This is the data protection policy of Joya London Ltd
Joya is committed to being transparent about how it collects and uses the personal data including, in particular, the data of our employees, suppliers, and actual and potential clients/customers of our services.
This policy applies to the personal data of all such persons.
Data Protection Principles
- Joya processes personal data in accordance with the following data protection principles:
- Joya processes personal data lawfully, fairly and in a transparent manner.
- Joya collects personal data only for specified, explicit and legitimate purposes.
- Joya processes personal data only to an extent which is adequate, relevant and limited to what is necessary for the purposes of processing.
- Joya keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
- Joya keeps personal data only for the period necessary for processing.
- Joya adopts appropriate measures to make sure that personal data is secure, and protected: from unauthorised or unlawful processing; and from accidental loss, destruction or damage
Joya tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where Joya relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.
The Legal Basis on Which We Process Personal Data
We hold personal data under the following permitted reasons provided by the GDPR - so one of these reasons will apply to our processing of your data in this way:
- Consent: you have given clear consent for Joya to process their personal data for a specific purpose, for example:
- you have input your details via USCREEN to access pre-recorded yoga or pilates sessions and make use of our services;
- you have registered on our website to access pre-recorded yoga or pilates sessions and to be notified when new recorded content or other materials becomes available;
- if you have paid for and accessed content or information online;
- if you are a Teacher, when we or you upload a video of one of your yoga or pilates sessions; or
- where anyone signs up to our newsletter.
(b) Contract: when you express an interest in, or take membership, you enter into a contract with Joya.
(c) Legal obligations: the processing is necessary for Joya to comply with laws including data protection and governance (which are separate from contractual obligations).
(d) Pastoral interests: the processing is necessary to protect or support you or those you love and who love you, for example, next of kin data / emergency contact data in case of emergency.
(e) Legitimate interests: the processing is necessary for Joya’s legitimate interests or the legitimate interests of a third party unless we have good reason to believe that your personal interests override those legitimate interests.
As a data subject, you have a number of rights in relation to your personal data.
Subject access requests
You have the right to make a subject access request. If you make a subject access request, Joya will tell you:
- whether or not your data is being or has been processed and if so why, the categories of personal data concerned and the source of the data if you have not provided the data yourself;
- to whom your data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
- for how long your personal data will be held (or how that period is decided);
- your rights to correct errors in or erase your data, or to restrict or object to processing;
- your right to complain to the Information Commissioner if you think Joya has failed to comply with your data protection rights; and
Joya will also provide you with a copy of the personal data undergoing processing. This will normally be in electronic form if you have made a request electronically, unless you agree otherwise.
To make a subject access request, you should send the request to firstname.lastname@example.org
In some cases, Joya may need to ask for proof of identification before the request can be processed. Joya will inform you if it needs to verify your identity and the documents it requires.
Joya will normally respond to a request within a period of one month from the date it is received. In some cases, such as where Joya processes large amounts of your data, it may respond within three months of the date the request is received. Joya will write to you within one month of receiving the original request to tell you if this is the case.
If a subject access request is manifestly unfounded or excessive, Joya is not obliged to comply with it. Alternatively, Joya can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Joya has already responded. If you submit a request that is unfounded or excessive, Joya will notify you that this is the case and whether or not it will respond to it.
You have a number of other rights in relation to your personal data. You can require Joya to:
- amend inaccurate data;
- stop processing or erase data that is no longer necessary for our legitimate processing purposes ;
- stop processing or erase data if your interests override Joya's legitimate purposes for processing data (where Joya relies on its legitimate interests as a reason for processing data)
- stop processing or erase data if processing is unlawful; and
- stop processing data for a period if data is inaccurate or if there is a dispute about whether or not your interests override Joya's legitimate processing purposes.
To ask Joya to take any of these steps, you should send the request to email@example.com
Joya takes the security of your personal data seriously. Joya has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by our employees and third party suppliers in the proper performance of their duties.
If Joya discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. Where the Information Commissioner or we decide that the breach poses a risk to you, we will notify you. Joya will record all data breaches regardless of their effect.
You are responsible for helping Joya keep your personal data up to date. You should let Joya know if data provided to Joya changes, for example if you move house or changes to your bank details.
If you download yoga or pilates sessions be aware that you are processing the Teacher’s personal information (their image, their voice recording) and act responsibly with regard to that personal data: don’t keep it for longer than you need to make use of it; and if you download it, please secure it from unauthorised access and use by storing it in a firewall-protected location.
Teachers and Directors
Joya Teachers and Directors may have access to the personal data of other individuals / clients in the course of their work for Joya. Where this is the case, Joya relies on you, the Teacher, to help meet its data protection obligations for our clients, as outlined below.
If you have access to the personal data of others then you are required:
- to access only data that you have authority to access and only for authorised purposes;
- to notify anyone who is present at the recording of a yoga or pilates session (whether a participant or not) for streaming or download that they will be included in the recording if they remain and give them an opportunity to leave the session;
- not to include in any recorded sessions for streaming or download, images, names or voices of any persons who have not consented to their inclusion prior to the start of the recording;
- not to disclose data except to those (whether or not they work for Joya) who are properly authorised;
- to keep data secure (for example by complying with these rules on access to data, secure password protection, secure login of the USCREEN site and app for Joya purposes, and not storing any other person’s personal data in any form, in any place, or on any device which is not subject to Joya’s data security measures);
- not to remove personal data, or devices containing or that can be used to access personal data, from Joya’s premises without knowing that the appropriate security measures (such as encryption or password protection) to secure the data and the device are in operation;
- not to store personal data on local drives or on personal devices that are used for work purposes; and
- to report data breaches of which they become aware to Louise Jackson, Founder, Joya, immediately; firstname.lastname@example.org
Failing to observe these requirements may lead to a Teacher’s dismissal and removal from Joya’s schedule. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate processing purpose, may constitute gross misconduct and could lead to dismissal without notice.