The DaCapo Music Foundation (DaCapo) acknowledges the duty of care to safeguard and
promote the welfare of children and is committed to ensuring that its safeguarding practice
reflects statutory responsibilities, government guidance and complies with best practice and
requirements. The legal definition of a child is any person under the age of 18 years. DaCapo
will take all reasonable steps to ensure that the safeguarding of children is embedded within all
of our educational work and built into the arrangements at the planning stage.
The policy recognises that the welfare and interests of children are paramount in all
circumstances. It aims to ensure that regardless of age, ability or disability, gender reassignment,
race, religion or belief, sex or sexual orientation, socio-economic background, all children:
• have a positive and enjoyable experience of music making at DaCapo in a safe and child
• are protected from abuse whilst participating in music making activities or outside of the
DaCapo acknowledges that some children, including disabled children and young people or
those from ethnic minority communities, can be particularly vulnerable to abuse and we accept
the responsibility to take reasonable and appropriate steps to ensure their welfare.
As part of our safeguarding policy DaCapo will:
• promote and prioritise the safety and wellbeing of children and young people
• ensure everyone understands their roles and responsibilities in respect of safeguarding
and is provided with appropriate learning opportunities to recognise, identify and
respond to signs of abuse, neglect and other safeguarding concerns relating to children
and young people
• ensure appropriate action is taken in the event of incidents/concerns of abuse and
support provided to the individual/s who raise or disclose the concern
• ensure that confidential, detailed and accurate records of all safeguarding concerns are
maintained and securely stored
• prevent the employment/deployment of unsuitable individuals
• ensure robust safeguarding arrangements and procedures are in operation.
This policy applies to all members of staff (whether employees, contractors, consultants or
freelance), volunteers, trustees and anyone working for or on behalf of DaCapo.
DaCapo will appoint a Safeguarding Officer (SO), who will:
• Act as the first point of contact for all safeguarding matters
• Communicate with DaCapo’s personnel and partner organisations their responsibilities
regarding child protection
• Receive appropriate ongoing training, keep up to date with changes in local and
national policy and guidance, and share relevant information with the Board of Trustees
• Ensure that DaCapo’s Safeguarding Policy, Procedures and Code of Practice are
reviewed on a yearly basis (sooner in the event of any disclosures or allegations), and
updated and expanded as necessary
In case of the SO’s absence, DaCapo will appoint a Deputy to be the responsible point of
contact and communication on all safeguarding matters
Safeguarding Officer (SO)
Michelle Groves email@example.com. 07595 367 194
Jane Cutler firstname.lastname@example.org 07590 689388
This policy will be reviewed a year after development and then every three years, or in the
• changes in legislation and/or government guidance
• as required by the Local Safeguarding Children Board
• as a result of any other significant change or event.
CODE OF PRACTICE WHEN WORKING WITH CHILDREN
Our guiding principles when working with children are:
• Our primary concern is the welfare and safety of each child
• We respect the rights and dignity of each child
• We ensure that the feelings and concerns or any child or their parent/carer are listened
to and acted upon
• We have a responsibility to prevent the physical, sexual or emotional abuse of any child,
and any suspicions or allegations of abuse are taken seriously and responded to
• These principles will be applied regardless of gender, race, disability, religion or belief,
sexual orientation or gender reassignment
Adults who work with children are responsible for their own actions and behaviour and have a
duty of care to children at all times. All DaCapo personnel should:
• Remember you are working in a position of trust
• Keep communication professional and avoid asking personal questions
• Avoid physical contact which can be misinterpreted. Can the action be demonstrated
instead? Only touch children when it is necessary in relation to the activity. Seek the
consent of the child prior to any physical contact and explain the purpose
• Never use offensive or abusive language
• Never share any personal contact details or social networking accounts
POLICY & PROCEDURES
• DaCapo will ensure that we assess and monitor all safeguarding risks from planning to
delivery for each project involving children
• Our Code of Practice, and our Policy & Procedures will also apply to those instances
where DaCapo organises a workshop, concert or other outreach activity which is not on
the organisation’s premises.
• DaCapo will require the name, email and phone number of the host/partner
organisation’s Designated Safeguarding Lead who has the supervising responsibility on
• The SO is responsible for sharing the details of the Designated Safeguarding Lead with
all the DaCapo personnel involved, in advance of the event.
• DaCapo will share its Safeguarding Policy and Code of Conduct with every host/partner
organisation in advance of any activity
• DaCapo will ensure that all personnel who work with children on DaCapo’s behalf have
read and understood the Safeguarding Policy and our Code of Practice
• DBS (Disclosure and Barring Service) checks at the enhanced level with a barred check
list, will always be carried out by DaCapo on behalf of any personnel whose work on
behalf of DaCapo involves working unsupervised contact with children.
When DaCapo personnel are working on any premises being used for DaCapo’s
educational/outreach work, then any safeguarding concerns raised by DaCapo personnel (or
concerns or disclosures made to them), need to be passed on to the Designated Safeguarding
Lead that same working day. A clear written record should be made of all observations, actions
and conversations, the time and date, and the response that was taken. Every effort should be
made to record what the child or adult says in their own words. Records should be immediately
signed and dated. The Designated Safeguarding Lead will determine what action is needed.
The SO (or Deputy) can be consulted in advance of that and should be informed of the details
of the concern and action taken.
The SO (or Deputy) is responsible for follow up with the school/further education
college/university, or partner organisation, to ensure action has been taken and a record made
of the outcome.
