Guildhall School of Music & Drama - Report + Support Privacy Notice
Guildhall School of Music & Drama (“Guildhall School”, “the School”, “we” “us”, or “our”)is a department of the City of London Corporation (“the City Corporation”). This privacy notice covers those activities in respect of the Report + Support tool at Guildhall School and administered independently of other departments in the City Corporation. The City Corporation’s privacy notice can be found at their website.
Guildhall School is committed to protecting your privacy; this privacy notice explains how we use information about you and how we protect your privacy in respect of the Report + Support tool. If you have any concerns or questions about how the School looks after your personal information please contact the City Corporation’s Data Protection Officer, at information.officer@cityoflondon.gov.uk or alternatively contact the School [see our website for most up to date contact details].
The Report + Support tool is run by the School’s Registry and HR teams. If you have any questions about Report + Support and its use at Guildhall School please contact Casework@gsmd.ac.uk
Guildhall School acts as a controller in respect of the Report + Support tool, as we determine the purpose and the manner that any personal data is, or is likely to be, processed. This means that we are legally responsible for the personal data we collect and hold about you.
One of our responsibilities is to tell you about the different ways in which we use your personal data and your rights in relation to the information that you, or someone else provides, about yourself. Please see Section 3 of this notice for a detailed breakdown of the data processing.
One of our responsibilities is to tell you about the different ways in which we use your personal data and your rights in relation to the information that you, or someone else provides, about yourself. Please see Section 3 of this notice for a detailed breakdown of the data processing.
This privacy notice supplements the following Guildhall School of Music & Drama privacy notice:
Please note – this privacy notice was updated in September 2024
The Report + Support tool at Guildhall School of Music & Drama
The Report + Support tool at Guildhall School of Music & Drama provides staff, students and visitors with a portal to report and seek support in respect of issues including bullying, harassment and sexual misconduct.
It enables the School, where appropriate, to manage and act on those reports as well as gather aggregated data for future preventative work. Please note that where data has been aggregated this data has been sufficiently anonymised and will not identify an individual.
The Report + Support tool is not designed to be used when reporting potential safeguarding or criminal offences to Guildhall School which may relate to an individual's criminal convictions and offences. If you become aware of a safeguarding issue or wish to report criminal offence data, please follow the procedures set out in Guildhall School’s Safeguarding Policy.
- There may be occasions where the School is legally obliged to provide information to an official authority. For example, if criminal offence data has been provided, we will share the information to the relevant bodies, for example the police.
- What happens if I am reported?
If you’re reported, then what happens to your data will usually depends on whether the reporting party wants a formal investigation or for it to be resolved informally. However, there are certain circumstances in which the School may take steps such as those provided in this privacy notice in relation to an anonymous report and/or where the reporting party has stated they do not wish any further action to be taken. We will usually do this when we are concerned for their safety or the safety of others, or where there is a pattern identified and action is necessary in relation to our duty of care to staff and/or students, or our obligations as an employer. - Formal Investigation
The report will be forwarded on to the relevant teams (Student Conduct & Appeals for students and Human Resources for staff) and your data will be shared as above in 1 – 6. - Informal Resolution
Each case will be considered on an individual basis and where a reporting party only wishes for support then no further action will be taken other than for safeguarding purposes. Where there are safeguarding concerns and/or the reporting party wishes for an informal resolution such as a No Contact Agreement or mediation then the person who is reported will be contacted and your data will be shared as above in 1 – 6.
Your personal data
Personal data is anything that directly or indirectly identifies and relates to a living person, such as a name, address, telephone number, date of birth, unique identification number, photographs, video recordings (including CCTV) etc.
Some personal information is ‘special category data’ and needs more protection due to its sensitivity. In the context of the School’s activities, this includes any information about an identifiable individual that can reveal their physical or mental health, sexuality and sexual health, religious or philosophical beliefs, racial origin or ethnicity. Personal information relating to criminal offences and convictions, although not ‘special category data’, is still sensitive in nature and merits higher protection.
Reports may be made by staff, students and visitors
The Report + Support tool at Guildhall School of Music & Drama provides a means to make a report and also seek support in respect of issues including harassment and sexual misconduct.
In both cases, any personal data processed by Guildhall School through Report + Support is voluntarily provided by the staff, students or visitors making those reports.
Reports may be made
(a) on an anonymous basis, whereby no names or other information that could be used to identify the individual making the report or a third party are provided.
Please note that where we receive an anonymous report containing third-party information, Guildhall School may not take further action on that information, unless we are concerned for your safety or the safety of others, or where there is a pattern identified and action is necessary in relation to our duty of care to staff and/or students, or our obligations as an employer.
(b) including names and contact details.
In respect of any submissions made, we note that the following personal data may be processed (if provided):
- Name
- Student ID Number
- Contact details – e.g. email address, phone number
- Department
- Gender
- Names and contact details of third parties (as applicable)
- Details of the complaint, including bullying, harassment and sexual misconduct
In respect of any submissions made, we note that the following ‘special category data’ may be processed (if provided):
- Ethnicity
- Religious
- Health and disability
- Sexual life or sexual orientation.
- Political opinions
Why do we need your personal data?
