How we process your personal data
The terms “we” “us” “De Rosa” “De Rosa music” “The academy” “De Rosa Music academy” “De Rosa Music school” or any variant of these refer to De Rosa Music limited. Company registration number 08462385 (UK).
“Your information”, “your details”, “information”, “details” or any combination or variant of the above terms refer to information that may be deemed as information that could be used, on its own or in conjunction with other data, to identify an individual under the GDPR legislation.
De Rosa Music Academy
How we will process your data.
1. Students attending the De Rosa Music Academy
The personal identification data we hold on students and how we use it .
We will use the information that you give us for communication regarding lessons booked with us either at De Rosa Music or any peripatetic tuition performed on our behalf at a different location. We may use SMS messaging and/or email to communicate with you.
The purpose of our communication with you include:
- The initial organisation of music lessons for a student (child or adult)
- Ongoing communications regarding music lessons, and/or exams
- Changes to music lessons (e.g. scheduled times and/or days)
- Option of additional lessons at any time (e.g. Summer school or further additional tuition)
- Changes of teacher
- To send invoices in advance of the forthcoming term of tuition
- Collection of outstanding fee balances if applicable
- Failure of lesson fee payments by direct debit or other online payment method notifications
- Any issue regarding payments related to but outside tuition specifically e.g. instrument rentals or repairs
This list is not exhaustive.
In the case of students who are adults (over 18 years old at the time of booking) we retain your name, status (where given), gender, email address, telephone numbers (mobile and/or landline numbers).
Where students are under 18 years of age at the time of record creation, we will ask for a parent or guardian’s name and contact details as set out above on behalf of the student(s) being enrolled. We will also ask for the students name and current age for placement in an age and standard appropriate class.
We will contact the parent or guardian on behalf of all students under 18 years old.
We take student safety seriously and always act in accordance with our student safeguarding policy. Details of the safeguarding policy can be found here.
Legal basis of data processing.
We will process your data on the basis of consent regarding matters surrounding the music school & communications surrounding & specifically relating to the provision of this service or services (e.g. direct debits & our instrument rental scheme). Additionally we may process the data on the ground of legitimate interest as there may be instances where a third party purchases lessons as a gift. This may require an approach to make a booking at a pre-agreed date or time without initially obtaining consent from the student in advance (we will have obtained consent from the person making the booking on another’s behalf). If you are on our waiting list for lessons, we may also contact you termly to ask if you would still be interested in lessons.
Additional non-personal data we hold on enrolled students.
We will retain other (non-personal data) within our data records including, but not limited to, the day & time of your attendance, the number of attendances made, the teacher(s) you have, the instrument(s) you are learning and the standard of the classes you are currently in. This data is used exclusively for timetabling and administrative purposes within our organisation only. We do not share, sell or otherwise disclose the data we hold on you pertaining to tuition services to any non-essential third parties.
The only personal data we will share with a third party regarding tuition services is to Go Cardless who provide Direct Debit (DD) services on behalf of De Rosa Music.
In this instance we will request Go Cardless email you a link directly and you will fill in details of your bank account number, bank sort code & address to set up a DD for tuition with De Rosa Music.
We will be able to see the direct debit account with go cardless is set up and monitor account payments exclusively to De Rosa Music only (no other transactions are visible). We are the data controller for the tuition services, Go Cardless are the data controller & data processor for your DD transactions.
Removing your data from our records.
You have the right to request we permanently delete your information from our database at any point. Whether you currently have lessons through us or not. You may also request a copy of any & all personal data that we hold on you. We will make this data available to you on request with suitable I.D. in digital format. To request your data or to ask for it to be removed, please make your request by email to firstname.lastname@example.org.
For all waiting list data.
The data we hold on our students is gathered, with your consent, at the time of student digital record creation. This may be used to timetable a student at a later stage if you have agreed to be placed on our waiting list for future lessons.
Duration of waiting list data storage
We will keep your information on file for a maximum of 1 year (3 tuition terms) from the date of collection whereupon it will be permanently deleted without further contact with you. You may also ask us to remove your data from our records at any time.
De Rosa Music retail sales
How we will process your data.
All purchases made in-store at De Rosa Music are recorded electronically. We may ask you for your personal data for the following reasons.
1. We offer a paperless invoice option to all of our customers. We may ask for your first and last name, an email address and a contact telephone number (mobile and/or landline). We use this data to create a customer account for you under the first and last name provided by you. This information is gathered to enable our retail system to send you a sales receipt for your records by email.
