 

Consent, once given, may be withdrawn at any time, again with no consequences. 

 

5. NKYO medical forms and information about the health and wellbeing of your child 

 

Before your child attends a live NKYO session or activity, we may ask you to complete a medical form and to provide details of your child’s health and wellbeing. 

 

For the purposes of GDPR, information about health is classed as a special category of personal data, and this requires us to take additional steps to explain to you why we ask for this data and the basis on which we process them. 

 

Under Articles 6 and 9 of GDPR, when we request health information about your child, it is on the basis of our legitimate interest (in ensuring we have information that will allow us to do our best to look after your child) and in order to comply with health and safety requirements. 

 

We do not need to ask for your consent if we use special categories of personal data in order to carry out our legal obligations.

 

You are not obliged to provide health and wellbeing information about your child but without this being provided on the occasions when we ask for it, we are unlikely to be able to allow your child to take part. 

 

6. Photographs and video 

 

In this section, we explain how we approach photographs and videos (‘images’) of people that NKYO takes for its own purposes and which may feature your child. It explains why we do this, our legitimate basis for doing this, when we may additionally ask for your and your child’s consent, your rights on their behalf and your child’s rights.

By photographs and videos we mean those already stored securely in NKYO systems as well as those we may capture in the future.

Our purpose of taking images of your child

 

We take photos and videos to:

  • document and raise the profile of our work promoting, teaching and performing klezmer music

  • encourage new members to join and donors to support the work

 

How we manage risk and protect your child’s privacy relating to images

 

Using an image brings some risk, for example that of your child is recognised by others. We understand that in the normal course of events, this may not to be a cause of concern. However in order to manage any risk appropriately NKYO will never: 

  • use an image which has identifying information, such as a name badge or the name of a school 

  • knowingly use an image of a child where there is a legal reason/requirement for their identity to be concealed

  • take an image that is inappropriate, which contravenes our safeguarding policies and procedures

  • which features a child who is not involved in a NKYO activity

 

How we take and share images 

 

  • images are taken by designated NKYO personnel, or a third party photographer or videographer employed by NKYO for a specific event authorised via an appropriate third party data controller/processor agreement 

  • images will not be taken on personal devices unless express permission has been given by the Director because this is operationally the most appropriate way for images to be taken 

  • images may be shared across NKYO-related websites and social media channels, including the NKYO YouTube channel 

  • in the usual course of events, NKYO channels are accessed and controlled by Ilana Cravitz (NKYO Director) only. Other authorised personnel may be allowed in exceptional circumstances.

 

Control of images

Images taken by NKYO personnel on mobile devices at sessions are deleted immediately after the image is sent directly to the Director or other authorised staff member. Occasionally, the image may be uploaded directly to social media or into NKYO’s secure Google Folder.

NKYO operates appropriate security measures to prevent images featuring your child from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed to others who should not see them. 

 

How we use photos and videos 

We may take images featuring your child to use as follows:

  • on NKYO’s website and in blogposts

  • on NKYO Social Media accounts or YouTube channel 

  • as part of printed publications promoting or reporting on our work

  • to support fundraising activities, where they can be seen by potential donors and grant-giving trusts and foundations

  • in press releases and media pieces as part of the promotional activity of NKYO

 

Please note that where an image is used on a widely distributed physical document, such as a paper annual report, or as part of a promotional film or film ‘montage’ of NKYO activities it may be practically impossible to recall all copies featuring an image for which consent to use has been withdrawn. For this reason NKYO urges you to consider extremely carefully before deciding whether or not to provide consent in these circumstances.

 

Our lawful basis for using images


NKYO has a legitimate interest in processing images of children for the purposes in the section above. 

We have considered our responsibilities for protecting the rights and interests of the children in this respect and as required by data protection law we have undertaken a Legitimate Interest Assessment (LIA). 

 

You can ask to see a copy of this LIA by contacting NKYO, as per the start of this policy document. 

 

NKYO retains the copyright in all images and will reserve and protect these rights in accordance with the law. 

 

Asking for your child’s consent as well as yours 

At NKYO we believe it is important for children and young adults to be included in the decision-making process about the use of their images and that their consent (or non-consent) is also respected. 

In the circumstances described above where we do not rely on legitimate use as the basis for using an image featuring your child, and where we will instead ask for specific consent, if your child is over the age of 13 we will also ask for their permission to use the image. 

If a situation arises where you are happy to give your permission to use your child’s image, but they are not, we will always go with their wishes. 

Opting out of photographs & images

We offer you the opportunity to ‘opt out’ of your child’s images being taken when you sign them up for a NKYO membership, or – for non-members participating in NKYO events – an  activity. Where you opt out, we will do our best to ensure that your child is identified by a discreet addition to his/her name badge and no images are taken. 

7. How does NKYO protect your and your child’s data? 

 

NKYO takes the security of your data seriously. We are working towards establishing effective internal policies and controls to ensure that your data are not lost, accidentally destroyed, misused or disclosed, and are not accessed except by authorised members of the NKYO team. 

