Helen O’Grady Academy Malta [INSERT COMPANY NUMBER AND ADDRESS], herein (“we”, “us”, “our” or “Helen O’Grady Malta”) and our affiliates respect your privacy and are committed to protection your personal data. Helen O’Grady Malta is part of an international group providing drama classes to students of all ages, herein the “Services”.
We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta) (the “Act”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), following its application on 25th May 2018 and any amendments thereto.
This Website is not directed towards children[PMG1] and is not intended to market its Services directly toward children. Any information submitted over this Website should be submitted by adults or the legal guardians of any minors wishing to attend any of our classes.
Purpose of this Notice
This Notice aims to give you information on how Helen O’Grady Malta, as defined above, collects and processes your personal data (i) when you use our Services and furthermore, (ii) through your use of this website (the “Site”), including any data you may provide via the Site
Helen O’Grady Academy [INSERT COMPANY DETAILS AND ADDRESS] is the controller and responsible for your personal data.
If you have any questions about this Policy, including any requests to exercise your legal rights as a data subject, please contact our Data Protection Contact Point (“DPCP”) using the details set out below.
You can address any comments, queries or complaints to the DPCP, using the details indicated below, with the words ‘Data Protection Matter’ in the subject line.
Our full details are:
Full name of legal entity: Helen O'Grady Malta
Email address: email@example.com
Postal address: The Helen O’Grady Academy Malta, 73, Middle Street, Siggiewi, SGW 1202, Malta
You have the right to lodge a complaint at any time to the competent supervisory authority in your jurisdiction on data protection matters. In the case of Malta, this is the Information and Data Protection Commissioner (“IDPC”) (https://idpc.org.mt/en/Pages/Home.aspx). We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
Changes to the Policy and Your Duty to Inform Us of Changes
This version of the Policy was lasted updated on 18/07/2018. It is imperative that the personal data we hold about you is accurate and current at all times. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and disclose different kinds of personal data about you which we have grouped together as follows:
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or in order to register you as a member and you fail to provide that data when requested, we may not be able to perform the contract which we have or which we are otherwise trying to enter into with you (namely regarding your registration as a member of our voluntary organisation). In such a case, we may have to cancel, or otherwise refuse to process your enrolment form.
If you Choose Not to Provide Your Consent
In certain cases you shall be asked to provide your consent in order for us to process certain personal data, in particular Sensitive Data. We shall only process such Sensitive Data for the purpose specified in the enrolment form available on our website, namely to ensure health and safety of our students.
Should you choose not to provide your consent, we shall be unable to process such personal data and therefore you will not be able to submit this information without providing your explicit consent.
You may choose to withdraw your consent to us processing such Sensitive Data at any time. In the event that you choose to withdraw your consent we shall cease to process such personal data and you assume full responsibility for any consequences resulting from the withdrawal of your consent.
Sensitive Data will be accessible solely by authorised personnel as required for the safety of the student.
In case of emergency only, some details may be given to authorized personnel.Otherwise no personal and sensitive data will be passed on to third parties unless it is explicitly expressed in writing. No personal data related to any student shall be passed on third parties without your explicit consent, unless such third parties are medical professionals in cases where the student needs medical attention or in compliance with a lawful order issued by a competent regulatory or governmental authority, the Police or a court or tribunal.
We use different methods to collect data from and about you, including through:
(i). Direct Interactions: You may give us your Identity, Contact and Financial Data by engaging us to carry out our Services or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
(iii). Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including Identity and Contact Data from publicly availably sources, such as company registers and credit check databases.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
We have also identified what our legitimate interests are where appropriate
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
To enrol you as a student and enter into a contract with you
(b) Contact(c) Financial
|(a) Take steps to enter into a contract with you|
a) To provide the Services you request;(b) Manage payment, invoicing and costs and collect and recover money owed to us.
a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us and prevent fraudulent transactions).
To manage our relationship with you, which will include:
(a) Notifying you about changes to our terms or this Policy.
(b) To resolve any issues which you have reported regarding your membership
(c) To inform you of any material developments, in particular in case of an emergency
(c) Specific Child Data
(a) Performance of a contract with you.
(b) Necessary for compliance with our legal obligation
|To administer our Site (including troubleshooting, data analysis, testing, system maintenance, support, safety and security testing, reporting and hosting of data).||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and prevention of hacks and other attacks
|To ensure the health and safety of our students and take steps in case of an emergency||
(c) Specific Child Data(d) Sensitive Data
|(a) Processing is carried out on the basis of consent|
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below, strictly for the purposes set out in the table in paragraph 4 above. These include:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Furthermore, these third parties and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.
We may also disclose your data if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority.
We may also disclose your data to enforce our contractual terms with you, or to protect our rights, property or safety, that of our partners or other users of the Site and Services. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
We may transfer your personal data to our parent company Helen O'Grady CI Limited located at Helen O'Grady CI Limited, North Side, Vale, Guernsey, GY3 5TX,, United Kingdom]. Such transfers are carried out in furtherance of our legitimate interest to consolidate internal reporting and accounting procedures and promote business efficiency.
We do not transfer your personal data outside the European Economic Area (EEA).
We may transfer any personal data we hold to a country outside the EEA provided that:
If we have to transfer your data outside the EU for any other reason, we shall ensure that the necessary safeguards are in place to legitimise such transfers of personal data.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In particular we use Secure Socket Layer (SSL) technology to ensure the security of any information passed over our Website.
In addition, we limit access to your personal data to those employees, agents, contractors, partners, service providers and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a strict and rigid duty of confidentiality.
Furthermore, we have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so, and within the timeframe prescribed at law.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By and large, retention of most data shall not exceed the period of six (6) years from the date of termination of your membership with us. This period of retention enables us to use the data for the defence of possible future legal claims (taking into account the applicable prescriptive period at law, plus a slight grace period past the expiry of prescription). In certain cases, we may retain your data for a period which will not exceed ten (10) years from the date of termination or completion of the Services and this will be retained in order for us to comply with applicable accounting and tax laws.
Whenever and to the extent possible, we anonymise the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you.
In some circumstances, we may even anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further Policy to you.
You have the right to:
a) there is no good reason for us continuing to process it;
b) you have successfully exercised your right to object to processing (see below);
c) we may have processed your information unlawfully; or
d) we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
a) if you want us to establish the data's accuracy;
b) where our use of the data is unlawful but you do not want us to erase it;
c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Google Analyticis
So as to improve the quality and overall user experience of the Website, we are using Google Analytics Advertising Features, including Google Universal Analytics.
We use these analytical tools in order to calculate information relating to the number of visitors to our Website as well as how users interact with our Website, including how long they spend browsing our Website.
If you would like to opt-out of Google Analytics for display advertising, you may do so by using the Ads Preference Manager. In addition, there is also a Google Analytics Opt-Out browser add-on that you can download at https://tools.google.com/dlpage/gaoptout.
Any changes that we may make in the future to this Policy will be visibly posted on the Site and, if appropriate, notified to you via email.
Address: The Helen O’Grady Academy Malta, 73, Middle Street, Siggiewi, SGW 1202, Malta
Please check back frequently to see any updates or changes to this Policy.