D Sharp Music Academy Privacy Policy
Online and in-person music coaching
Effective date 29 September 2026
Last reviewed 29 September 202This Privacy Policy explains how dsharpmusic academy (the Academy, we, us or our) collects and uses personal information when you enquire, book or receive singing, piano or keyboard, performance, songwriting, production or related coaching, whether online or in person. It also covers use of our website, discovery sessions, events and marketing communications.
We aim to use only the information reasonably needed to provide a premium, personalised and safe service. We do not sell personal information. This policy should be read with our Terms and Conditions and, where relevant, our Cookie Notice and Safeguarding Policy.
Publication requirement: complete the controller identity and contact details in section 2, confirm the actual suppliers and retention periods in the publication checklist, and obtain UK legal review before this policy goes live.
1 Who this policy applies to
This policy applies to prospective and current clients, students, parents or guardians, website visitors, event participants and people who communicate with us. The person paying for coaching may be different from the student. Where a student is under 18, we normally deal with their parent or legal guardian as the client and collect only the child's information needed for tuition, safety and safeguarding.
It does not govern the independent privacy practices of a venue, examination board, payment provider, video-call platform or other organisation acting as its own controller. Their own privacy information may also apply.
2 Who is responsible for your information
The data controller is Darren Edwards, trading as dsharpmusic academy.
Contact email: hello@dsharpmusic.com
We have not appointed a Data Protection Officer unless stated on our website. Privacy questions and requests should be sent to the contact above.
3 Information We Collect
| Category | Examples |
|---|---|
| Identity and Contact | Name, age or date of birth where relevant, postal address, email address, telephone number, preferred contact method and parent or guardian details. |
| Enquiry and Booking | Goals, instrument or voice type, experience, availability, chosen service, lesson format, venue, booking history and correspondence. |
| Coaching and Progress | Attendance, lesson notes, repertoire, exercises, assessments, goals, feedback, progress, practice plans and materials shared with us. |
| Payment and Transaction | Amounts, dates, invoices, refunds, billing status and limited payment references. Full card details are normally collected directly by the payment provider, not by us. |
| Online Lessons and Technical | Account or display name, email address, meeting metadata, device, IP address, connection and diagnostic information. Live audio and video pass through the chosen platform. |
| Health and Access | Only information you choose or need to provide for safe participation or reasonable adjustments, such as a vocal injury, hearing concern, respiratory issue, disability or access need. As a minimum, please do not smoke or vape in the 24 hours immediately before your session. Out of consideration for other clients in the chamber, we ask that you arrive without the smell of smoke on your clothes, hair, or breath. Staff may ask you to reschedule if this is not the case. |
| Safeguarding and Emergency | Age, emergency contact, collection arrangements, relevant concerns, incident records and communications with a parent, venue or authority where necessary. |
| Recordings and Media | Audio, video, photographs, testimonials or performance material where recording or use has been separately agreed. |
| Website and Communications | IP address, browser, device, pages viewed, cookie choices, form submissions, email engagement and marketing preferences. |
| Professional and Legal | Complaints, claims, insurance correspondence, permissions, contracts, consent records and information required for accounting, tax or legal compliance. |
Please do not send medical records or other highly sensitive information unless we specifically request it and it is necessary. You may choose not to provide optional information, but we may be unable to offer a requested adjustment or service if essential information is withheld.
4 How we collect information
Directly from you when you enquire, complete a form, book, pay, attend a discovery session or lesson, send material, give feedback, opt into marketing or contact us.
From a client, parent, guardian, student, referrer, employer, school, venue or collaborator where they arrange or support the service and are permitted to share the information.
Automatically through our website, booking system, email service and online lesson platform, subject to your cookie and device settings.
From payment providers and banks, usually as payment confirmation, transaction references, refunds or fraud-prevention information rather than full card details.
From public sources where relevant to a genuine business enquiry, professional collaboration or permissioned testimonial, and only where our use is lawful and reasonably expected.
5 Why we use information and our lawful bases
UK data-protection law requires us to have a lawful basis for each use. The basis depends on the purpose and circumstances. The table describes the bases we generally expect to use; the Academy must confirm these against its actual operations before publication.
