PRIVACY POLICY

Hayto Music Services Ltd trading as Hayto Home Music School (HHMS)

 

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Privacy Policy Last updated: 01/09/2026

Hayto Music Services Ltd, trading as Hayto Home Music School (“HHMS”, “we”, “us”, “our”) is committed to protecting and respecting your privacy. This policy explains how we collect, use, store, share and protect your personal data when you use our website, enquire about or use our services, attend our workshops or events, or otherwise communicate with us.

Hayto Music Services Ltd is the data controller responsible for your personal data. Registered in England and Wales.

Data Controller

Hayto Music Services Ltd
Company Number: 10616569

Email: info@haytohms.co.uk

Telephone: 07477 534819

Website: www.haytohms.co.uk

This Privacy Policy should be read alongside the relevant HHMS Terms and Conditions applicable to the services you receive.

  1. What Personal Data We Collect

We may collect and process the following categories of personal data:

Clients, Parents and Students

  • Name
  • Email address
  • Telephone number
  • Postal address
  • Child’s name
  • Child’s age
  • Child’s instrument (where applicable)
  • Where voluntarily provided, we may also process information relating to a student’s learning needs, which may include health or disability information where relevant to the provision of the service.
  • We collect personal data relating to children only where necessary to provide our educational services and normally receive this information from a parent or person with parental responsibility.
  • Academic subject(s) studied (where applicable)
  • Payment and billing information, including payment status and transaction information where applicable.
  • Photographs, video and audio recordings of Participants attending RockJam workshops, rehearsals, concerts, performances and other RockJam activities, where applicable

Tutors

  • Name
  • Email address
  • Telephone number
  • Address
  • Teaching experience and qualifications
  • DBS and safeguarding information, where applicable, including DBS verification details and, where disclosed, relevant criminal offence information and information necessary to assess suitability. HHMS does not retain photocopies, photographs, scans or other images of DBS certificates and retains only information that is necessary and proportionate for safer recruitment and safeguarding purposes.
  • CV and references
  • Instruments and/or academic subjects taught
  • Biography and teaching profile
  • Bank details (for payment purposes)

Employees

  • Name
  • Address
  • Telephone number
  • Email address
  • Date of birth
  • National Insurance number
  • Bank details
  • Payroll information
  • Pension information
  • Emergency contact details
  • Right to Work documentation
  • Employment records
  • Training records
  • DBS information (where applicable)

Website Users

  • IP address
  • Browser type and device information
  • Usage data through cookies (see Cookies section)

Children have their own data protection rights. Where appropriate, HHMS will provide information about how we use a child’s personal data in a clear and age appropriate way.

 

2.How We Collect Personal Data

We collect personal data directly from you and, where appropriate, from other people or organisations. This may include parents or guardians providing information about students, Clients and Tutors providing information necessary to arrange tuition, referees providing references, and information received from service providers or public authorities where lawful and necessary.

 

Where we need personal data to enter into or administer a contract, provide a service, or comply with a legal obligation, we will indicate where the information is required. If required information is not provided, we may be unable to provide the relevant service, arrange an Introduction or Assignment, process a booking or payment, or meet our legal or safeguarding obligations.

  1. How We Use Your Personal Data

We only use your personal data when the law allows us to.

Under UK GDPR, we rely on the following lawful bases:

Contract
Where processing is necessary to take steps at your request before entering into a contract, or to perform a contract with you. This includes administering HHMS services, arranging Tutor introductions and private tuition bookings where HHMS acts as an employment agency, administering RockJam workshops and events where HHMS acts as an employment business, managing payments and communicating with you about the services you use.

Legal Obligation
To comply with our legal obligations, including those relating to accounting, payroll, taxation, employment law and safeguarding, including maintaining appropriate safeguarding records where required.

Legitimate Interests
We may use email tracking technology provided through TutorCruncher to help us understand whether important service communications have been opened and whether links within those communications have been accessed. This helps us administer our services effectively and improve our communications. We have carefully considered the impact on individuals and have concluded that our legitimate interests are not overridden by their rights and freedoms.

To operate and improve our business, including:

  • Internal administration
  • Service improvement
  • Responding to enquiries
  • Preventing fraud

We ensure our legitimate interests do not override your rights.

