Privacy Notice

We are Raj Academy Conservatoire, a non-profit organization operating in the UK, Europe, USA and Canada. You can contact us at info(at)rajacademy.com.
Our main establishment in Europe is in the UK. This means our lead data protection supervisory authority is the Information Commissioner’s Office.
We are committed to safeguarding the privacy of our students, event participants, supporters and website visitors; here we explain how we will treat your personal information.

What do we do with your information?

When you register for a course or event, we ask you for the personal details we need to stay in contact with you and to run the program with proper care for your health and safety.

When you are a registered student on one of our courses, we keep ongoing records of our communication with you to monitor your learning progress and improve the support we can offer you as a team.

When you purchase something from us we ask you for the personal details we need to deliver your order.

When you browse our site, we automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system. Website usage information is collected using cookies.

With your permission we may send you emails about our activities and other updates.

In our legitimate interests, we may use records of your involvement with us to inform our business and to improve the relevance of any messages you agree to receive from us.

We retain the information you give us when you register for a program, or make a purchase or an inquiry, for a potentially indefinite period. If you have given your consent to receive marketing messages from us, we retain your contact details for that purpose for as long as consent is not withdrawn.

Consent

How do you get my consent?

We would like to send you information about our courses, events and other updates that may interest you. We will do so only if you opt in, such as by ticking a box on a form on our website.

How do I withdraw my consent?

If after you opt in you change your mind, you may at any time withdraw your consent for us to contact you for marketing purposes by emailing us at info(at)rajacademy.com. You may also use the ‘unsubscribe’ link in any of our marketing emails.

Your Rights

You have the right to withdraw your consent to receive marketing messages (as above).

You also have the right to request a copy of the information that we hold about you. If you would like a copy of your personal information please email us.

You may ask us to delete or correct information at any time.You have the right to complain to the ICO in the UK if you are not happy with the way we have handled your data.

Disclosure

We will not supply your personal information to anyone else for the purpose of direct marketing without your permission.

We may disclose your personal information if we are required by law to do so or if you violate our terms of service.

Any personal information we hold about you is stored and processed in line with the Data Protection Act 1998 and the EU General Data Protection Regulation (GDPR).

Any personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

Third-party services

Our WebSchool is hosted by Pathwright, whose privacy policy is here:
https://grow.pathwright.com/pages/privacy-policy.html

Our student database is provided by Ragic, whose privacy policy is here:
https://www.ragic.com/sims/reg/privacy.html

We keep records of student communications on a platform called Monday, whose privacy documentation is here:
https://monday.com/terms/all

The forms on our website are built and hosted by Wufoo. Our course and event payment processes are provided by chargify and Wufoo. They provide us with the systems that allow us to sell our services to you. Chargify’s privacy policy is here:
https://www.chargify.com/privacy-policy.

Wufoo’s privacy policy is here:
https://www.wufoo.com/privacy.

Our online donations are handled by donorbox, whose privacy policy is here:
https://donorbox.org/privacy.

Payment gateways and other payment transaction processors used by chargify, Wufoo and donorbox have their own privacy policies in respect of the information they require for your transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which they will handle your personal information.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction from either you or us. So when you proceed with a transaction involving the services of a third-party provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this privacy policy or our website’s terms of service.

For our email marketing we use Mailjet. They never sell lists or email addresses. Mailjet’s privacy policy is here:
https://www.mailjet.com/privacy-policy.

Links
When you click on links on our website, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

Cookies

What is a cookie?
A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website.

Cookies allow websites and applications to store your preferences so as to present content, options or functions that are specific to you. They also enable us to see information such as how many people use the website and what pages they tend to visit.We ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

How we use cookies
We may use cookies to:

  • Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website’s structure, design, content and functions.
  • Identify whether you are signed in to our website. A cookie allows us to check whether you are signed in to the site.
  • Test content on our website. For example, 50% of our users might see one piece of content, the other 50% a different piece of content.
  • Store information about your preferences. The website can then present you with information you will find more relevant and interesting.
  • Recognise when you return to our website. We may show you relevant content, or provide functionality you used previously.

Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.

Controlling cookies
You can use your web browser’s cookie settings to determine how our website uses cookies. If you do not want our website to store cookies on your computer or device, you should set your web browser to refuse cookies.

However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.Unless you have changed your browser to refuse cookies, our website will issue cookies when you visit it.

To learn more about cookies and how they are used, visit http://www.allaboutcookies.org.

Changes to this privacy policy

We keep our privacy policy under regular review, and we will place any updates on this web page. This privacy policy was last updated on 13th September 2018.
If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or if you simply want more information, contact us at info(at)rajacademy.com.

