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Inclusive Music Ltd 

Company number 09226402 


Policies



1. GDPR Privacy Policy

2. Equality, Diversity & Inclusion Policy

3. Safeguarding Policy


GDPR Privacy Policy

Introduction

Thank you for choosing to be part of our community at Inclusive Music. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at info@inclusivemusic.com


When you visit our website https://learning.inclusivemusic.com/ and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our site and our services.


This privacy policy applies to all information collected through our website.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.  

Table of contents

  1. WHAT INFORMATION DO WE COLLECT? 

  2. HOW DO WE USE YOUR INFORMATION? 

  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

  5. DO WE USE GOOGLE MAPS?

  6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

  7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

  8. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

  9. HOW LONG DO WE KEEP YOUR INFORMATION? 

  10. HOW DO WE KEEP YOUR INFORMATION SAFE? 

  11. DO WE COLLECT INFORMATION FROM MINORS?

  12. WHAT ARE YOUR PRIVACY RIGHTS?

  13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

  14. DO WE MAKE UPDATES TO THIS POLICY?

  15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?


WHAT INFORMATION DO WE COLLECT? 


Personal information you disclose to us  


In Short: We collect personal information that you provide to us such as name, contact information, company and login data.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we COLLECT can include the following: 

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor (Stripe) and you should review its privacy policies and contact the payment processor directly to respond to your questions.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.  


Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our website. 


We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes. 


HOW DO WE USE YOUR INFORMATION? 


In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.


We use personal information collected via our Site for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.  


We use the information we collect or receive:  


  • To facilitate account creation and logon process [with your Consent]


  • To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below). 


  • To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual]. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.


  • Fulfill and manage your orders [for Contractual reasons]. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Site.


  • To post testimonials [with your Consent]. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at info@inclusivemusic.com and be sure to include your name, testimonial location, and contact information.


  • Deliver targeted advertising to you [for our Business Purposes and/or with your Consent]. We may use your information to develop and display content and advertising tailored to your interests and/or location and to measure its effectiveness. 


  • Administer prize draws and competitions [for our Business Purposes and/or with your Consent]. We may use your information to administer prize draws and competitions when you elect to participate in competitions.


  • Request Feedback [for our Business Purposes and/or with your Consent]. We may use your information to request feedback and to contact you about your use of our Site. 


  • To protect our Site [for Business Purposes and/or Legal Reasons]. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).


  • To enable user-to-user communications [with your consent]. We may use your information in order to enable user-to-user communications with each user's consent.


  • To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or possibly Contractual].


  • To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.


  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Site, products, services, marketing and your experience.


WILL YOUR INFORMATION BE SHARED WITH ANYONE? 


In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. 


We only share and disclose your information in the following situations:


  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).


  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. 


  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. 


  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


  • With your Consent. We may disclose your personal information for any other purpose with your consent.


  • Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Site) or otherwise interact with public areas of the Site, such personal information may be viewed by all users and may be publicly distributed outside the Site in perpetuity. 


DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 


In Short: No


DO WE USE GOOGLE MAPS?


In Short: No


HOW DO WE HANDLE YOUR SOCIAL LOGINS?


In Short: We don’t.


IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?  


In Short: No


WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?


In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites. 


The Sites may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.


HOW LONG DO WE KEEP YOUR INFORMATION? 


In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. 


We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 90 days past the termination of your account.


When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


HOW DO WE KEEP YOUR INFORMATION SAFE? 


In Short: We aim to protect your personal information through a system of organizational and technical security measures. 


We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment. 


DO WE COLLECT INFORMATION FROM MINORS? 


In Short: We do not knowingly collect data from or market to children under 18 years of age. 


We do not knowingly solicit data from or market to children under 18 years of age. By using the Site, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site.

Please note: In order that we do not collect any data from anyone under the age of 18 who subscribes to a course, we strongly advise that they sign up with a fake ID. For example:

First name or initial can be any single letter from the alphabet e.g. A

Surname can be any single letter from the alphabet e.g. Z

Email can be az@example.com


Using @example.com is a safe and well practiced internet protocol


If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at info@inclusivemusic.com. 



WHAT ARE YOUR PRIVACY RIGHTS?


In Short: [In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.] You may review, change, or terminate your account at any time. 


[In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided - info@inclusivemusic.com. We will consider and act upon any request in accordance with applicable data protection laws. 


If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.


If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm] ]


[Account Information

You may at any time review or change the information in your account or terminate your account by:

  • Logging into your account settings and updating your account

  • Contacting us using the contact information provided below

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.]


Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Site visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by: 

  • Noting your preferences at the time you register your account with the Sites.

  • Logging into your account settings and updating your preferences.

  • Contacting us using the contact information provided below


DO WE MAKE UPDATES TO THIS POLICY?


In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.


We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 


HOW CAN YOU CONTACT US ABOUT THIS POLICY?


If you have questions or comments about this policy, email phil@inclusivemusic.com or by post to:

Inclusive Music

Lighthouse View

Azure, Headland Rd

Newquay

Cornwall

UK


If you have any further questions or comments about us or our policies, email us at phil@inclusivemusic.com or contact us by post at the address above.

Last updated 01 07 20


EQUALITY, DIVERSITY & INCLUSION POLICY


Inclusive Music is committed to inclusion, equality and diversity and actively supports practices that promote genuine equality of opportunity for all young people and school staff.


Phil Heeley is a sole trader operating as Inclusive Music Ltd, and I am not planning to employ any members of staff at this stage or for the foreseeable future. However, the services I provide put me into positions of trust and confidentiality with a large number of people. This policy therefore sets out my aims, values and practice around the issue of equality, diversity and inclusion. 


Definitions


Equality is about creating a fairer society where everyone has the opportunity to fulfil his or her potential.

Diversity is about recognising and valuing difference in its broadest sense.

Inclusion is about access and engagement, enabling each individual to feel valued as an integral part of society.


Aims 

We are wholeheartedly committed to the principle of equality of opportunity as a provider of services to others. We aim to provide services to all irrespective of gender, race, disability, age, sexual orientation, religion, belief, gender reassignment, pregnancy and maternity or marital or civil partnership status. 

We look to ensure that my practice is in the service of the celebration of human difference and diversity and that at no time is my practice used as a means of coercion or oppression of any group or individual.

We aim to be supportive, fair, just and free from discrimination. 


I support:

The UK Department for Education’s equality and diversity objectives, statements and policies

The United Nations agencies treaties such as the Convention on the Rights of Persons with Disabilities

The United Nations - Vision for an Inclusive Society


Objectives : 

  • To narrow the achievement gap for children and young people, including children in care, by ensuring increased opportunities and improved outcomes

  • To help children to fulfil their full potential, by supporting families and focusing support on improving the lives of the most vulnerable children, including those who experience bullying or exclusion

  • To eliminate barriers to education and promote reform in the culture, policy, and practice in schools to include all students


Values

  • All individuals have a fundamental right to education. A principle that values students’ wellbeing, dignity, autonomy, and contribution to society 

  • Respect is given to the individual and common humanity of all people 

  • Relationships shall be carried out without discrimination on the basis of race, religion or belief, colour, creed, disability, nationality, socio-economic status, gender or gender reassignment, age, sexual preference or orientation, or any other form of diversity 

  • Physical, psychological and social violence and oppression are opposed

  • Students are encouraged to be aware of their relationship to the world around them and to choose effectively their own responses and be responsible in their behaviour 

  • These values and subsequent actions are to enhance the well-being of individual students and society

  • We aim to conduct my activities in ways that reflect the values listed above and the practices listed here




Practice 


  • Teaching is planned with all students in mind 

  • We aim to create an environment which supports all students’ learning and encourages students to support each other in their learning 

  • Lessons encourage the participation of all students and all students are treated equally as valued members of the class

  • We ensure students feel that their opinions and views are valued 

  • Through a flexible and accommodative curriculum, I ensure that all students can access learning in all lessons through differentiation and are actively involved in their own learning 

  • We aim to ensure that all students are engaged in all lesson activities and enjoy their music lessons

  • We aim to ensure that all students achieve their learning according to their individual ability and offer support when students experience difficulties 

  • We aim to ensure that all children including the vulnerable, are successful in their learning 

  • Classroom discipline is based on mutual respect and healthy living

  • We monitor our language, both spoken, written and non-verbal, for inadvertent discrimination 

  • We constantly seek to enhance my own awareness of possible areas of discrimination 

  • We aim to challenge, in a supportive way, any student or staff whom I perceive to be using discriminatory behaviour 

  • We avoid knowingly discriminating on any grounds 

  • We engage in developmental activities that are likely to increase my self-awareness, especially in relation to diversity 


Communication of this policy 

This policy will be communicated to my clients and potential clients via the company website: https://learning.inclusivemusic.com

This policy is subject to continual review, and at least annually, in order to ensure it remains current and appropriate.