You are not required to provide any personal information to us if you choose not to. This has no consequence on your consumer rights and we can, on request, provide you with a printed receipt instead.
Placing an order for non-stock items
We will ask for your name, email address and telephone number when we place an order for any item so we are able to call you on the item’s arrival. Typically this will be book(s) and/or small accessory orders but will cover all items regardless of size and value including those to be delivered.
2. We may additionally ask you for your home or delivery address (if different) in cases where goods are to be delivered either by courier, postal service or by our own delivery service.
3. We may also use your information to tell you about essential software updates to relevant products or other pertinent matters such as product recalls or safety information where applicable.
4. We may also register instruments for manufacturers extended warranty offers and may contact you to seek permission.
Purchases using retail finance
In order to authorise a credit application, we will need to gather personal information and pass it on to a third party for credit authorisation. Our current retail finance arrangements are with V12 Finance.
Finance companies will make a credit reference check as part of the finance agreement authorisation process. This process will use some or all of the personal data you provide to us depending on how the application is submitted to the finance company.
Personal information gathered during a credit application filled out in-store includes (but is not limited to):
- Your name
- Your address
- Your employment status
- Your employers details
- You income bracket (self declaration using income bands set by the Finance company)
- A declaration by you that the information provided is correct and can be used for a credit reference check
- A digital signature to confirm that you are fully informed of the contract you are entering in to, that the loan is affordable, that you freely provide your consent to the loan and you are aware of and agree to the pre-loan credit reference agency check.
Please note that regardless of the outcome, the check will appear in your credit reference agency history.
We offer an alternative option that allows your privacy to be further protected.
This method involves us requesting that V12 retail finance send you a link to the online credit application form via email to fill in yourself. In sending this link request we are sharing your personal data with a third party with your full knowledge and consent in order to fulfil a contract.
Once you receive the credit application form link from V12 retail finance, you then send the completed form for credit reference checking in the same way as the in-store process. All other details and consequences of the credit checking process itself remain the same.
Legal basis of data processing.
Under the circumstances listed above we will process your data on the basis of consent as you have provided us with the data at the point of sale with your full consent, and/or by contract where we need to contact you regarding stock availabilty and you have asked us to perform this task on your behalf.
This will also apply to credit applications where data is processed by a third party on your behalf as part of a contract.
Finally on legitimate interest as software updates can be beneficial to product owners who may not be aware of the option to upgrade. Upgrades are usually free of charge, we will tell you if there is a fee and explain what the cost is for. Where credit applications have been made, we will receive notification by email of the decision to either lend or not to lend. we do not receive any other information regarding the decision itself.
Online sales from the De Rosa Music website:
To transact your order, we gather your first and last name, your home and/or delivery address (if different), phone number and email. We also gather information about you in the form of cookies via the website.
Legal basis of data processing.
We gather this information on the basis of consent and/or on the basis of contract. Where we deliver your goods, we will pass your personal details to the courier company for delivery purposes only.
Abandoned shopping carts.
Where you enter your personal data in the required form fields but do not proceed to payment we may automatically gather your email address and process your data on the grounds of legitimate interest. We may contact you to offer a further opportunity to purchase your shopping basket item(s) a short time period after shopping cart abandonment.
De Rosa Music instrument rental scheme
In order to rent an instrument or item from De Rosa Music, we will ask for personal information about the person renting the product from us. We use your personal data for both ongoing communication and security purposes prior to any item leaving the store in this instance.
Legal basis of data processing for rentals.
We will process your data on the basis of consent as you have provided us with the data at the point of rental with your full consent, and/or by contract where we need to contact you regarding stock servicing or return as part of the rental agreement. Finally on legitimate interest as you may be entitled to a rebate if you decide to purchase an instrument in the future. Not all instruments qualify for our rebate scheme – please see rental T&C for full details.
A rental agreement is a formal contract between the hirer and De Rosa Music. In order to release an instrument to the hirer, we will ask for personal information as follows to create an account on our retail payment system:
- The name and daytime telephone number/mobile phone number of the hirer
- A form of either photo ID/driving licence or a utility bill/bank statement less than 3 months old showing the hirers current address
- A credit or debit card owned or controlled by the hirer, registered to the address presented in the documentation provided as ID. Credit card information is additionally gathered at this point
We use a mail order transaction process to further verify the card details and address details match. The credit card details are shared with the authorising card processing centre at this point.
We ask for an email address to send a link from Go Cardless, a third party who provide Direct Debit facilities to customers. The direct debit, once authorised in store, is set up to start from the start of the second month and to recur until the item on rent from us is returned.
Last policy update 18.06.2018