Consent

We rely on consent where it is the appropriate lawful basis for the relevant processing activity and where consent is required by applicable law.

In relation to RockJam, where HHMS wishes to use identifiable photographs, video or audio recordings of a Participant online or otherwise for the promotion or marketing of HHMS services, we will obtain the Client’s prior written consent. This consent is sought separately from acceptance of the RockJam Parent Terms and Conditions and is not a condition of participation in RockJam.

The Client may withdraw this consent at any time by notifying HHMS. Withdrawal of consent will not affect the lawfulness of any processing carried out before consent was withdrawn. Upon receipt of a withdrawal request, HHMS will cease any further promotional or marketing use of identifiable photographs, video or audio recordings of that Participant.

Special Category and Criminal Offence Data

Where HHMS processes special category personal data, we will identify an appropriate lawful basis under Article 6 UK GDPR and a condition under Article 9 UK GDPR and, where required, a condition under Schedule 1 of the Data Protection Act 2018. Where we process criminal offence data, including relevant DBS information, we will do so in accordance with Article 10 UK GDPR and the Data Protection Act 2018. Where required, this processing is supported by our Appropriate Policy Document.

This may include processing necessary for safer recruitment, assessing and reviewing tutor suitability, ongoing safeguarding and compliance with legal or regulatory obligations, where applicable.

  1. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected. Retention periods are determined by the nature and purpose of the information and any applicable legal, accounting, contractual, safeguarding or regulatory requirements.

Typical retention arrangements include:

  • Financial and accounting records: retained for the period required by applicable tax and accounting legislation.
  • DBS records: HHMS does not retain photocopies, photographs, scans or other images of DBS certificates. We may retain limited information about the DBS check, including the certificate issue date, certificate type and level, certificate reference number, relevant verification information and the recruitment or suitability decision. Where detailed certificate information is temporarily required to consider a suitability matter, it will be retained only for as long as necessary and handled in accordance with DBS guidance and applicable data protection requirements.
  • Safeguarding records: retained for an appropriate period having regard to the nature of the record, safeguarding requirements and applicable guidance.
  • Marketing information: retained until consent is withdrawn or the information is no longer required for the relevant marketing purpose.
  • Photographs, video and audio recordings used for promotional or marketing purposes: retained only for as long as the relevant consent remains valid and the material is required for the relevant purpose. Where consent is withdrawn, HHMS will cease any further promotional or marketing use of identifiable material relating to that Participant.

Other personal data is retained only for as long as reasonably necessary for the purpose for which it is held. Personal data is securely deleted, destroyed or anonymised when it is no longer required.

Further information about our retention arrangements is set out in the HHMS Data Retention & Records Management Policy.

  1. Marketing Communications

HHMS does not routinely send marketing communications. Most communications we send relate to the administration and delivery of our services, including lessons, bookings, payments, workshops, events and important service updates.

Where we send direct marketing communications, we will only do so where permitted by applicable law and will provide an appropriate way to opt out of future marketing communications.

Essential service and administrative communications cannot generally be opted out of where they are necessary to provide or administer an active service.

  1. Email Tracking

We may use email tracking technology provided through TutorCruncher to monitor whether service communications have been opened and whether links within those communications have been accessed.

This helps us administer our services effectively and improve our communications.

You may opt out of marketing communications at any time. Essential service communications relating to active services cannot generally be opted out of where they are necessary for the administration of lessons, workshops or other services.

  1. Sharing Your Information

We do not sell your personal data.

We may share personal data:

  • With tutors where necessary to arrange or provide tuition, workshops or other educational services
  • With payment providers
  • With payroll and pension providers, where applicable
  • With professional advisers, including accountants, legal advisers and safeguarding advisers, where necessary and lawful
  • With IT and administration providers, including TutorCruncher
  • Where required by law
  • With the Disclosure and Barring Service (DBS), safeguarding authorities, law enforcement agencies or other statutory or regulatory bodies where disclosure is necessary and lawful.

All third-party providers are required to respect the security of your personal data.