Questions and contact information

If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or if you simply want more information, contact us at info(at)rajacademy.com.

Complaints Policy

At Raj Academy we recognise that:

The purpose of this policy:

  • everyone who comes to us has the right to a high standard of service
  • those who come to us have the right to complain if they are not happy with the standard of service they receive
  • learning from complaints helps us to improve the service we provide.

The purpose of this policy and procedure is to:

  • help us to provide a service of the highest standard to all those who come to Raj Academy
  • help us to ensure that children and families using or wishing to use our service know they have a right to complain about our service if they need to
  • help us to deal with complaints in a positive way and use them to improve our service
  • set out the issues that could be covered under this procedure
  • set out the steps that children, young people and their families should take if they wish to make a complaint
  • set out how we can deal with complaints in a fair and consistent way.

This policy and procedure applies to all children, young people and families attending or wishing to attend Raj Academy Conservatoire Ltd.If anyone, whether staff member, volunteer, child/young person or family member, is concerned that a child or children may be at risk of harm, they should use Raj Academy’s child protection policy and procedures rather than this complaints policy or procedure.

We will seek to deal with complaints by:

  • defining clearly what we mean by a complaint
  • setting out a procedure that can be easily followed and understood
  • 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.

We will seek to keep children and young people safe by:

  • valuing them, listening to and respecting them
  • adopting child protection practices through procedures and a code of conduct for staff and volunteers
  • making sure that everyone knows about the policy and procedure
  • reassuring people that they will not be penalised in any way for using the complaints procedure and that we will respond positively to any complaints made in good faith
  • offering extra support to those who need help to make a complaint
  • taking a staged approach to complaints that takes account of the level of seriousness and the possibility of resolution at different points
  • investigating each complaint as objectively and fully as we reasonably can
  • taking a staged approach to complaints that takes account of the level of seriousness and the possibility of resolution at different points
  • keeping the complainant informed during the course of the investigation and of the outcome of his/her complaint
  • keeping clear records of complaints and of how they are resolved.

Complaints procedure

What do we mean by a complaint?
A complaint is a statement from someone that he/she is not happy about the service provided to him/her by Raj Academy and would like this to be improved.The complaint might be about:

  • the behaviour of a staff member or volunteer (if this relates to allegations that someone may have harmed a child or be at risk of doing so, child protection procedures should be used)
  • the behaviour of other children and young people in the group (please note the comment about child protection procedures above)
  • the level of service received
  • the type of service received
  • being refused a service altogether
  • the building or facilities
  • written information
  • service received over the telephone (eg not being able to get through or being kept waiting)
  • a child, young person or family member feeling that he or she has been treated unfairly or in a way that is discriminatory
  • a specific activity or outing
  • anything else related to the service provided at Raj Academy.

Procedure for making a complaint

  • The complainant should put their concerns in writing to their key worker or, if the key worker is the subject of the complaint, to the key worker’s manager. If he/she needs help to do this, and a family member is not able to offer this support, help should be provided by the key worker, or, if the key worker is the subject of the complaint, by another member of staff identified by the manager
  • The key worker should give the written complaint to the manager within 24 hours. The manager should then acknowledge the complaint within two working days by sending a brief letter to:
    - thank the complainant for getting in touch
    - express regret that a complaint has been necessary
    - assure him/her that the matter will be investigated
    - set a provisional timescale for the investigation that is achievable but avoids delay as much as possible
    - explain when the manager will next be in contact
    - offer a contact name (usually the key worker or the manager’s own name) in case the complainant has any questions in the meantime
    - make any temporary arrangements that may be necessary pending the outcome of the investigation into the complaint.
  • Normally the service to the complainant should continue as normal during the investigation into the complaint. If this is not possible (eg because a child has had to be excluded from an activity, or because the complainant does not want to use the service at that point, or because it would not be appropriate for the key worker to continue working with the child/family) then this should be acknowledged and temporary alternative arrangements made, if possible.
  • If the complaint is about a specific staff member, volunteer or other child/young person, then that person (and the parent/carer if the person is a child) should be informed within two working days (or as soon as possible) that a complaint has been made against him/her and the nature of the complaint. However, the person should not be informed if doing so would compromise anyone’s safety or a police investigation.
  • The manager should normally be responsible for investigating a stage one complaint. The manager should plan the investigation according to the nature of the complaint, taking into account any witnesses or specialist opinion that should be sought. As a minimum, the complainant (and parent/carer if the complainant is a child/young person) should be interviewed. Any person who might be the subject of the complaint should also be interviewed, provided that doing so would not compromise anyone’s safety or a police investigation.
  • If the complaint is about a building, facilities or equipment, then this should be examined.
  • If the complaint is about access to a service, the reasoning behind a decision to offer or not offer a particular service should be examined.
  • If, at any point during the investigation, it appears that a criminal offence may have been committed, the matter should be reported to the police. Discussions should be held with the police about whether the investigation into the complaint can continue alongside their own enquiries.
  • If it emerges at any point that a child may have been caused significant harm or may be at risk of significant harm, child protection procedures should be instigated immediately.
  • The investigating manager should make notes of the investigation, including notes of any meetings that take place, and should write a report based on his/her findings. The report should state clearly whether the complaint is upheld or not, and should make recommendations about how the matter can be taken forward. The report should be shared with both the complainant and any specific member of staff, volunteer or other child, who may be involved. Any comments that either party may wish to make about the extent to which he/she accepts or rejects the findings of the report should be noted.
  • Once a way forward has been agreed, this should be reviewed regularly.
  • If either the complainant or a person who is the subject of the complaint is not prepared to accept the findings of the report, they should confirm this in writing. The matter then becomes a stage two complaint.
  • A complaint also progresses to stage two if it has previously (ie within the last 12 months) been handled as a stage one complaint but has resurfaced.