|
Purpose |
Information |
Lawful basis |
|
Answer enquiries and arrange discovery sessions |
Contact details, goals, experience and availability |
Legitimate interests in responding to requests and developing our services; steps requested before entering a contract where applicable. |
|
Book and deliver coaching |
Identity, contact, booking, coaching and relevant online lesson data |
Contract, or steps requested before contract. |
|
Personalise tuition and track progress |
Goals, lesson notes, repertoire, exercises and feedback |
Contract and legitimate interests in providing consistent, high-quality coaching. |
|
Take payment and manage accounts |
Transaction, invoice, booking and contact data |
Contract; legal obligation for accounting and tax records; legitimate interests in preventing fraud and recovering sums due. |
|
Send service communications |
Contact and booking data |
Contract and legitimate interests in administering lessons, changes, reminders and support. |
|
Provide reasonable adjustments and protect health |
Relevant access or health information |
Explicit consent where appropriate; vital interests in an emergency; and other conditions permitted by law where applicable. |
|
Safeguard children or vulnerable people |
Identity, age, parent or guardian, incident and concern records |
Legal obligation, vital interests and legitimate interests in protecting welfare. Special-category or criminal-offence data requires an additional legal condition. |
|
Record a lesson for personal study |
Audio or video |
Contract where recording is requested as part of the agreed service, or consent where appropriate. No recording will be made secretly. |
|
Publish images, recordings or testimonials |
Name, image, voice, words and performance |
Separate, specific consent, withdrawable for future use. For a child, appropriate parental or guardian permission and safeguarding controls. |
|
Improve and secure services |
Usage, technical, communications and service feedback |
Legitimate interests in quality, security, troubleshooting and business improvement, balanced against your rights. |
|
Send electronic marketing |
Name, contact details, interests and preferences |
Consent where required by electronic marketing law; otherwise legitimate interests only where the law permits and after appropriate assessment. You can opt out at any time. |
|
Handle complaints, claims and legal duties |
Relevant account, communications, incident and transaction records |
Legal obligation and legitimate interests in establishing, exercising or defending legal claims. |
Where we rely on legitimate interests, we consider the purpose, necessity and likely effect on you. You may object to this processing; see section 13. Where we rely on consent, you may withdraw it at any time without affecting earlier lawful use.
6 Online lessons and recordings
Online lessons may be delivered using Zoom, Google Meet or Microsoft Teams. The platform may process account details, meeting metadata, IP address, device information and live audio or video under its own terms. We will use suitable security settings and will not publish private joining details.
Private sessions are not recorded by the Academy unless this is agreed in advance. Before recording, we will explain the purpose, who can access it, how it will be shared and when it will be deleted. A student recording supplied for personal practice must not be published or shared beyond the agreed use without permission.
For anyone under 18, recording requires prior written parent or guardian permission and must follow the Academy's safeguarding procedure. We avoid private messaging with a child and normally communicate through the parent or guardian or another agreed safeguarding channel.
7 Health, access and other sensitive information
Information about health, disability, ethnicity, religion, sexual orientation or similar matters may be special-category data. We do not seek it routinely. We process only what is relevant to safe coaching, an adjustment, safeguarding or a legal requirement, and only when both a general lawful basis and an additional special-category condition apply.
Where explicit consent is the appropriate condition, we will ask separately and record it. You can withdraw consent, although we may retain limited information where another legal duty or a safeguarding or legal-claims reason requires this.
8 Children and young people
The Academy primarily serves adults. Coaching for a person under 18 is offered only by prior agreement. We collect the minimum student and parent or guardian information needed to manage the lesson, communicate safely, provide appropriate tuition and meet safeguarding responsibilities.
A parent or guardian should make the booking and provide emergency and collection details. Marketing consent, testimonials and publicity permissions are separate from acceptance of lesson terms and are never a condition of receiving tuition. We do not knowingly create direct-marketing profiles for children.
A child may have data-protection rights in their own name depending on their age and understanding. We will consider the child's best interests, maturity, confidentiality and safeguarding obligations when responding to a request.
9 Who receives information
We share information only where necessary, proportionate and lawful. Recipients may include:
booking, calendar, customer-management, email, cloud-storage, website-hosting and IT-security providers;
video-call and online-teaching platforms used to deliver remote coaching;
payment providers, banks, accountants, tax advisers and debt-recovery services where lawfully required;
coaches, accompanists, contractors, studios and venues involved in an agreed service, subject to appropriate confidentiality and data-protection arrangements;
schools, employers, parents or guardians where they arrange the service or where sharing is necessary for attendance, safety or safeguarding;
insurers, solicitors, professional advisers, auditors and prospective purchasers of the business under suitable confidentiality controls; and
the police, courts, regulators, emergency services, local authorities or safeguarding bodies where the law requires or permits disclosure to protect rights, safety or welfare.
We do not sell or rent personal information. Service providers acting as processors may use information only on our documented instructions, subject to contract, security and confidentiality duties. Some organisations, such as banks or payment providers, may act as independent controllers for their own legal purposes.
10 International transfers
Some technology or support providers may store or access information outside the United Kingdom. Before making a restricted transfer, we will use a lawful transfer mechanism, such as UK adequacy regulations or approved contractual safeguards, and any additional measures reasonably required. You may ask for more information about the relevant safeguard, subject to lawful redactions.