Equality, Diversity & Inclusion Policy – September 2019


Safeguarding Policy


Inclusive Music abides by the duty of care to safeguard and promote the welfare of children and young people and is committed to safeguarding practice that reflects statutory responsibilities, government guidance and complies with best practice requirements.

  • We recognise the welfare of children is paramount in all the work we do and in all the decisions we take

  • All children, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation has an equal right to protection from all types of harm or abuse

  • Some children are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues

  • Working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare.


Purpose:

Inclusive Music will:

  • Protect children and young people who receive Inclusive Music’s services

from harm. This includes the children of adults who use our services

  • Provide staff and volunteers, as well as children and young people and their families, with the overarching principles that guide our approach to child protection.


This policy applies to anyone working on behalf of Inclusive Music, including senior managers and the board of trustees, paid staff, volunteers, sessional workers, agency staff and students. Failure to comply with the policy and related procedures will be addressed without delay and may ultimately result in dismissal/exclusion from the organisation.

 

Definitions:

The Children Act 1989 definition of a child is: anyone who has not yet reached their 18th birthday, even if they are living independently, is a member of the armed forces or is in hospital.


Adult at Risk:

An adult who has needs for care and support (whether or not the authority is meeting any of those needs),

  • is experiencing, or is at risk of, abuse or neglect, and

  • as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it.


Child and Adult Abuse: Children and adults may be vulnerable to neglect and abuse or exploitation from within their family and from individuals they come across in their daily lives. There are 4 main categories of abuse, which are: sexual, physical, emotional abuse, and neglect. It is important to be aware of more specific types of abuse that fall within these categories, they are:


  • Bullying and cyberbullying

  • Child sexual exploitation

  • Child Criminal exploitation

  • Child trafficking

  • Domestic abuse

  • Female genital mutilation

  • Grooming

  • Historical abuse

  • Online abuse


Safeguarding children: Safeguarding children is defined in Working Together to Safeguard Children 2018 as: 


  • protecting children from maltreatment. 

  • preventing impairment of children’s health or development.

  • ensuring that children are growing up in circumstances consistent with the provision of safe and effective care.

  • taking action to enable all children to have the best outcomes.


Legal Framework:

This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in England. A summary of the key legislation is available from nspcc.org.uk/learning.



Training and Awareness: 

Inclusive Music will ensure an appropriate level of safeguarding training is available to its Trustees, Employees, Volunteers and any relevant persons linked to the organisation who requires it.


For all employees who are working or volunteering with children, this requires them as a minimum to have awareness training that enables them to: 


  • Understand what safeguarding is and their role in safeguarding children.

  • Recognise a child potentially in need of safeguarding and take action.

  • Understand how to report a safeguarding Alert.

  • Understand dignity and respect when working with children.

  • Have knowledge of the Safeguarding Children Policy.


Confidentiality and Information Sharing:

Inclusive Music expects all employees, volunteers and trustees to maintain confidentiality.  Information will only be shared in line with the General Data Protection Regulations (GDPR) and Data Protection. See (Inclusive Music’s GDPR policy).


However, information should be shared with the Local Authority if a child is deemed to be at risk of harm or contact the police if they are in immediate danger, or a crime has been committed


Recording and Record Keeping:

A written record must be kept about any concern regarding an adult with safeguarding needs. This must include details of the person involved, the nature of the concern and the actions taken, decision made and why they were made.


All records must be signed and dated. All records must be securely and confidentially stored in line with General Data Protection Regulations (GDPR). See (Inclusive Music’s GDPR policy).


Safe Recruitment & Selection:

Inclusive Music is committed to safe employment and safe recruitment practices, that reduce the risk of harm to children from people unsuitable to work with them or have contact with them. 


  Use of Mobile Phones and other Digital Technology:

All employees, trustees and volunteers should be aware of Inclusive Music’s policy and procedures regarding the use of mobile phones and any digital technology and understand that it is unlawful to photograph children and young people without the explicit consent of the person with parental responsibilities.


Whistleblowing:

It is important that people within Inclusive Music have the confidence to come forward to speak or act if they are unhappy with anything. Whistleblowing occurs when a person raises a concern about dangerous or illegal activity, or any wrong-doing within their organisation. This includes concerns about another employee or volunteer. There is also a requirement by Inclusive Music to protect whistleblowers.


Contact:

Senior Lead for Safeguarding
Name: Phil Heeley
Email address: Phil@inclusive Music.com