Your and your child’s data will be shared with members of the NKYO staff team, teachers and Facilitators only where it is necessary for them to undertake their duties. An example of this would be administering your application form and communicating details of an NKYO session to you and your child.

NKYO may also share your data with third parties that process data on our behalf, for example where we need to do so in order to plan an NKYO session or activity, or where we have another legitimate reason for doing so. These arrangements would also governed by a duty of confidentiality. 

Except for in the circumstances outline above, NKYO will not share your data with third parties for any other purpose without your express consent. 

In the course of its operations, NKYO may process and/or store personal data using third party data controller/processors which have some or all of their operations based outside of the EA. Examples include our website, WIX, or our Google Drive. NKYO is not accordingly, able to offer assurance that personal data processed by such authorised third parties is not transferred outside of the EA, nor that the standard of any such processing is at least equivalent to that required under GDPR. Data subjects are however reminded that in is in the commercial interested of these third parties to ensure that personal data is handled securely and appropriately, and that in each instance they assert that they comply with the EU-US Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union. 

 

 

8. For how long will NKYO keep your data? 

In line with data protection principles, we endeavour only to keep personal data for as long as we legitimately need it, which will be, at least, for the duration of your child’s NKYO membership, or participation in NKYO activities.

Retention periods can vary depending on why we need your data. This may be determined by law or by appropriate business practice. 

  • Health information about your child on NKYO medical forms is destroyed after the session or activity 

  • Photographs or images which we have a legitimate interest in using are generally kept for a period of 3 years

  • Images which we hold on the basis of consent are kept for three years, after which we will either ask you to renew your consent or we will destroy the images 

  • Participant records and records of parents of participants are retained for 3 years following their last known participation in an NKYO activity. We retain this personal information in order to be able to write to you with information about future NKYO events and activities, and updates about NKYO, which we believe you may find of interest. After 3 years, we will contact you to ask you whether you wish us to continue to retain this personal information for these purposes. Should your child turn 18 before the end of this 3 year period, we will contact you at that time to ascertain your wishes. 

  • Mailing list recipients and other contacts records are kept for 3 years from the last contact

  • Financial records are kept for 7 years after the end of the financial year to which each pertains

  • If you have subscribed to our mailing list but later unsubscribe, no further marketing materials will be sent, however we may still hold your personal data on file for the purposes of doing business with you. If you would like your personal information to be completely removed from our database you can request this at any time

 

You and your child also have rights under data protection legislation (explained more fully below) which include the right to request us at any time to delete such personal information as we have retained. 

9. Your and your child’s rights 

The law gives you and your child important rights over how NKYO uses your personal information. These are: 

  • the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this Privacy Policy

  • the right of access. You have the right to access the data that we hold and to receive a copy of your data and information about where it was sourced. To do so, you should make what is known as a subject access request. You can contact NKYO at the address at the beginning of this policy if you wish to do this. The Information Commissioner’s Office (ICO) publishes information on Subject Access Requests which may be of help to you – see https://ico.org.uk/your-data-matters/your-right-of-access/

  • the right for any inaccuracies in the data NKYO holds about you to be corrected 

  • the right to ask NKYO for your data to be erased, for example if you believe there is no longer any need for your data to be held for its original purpose, or if you decide to withdraw any consent that you have given for your data to be processed 

  • the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct 

  • the right to portability. You may transfer the data that we hold on you to another organisation for your own purposes 

  • you may have the right to object to the way we use your data if you do not agree that we are using it for our legitimate interests 

  • the right to regulate any automated decision-making and profiling of personal data

 

Where you have provided consent to NKYO using any of your or your child’s data, you also have the unrestricted right to withdraw that consent at any time. 

 

10. Applying your rights

 

Review your personal data

You have the right to request a copy of the information that we hold about you at any time. If you would like a copy of some or all of your personal information, you can email klezmeryouth@gmail.com. We will not charge you for this service unless the request is ‘manifestly unfounded or excessive or repetitive’. You can also use Tapmydata.com to find out what personal data organisations hold about you.

 

Unsubscribe
You can choose at any time to unsubscribe from marketing and fundraising communications by simply clicking the ‘unsubscribe’ link found in all of our marketing emails.

 

Stop processing
You also have a right to ask us to stop processing your personal data if your consent is required for that processing. To request this simply email klezmeryouth@gmail.com

 

Right to Erasure
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

 

Inaccurate Information
You can ask us to restrict the use of your personal information if:

  • it is inaccurate

  • it has been used unlawfully but you don’t want us to delete it

  • it is not relevant any more, but you want us to keep it for use in legal claims

  • you have already asked us to stop using your data but you are waiting for a response from us

 

11. Questions and complaints about this Privacy & Data Protection Policy

If you have any questions or concerns regarding our privacy and data protection policies, please send a detailed message to 

klezmeryouth@gmail.com. We would appreciate the opportunity to understand and correct any concerns you have. If, in the light of our responses, you believe that NKYO has not complied with your data protection rights, you can complain to the Information Commissioner. Their contact details can be found on their website: (www.ico.org.uk).