Stage two

  • A stage two complaint may come about for one of two reasons. It may be a complaint that has escalated from stage one because the complainant or a person who was the subject of the complaint wishes to challenge the findings from a stage one investigation. Alternatively, it may relate to matters that were investigated as a stage one complaint within the previous 12 months and have resurfaced.
  • Stage two complaints should be investigated either by a manager senior to the person who was investigating at stage one or by a completely independent person, not employed or acting as a volunteer for Raj Academy who should be nominated by Raj Academy’s management board. The investigation should be commissioned by the management board and findings reported back to the chair of the board.
  • 19. If a complaint is to progress to stage two, the complainant (this could be the original complainant or a person who was the subject of the original complaint) should again indicate in writing that he/she wishes to complain (or complain further) and should state the reason for this.
  • The written statement should be presented to the chair of the board, who should then, within two working days, respond in writing to the complainant in the same way as indicated in the stage one procedures. In addition, the chair should provide the complainant with the name of the person who will investigate the stage two complaint.
  • The procedure for the investigation and sharing of the report should be similar to that outlined in the stage one procedure.
  • Stage two is the final stage of the complaints procedure. If any party wishes to complain further following the completion of stage two, this should be taken up with an external party (eg local councillor, MP or commissioning body).

Keeping a record of the complaint

Regardless of whether a complaint is dealt with formally or informally, accurate notes should be made by the key worker or investigating manager of each stage of the process, including records of meetings. Copies of the final report should be given to the person making the complaint and to anyone who may be the subject of the complaint

If the complaint leads to any disciplinary action or a referral to a statutory authority, copies of the notes made during the investigation and the report of the investigation (together with any notes relating to the outcome) should be kept confidentially on the file of any person who is the subject of the complaint.

Anonymous summary notes of any complaint should also be kept in a complaints file. This will assist Raj Academy in the process of monitoring and learning from complaints.

Our Child Protection Policy

This policy applies to all staff, including senior managers and the board, paid staff, volunteers and sessional workers, agency staff, students or anyone working on behalf of Raj Academy Conservatoire Ltd.

The purpose of this policy:

  • to protect children and young people who receive Raj Academy’s services. This includes the children of adults who use our services;
  • to provide staff and volunteers with the overarching principles that guide our approach to child protection;

Raj Academy believes that a child or young person should never experience abuse of any kind. We have a responsibility to promote the welfare of all children and young people and to keep them safe. We are committed to practice in a way that protects them.

Legal framework
This policy has been drawn up on the basis of law and guidance that seeks to protect children, namely:

  • Children Act 1989
  • United Convention of the Rights of the Child 1991
  • Data Protection Act 1998
  • Sexual Offences Act 2003
  • Children Act 2004
  • Protection of Freedoms Act 2012
  • Relevant government guidance on safeguarding children

We recognise that:

  • the welfare of the child is paramount, as enshrined in the Children Act 1989
  • all children, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have a right to equal 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.

We will seek to keep children and young people safe by:

  • valuing them, listening to and respecting them
  • adopting child protection practices through procedures and a code of conduct for staff and volunteers
  • providing effective management for staff and volunteers through supervision, support and training
  • recruiting staff and volunteers safely, ensuring all necessary checks are made
  • sharing information about child protection and good practice with children, parents, staff and volunteers
  • sharing concerns with agencies who need to know, and involving parents and children appropriately

We are committed to reviewing our policy and good practice annually.