We will collect and process the above data (where provided) about you, for the following purposes:
- To enable the School to manage and administer the process as effectively as possible.
- For use by the School in reviewing and investigating complaints.
- Please note we will not normally take steps such as investigating the report, initiating disciplinary proceedings or passing information on to third parties in order to take the report further unless: (a) you have made a named report; and (b) you agree to this action.
- We will also process the names and other details about third parties who are involved in the issues reported or named in the report. If the decision is made to investigate the contents of the named report, we will contact the named individuals accordingly.
- To respond to any communication received from yourself.
Where data has been anonymised and aggregated this data will be used for the purposes of:
- Internal reporting, to undertake statistical analysis of instances.
- However, there are certain circumstances in which the School may take steps such as those listed above including investigating, initiating disciplinary proceedings or passing information to relevant third parties in relation to an anonymous report and/or where you have stated you do not wish any further action to be taken. We will usually do this when we are concerned for your safety or the safety of others, or where there is a pattern identified and action is necessary in relation to our duty of care to staff and/or students, or our obligations as an employer.
How the law allows us to use your personal data
Consent
If we have consent to use your personal data for any particular reason, you have the right to remove your consent at any time.
If you want to remove your consent, please contact information.officer@gsmd.ac.uk and tell us about the comment raised, so we can respond to your request.
Legitimate interest
As an organisation, we must ensure the safety and wellbeing of our community and comply with legal obligations. Details disclosed in your report may be used to understand trends of behaviours or incidents. This data may be used to develop policies, procedures or interventions.
Your rights regarding your personal data
As an individual whose data we process, you have certain rights in relation to that processing of your data.
To find out more about how the School deals with your personal information, including your rights and who to contact if you have a concern, please see the School’s privacy notices page.
You can ask us to:
- provide you with a copy of the personal data that we hold about you;
- correct personal data about you which you think is inaccurate;
- delete personal data about you if you think we no longer should be using it;
- stop using your personal data if you think it is wrong, until it is corrected.
Who do we share your personal data with?
Where you make a report through the Report + Support tool, Guildhall School of Music & Drama will disclose information to its staff members in the relevant departments on a need-to-know basis only.
We will not normally take steps such as investigating the complaint, initiating disciplinary or other formal proceedings (including litigation), or passing information on to third parties in order to take the report further unless you have made a named report, and you have asked for and consented to this action. However, there are certain circumstances in which the School may take steps such as those provided in this privacy notice in relation to an anonymous report and/or where the reporting party has stated they do not wish any further action to be taken. We will usually do this when we are concerned for their safety or the safety of others, or where there is a pattern identified and action is necessary in relation to our duty of care to staff and/or students, or our obligations as an employer.
Where criminal offence data are provided unsolicited, we will forward the information to the appropriate Guildhall School department in line with the School’s Safeguarding Policy and redact it from the report.
Our basis for sharing it:
- Both ours and your legitimate Interests to enable you to access the platform to report bullying, harassment etc. and to enable us to act on those reports and for administration purposes.
- Reasons of substantial public interest: such as safeguarding of children and individuals at risk.
- Where we have your consent to share it.
- To prevent or detect unlawful acts.
- To protect the public against dishonesty.
- For statutory and government reporting purposes.
- To enable us to establish, exercise or defend legal claims
Who we share it with internally:
- Appropriate data-sharing between internal teams on a need-to-know basis for the purpose of providing support and investigating the report. Depending on the nature of the report, such teams will be likely to include Student Services teams such as Student Conduct & Appeals, Counselling & Mental Health support, Advice Welfare and Well Being and Disability Support, and International Student Advice.
- Human Resources and managers (including Line Managers and Senior Management) on a need-to-know basis.
- Guildhall School’s Students’ Union where the situation involves their premises, staff or their activities.
Who we share it with externally:
- The Culture Shift Report + Support Platform we use.
- The police/social care services/local authorities/other similar bodies, where appropriate.
- Guildhall School consultants and professional advisors, such as legal advisors.
- Relevant Government Departments to fulfil our legal obligations, for example, under the Equality Act.
- Courts & Tribunals.
How do we protect your personal data?
All our third-party service providers and other entities in the School group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place measures to encrypt and protect the security of your information.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, or altered or disclosed while utilising Report + Support. In addition, we limit access to your personal information to those employees who need to know and have been trained to utilise the data and the system. They will only process your personal information on our instructions, in accordance with School procedures surrounding investigations of this type, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Where do we store your personal data?
We use a third party platform, HubSpot owned by Culture Shift, to support our Report + Support management. HubSpot uses the Google Cloud Platform (GCP) in the UK to support the processing of local customer data in the UK. This means your personal data will not leave the protections of UK GDPR.
How long do we keep your personal data for?
The information provided will be retained for seven years from the date of submission in line with Guildhall School of Music & Drama’s records retention schedule.
Any information or speculation around criminal convictions and offences is removed before the report is processed and not retained on the Report + Support website. However, it will be processed elsewhere in Guildhall School for safeguarding purposes.
Contact us
If you need to get in touch with us about Report + Support please contact: casework@gsmd.ac.uk
If you have any questions about this privacy notice, please write to information.officer@gsmd.ac.uk