11 How long we keep information
We keep information only as long as reasonably necessary for the purpose collected, including legal, accounting, safeguarding and claims requirements. The Academy must approve a working retention schedule and confirm the periods below before publication.
|
Record |
Proposed period |
Reason |
|
Unsuccessful enquiries |
Up to 12 months after the last meaningful contact |
Follow-up, service improvement and enquiry history, unless you ask us to delete sooner and no legal reason requires retention. |
|
Client, booking and lesson records |
For the coaching relationship and normally up to 6 years afterwards |
Service continuity and the usual limitation period for contract claims. |
|
Invoices, payments and tax records |
Normally 6 years after the relevant financial year, or longer if law requires |
Accounting and tax obligations. |
|
Routine lesson notes |
Reviewed annually and normally deleted or anonymised within 6 years after coaching ends |
Personalised tuition, quality and potential claims. |
|
Agreed private lesson recordings |
Delete after delivery or within 365 days. |
Personal study and secure transfer, unless a longer period is separately agreed. |
|
Publicity consent and published media |
For the stated campaign or until consent is withdrawn for future use; keep a minimal suppression record where needed |
To evidence permission and respect withdrawal. |
|
Marketing preferences |
Until opt-out; retain a minimal suppression record afterwards |
To avoid sending further marketing. |
|
Cookie and analytics data |
According to the Cookie Notice and consent tool |
Website operation, measurement and preferences. |
|
Safeguarding or serious incident records |
According to the Academy's safeguarding retention schedule and applicable guidance |
Protection of welfare, accountability and legal obligations; not a routine six-year deletion. |
|
Complaints and legal claims |
Normally 6 years after closure, or longer while a claim or investigation remains possible |
Establishing, exercising or defending legal rights. |
When deciding a period, we consider the amount, nature and sensitivity of the information, risk of harm, purpose, whether anonymisation is possible and relevant legal requirements. At the end of the period, we securely delete or anonymise the information, unless lawful preservation is required.
12 Security
We use proportionate technical and organisational measures designed to protect information from loss, misuse, unauthorised access, alteration or disclosure. Measures may include access controls, strong authentication, device and account security, secure payment handling, appropriate backups, confidentiality arrangements and provider due diligence.
No internet transmission or storage system is completely secure. If a personal-data breach is likely to risk people's rights and freedoms, we will assess it promptly and notify the Information Commissioner's Office and affected individuals where the law requires.
13 Your data protection rights
Depending on the circumstances, you may have the right to:
be informed about how we use your personal information;
request access to personal information we hold about you;
ask us to correct inaccurate or incomplete information;
ask us to erase information where there is no lawful reason to keep it;
ask us to restrict how information is used;
receive information you provided in a structured, commonly used, machine-readable format and ask us to transfer it where the right to data portability applies;
object to processing based on legitimate interests and object at any time to direct marketing;
withdraw consent at any time where consent is the basis; and
ask for safeguards where a significant decision is made solely by automated means. We do not currently make such decisions about coaching clients.
To exercise a right, contact us using section 2. We may ask for information needed to confirm identity and authority. We normally respond within one month, although the law allows an extension for complex or multiple requests. Rights are not absolute, and we will explain any lawful refusal or limitation.
14 Marketing
We may send news, coaching insights, offers or event information only where permitted. Where consent is required, the choice will be specific, informed and separate from the purchase of coaching. You can unsubscribe using the link in an email or contact us at any time. Opting out of marketing does not stop necessary messages about an enquiry, booking, payment, lesson or safety matter.
We do not buy or sell marketing lists. If referral partners or social platforms are used for advertising, the Academy must describe the actual arrangement and cookie choices before launch.
15 Website cookies and analytics
Our website may use essential cookies needed for security, navigation, booking or payment. Non-essential analytics, advertising or similar technologies will be used only after any consent required by the Privacy and Electronic Communications Regulations. You can manage non-essential choices through the site's cookie controls and withdraw consent as easily as you gave it.
A separate Cookie Notice should identify each cookie or technology, provider, purpose and duration. Browser settings may also block cookies, although some website features may then work less effectively.
16 Complaints
Please contact us first so we can try to resolve your concern. You also have the right to complain to the Information Commissioner's Office, the UK data-protection regulator, at www.ico.org.uk or by telephone on 0303 123 1113. If you live outside the UK, you may also have the right to contact your local data-protection authority.
17 Changes to this policy
We may update this policy when our services, suppliers or legal obligations change. The current version will be published on our website with its effective date. If a change is significant, we will take reasonable steps to bring it to the attention of affected people. Earlier versions may be requested where reasonably available.