  1. Third Party Platforms

TutorCruncher

We use TutorCruncher Ltd, a UK-based software provider, to manage lesson scheduling, tutor-client matching, communications, invoicing and certain administrative functions.

In relation to personal data processed on our behalf, TutorCruncher acts as a data processor under Article 28 of the UK General Data Protection Regulation (UK GDPR).

TutorCruncher processes personal data only on our documented instructions and under a Data Processing Agreement which includes appropriate technical and organisational security measures, confidentiality obligations, breach notification procedures and safeguards for international data transfers.

TutorCruncher may engage approved sub-processors, such as secure hosting providers and payment processors. These sub-processors are contractually bound by data protection obligations equivalent to those required under UK GDPR.

Where TutorCruncher collects personal data directly as a data controller, for example when individuals interact directly with TutorCruncher’s website or support services, TutorCruncher’s own privacy policy applies.

You can view TutorCruncher’s Privacy Policy here:
https://tutorcruncher.com/privacy

Stripe

We use Stripe, including Stripe Connect where applicable, to facilitate and process online payments.

When you make a payment through our system, your payment details are processed directly by Stripe. We do not store or have access to your full card details.

Stripe acts as an independent data controller in relation to payment processing and is responsible for handling your payment information securely and in accordance with applicable data protection laws.

Stripe’s Privacy Policy is available at:
https://stripe.com/gb/privacy

Social Media Links

Our website includes links to our official social media pages:

Facebook: https://www.facebook.com/haytohms
Instagram: https://www.instagram.com/hayto_home_music_school/
YouTube: https://www.youtube.com/@haytohomemusicschool6832

If you follow these links, you will be directed to external platforms operated by third parties. We are not responsible for the privacy practices of those platforms. We recommend reviewing their privacy policies before submitting any personal data.

  1. International Transfers

Some of our service providers may store or process data outside the UK.

Where personal data is transferred outside the UK, we ensure that the transfer is permitted under applicable data protection law and that appropriate safeguards are used where required. These may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.

You may contact us for further information about the safeguards used where your personal data is transferred outside the UK.

  1. Data Security

We take appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction.

Access to personal data is limited to those who have a genuine business need.

  1. Your Legal Rights

Under UK GDPR, you have the right to:

  • Request access to your personal data
  • Request correction of inaccurate data
  • Request erasure of your data
  • Request restriction of processing
  • Object to processing in certain circumstances, including where we rely on legitimate interests
  • Object at any time to the processing of your personal data for direct marketing purposes
  • Request transfer of your data (data portability)
  • Rights and safeguards relating to certain decisions made solely by automated processing, where applicable
  • Withdraw consent at any time

These rights are subject to the conditions and exemptions set out in applicable data protection law and may not apply in every circumstance.

You do not have to pay a fee to access your personal data.

We will normally respond to requests within one month, in accordance with applicable data protection law.

To exercise your rights, please contact us at info@haytohms.co.uk.

  1. Complaints

If you are unhappy with how we have handled your personal data or believe that we have not complied with our data protection obligations, you can make a complaint by contacting us at info@haytohms.co.uk.

We will acknowledge your complaint within 30 days, investigate it appropriately and keep you informed of its progress where necessary. We will notify you of the outcome of our investigation without undue delay.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO). Further information is available at www.ico.org.uk.

  1. Cookies

We use cookies and similar technologies to ensure our website functions properly, to improve user experience, and to analyse website traffic.

The types of cookies we use include:

  • Strictly necessary cookies for security and core functionality, including Google reCAPTCHA
    • Analytics cookies, including Google Analytics, to help us understand how visitors use our website
    • Functional cookies, such as those required for embedded content including YouTube videos
    • Third-party cookies associated with embedded content or external services

Strictly necessary cookies are always active as they are essential for the operation of the website.

All non-essential cookies, including analytics and embedded content cookies, are only placed on your device after you provide consent through our cookie banner.

You can manage or withdraw your consent at any time using the Cookie Settings tool available on our website.

For more detailed information about the cookies we use, including their purpose and duration, please refer to our Cookie Policy.

  1. Changes to This Policy

We may update this Privacy Policy from time to time.

The latest version will always be available on our website and will include the date of revision.

 

 

 

 

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