Details of any allegations against a member of DaCapo personnel must be recorded by the
Designated Safeguarding Lead that same working day. A clear written record should be made
of all observations, actions and conversations, the time and date, and the response that was
taken. Every effort should be made to record what the child or adult says in their own words.
Records should be immediately signed and dated. The Designated Safeguarding Lead will
determine what action is needed. The SO (or Deputy) must be informed the same working
If a serious allegation is made against a member of DaCapo Personnel, they will be excluded
from all DaCapo activities pending further investigation and to safeguard the FO member. FO
Trustees will immediately be informed.
Information about allegations and disclosures will be stored securely and shared only with
those who need to know about the incident or allegation.
How DaCapo personnel should record a Disclosure of Abuse:
• Do not promise to keep the disclosure to yourself
• Inform the student/staff member that the disclosure will need to be passed on to the
• Explain you may need to write some information down
• Do not ask leading questions or offer suggestions
• Do not discuss the disclosure with any other person other than the DSL
• All DaCapo personnel are aware that they cannot promise a child to keep secrets which
might compromise the child’s safety or wellbeing.
DACAPO WRITTEN: OCTOBER 2022
REVIEW: OCTOBER 2024
1.1 We are committed to safeguarding the privacy of our website visitors and service
1.2 This policy applies where we are acting as a data controller with respect to the
personal data of our website visitors and service users; in other words, where we
determine the purposes and means of the processing of that personal data.
1.3 In this policy, “we”, “us” and “our” refer to The DaCapo Music Foundation. For more
information about us, see Section 8.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and
specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data”). The
usage data may include your IP address, geographical location, browser type and version,
operating system, referral source, length of visit, page views and website navigation paths,
as well as information about the timing, frequency and pattern of your service use. The
source of the usage data is our analytics tracking system. This usage data may be processed
for the purposes of analysing the use of the website and services. The legal basis our
legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data”). The account data may include your
name and email address. The source of the account data is you or your employer. The
account data may be processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining back-ups of our
databases and communicating with you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.
3.4 We may process information that you post for publication on our website or through our
services (“publication data”). The publication data may be processed for the purposes of
enabling such publication and administering our website and services. The legal basis for this
processing is our legitimate interests, namely the proper administration of our website and
3.5 We may process information contained in any enquiry you submit to us regarding goods
and/or services (“enquiry data”). The enquiry data may be processed for the purposes of
offering, marketing and selling relevant goods and/or services to you. The legal basis for this
processing is consent.
3.6 We may process information relating to our customer relationships, including customer
contact information (“customer relationship data”). The customer relationship data may
include your name, your employer, your job title or role, your contact details, and
information contained in communications between us and you or your employer. The source
of the customer relationship data is you or your employer. The customer relationship data
may be processed for the purposes of managing our relationships with customers,
communicating with customers, keeping records of those communications and promoting
our products and services to customers. The legal basis for this processing is our legitimate
interests, namely the proper management of our customer relationships.
3.7 We may process information relating to transactions, including purchases of goods and
services that you enter into with us and/or through our website (“transaction data”). The
transaction data may include your contact details, your card details and the transaction
details. The transaction data may be processed for the purpose of supplying the purchased
goods and services and keeping proper records of those transactions. The legal basis for this
processing is the performance of a contract between you and us and our legitimate
interests, namely the proper administration of our website and business.
3.8 We may process information that you provide to us for the purpose of subscribing to our
email notifications and/or newsletters (“notification data”). The notification data may be
processed for the purposes of sending you the relevant notifications and/or newsletters. The
legal basis for this processing is consent.
3.9 We may process information contained in or relating to any communication that you
send to us (“correspondence data”). The correspondence data may include the
communication content and metadata associated with the communication. Our website will
generate the metadata associated with communications made using the website contact
forms. The correspondence data may be processed for the purposes of communicating with
you and record-keeping. The legal basis for this processing is our legitimate interests, namely
the proper administration of our website and business and communications with users.
3.10 We may process any of your personal data identified in this policy where necessary for
the establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure. The legal basis for this processing is our legitimate
interests, namely the protection and assertion of our legal rights, your legal rights and the
legal rights of others.
3.11 We may process any of your personal data identified in this policy where necessary for
the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is our legitimate interests, namely the
proper protection of our business against risks.
3.12 In addition to the specific purposes for which we may process your personal data set
out in this Section 3, we may also process any of your personal data where such processing
is necessary for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
3.13 Please do not supply any other person’s personal data to us, unless we prompt you to
4. Providing your personal data to others
4.1 We may disclose your personal data where such disclosure is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal data where such disclosure
is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings
or in an administrative or out-of-court procedure.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help
ensure that we comply with our legal obligations in relation to the retention and deletion of
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is
necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7. Your rights
7.1 In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are: (a) the right to access; (b) the right to
rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to
processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and,
where we do, access to the personal data, together with certain additional information. That
additional information includes details of the purposes of the processing, the categories of personal
data concerned and the recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. The first copy will be provided
free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into
account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue
delay. Those circumstances include: the personal data are no longer necessary in relation to the
purposes for which they were collected or otherwise processed; you withdraw consent to consentbased processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those
circumstances are: you contest the accuracy of the personal data; processing is unlawful but you
oppose erasure; we no longer need the personal data for the purposes of our processing, but you
require personal data for the establishment, exercise or defence of legal claims; and you have
objected to processing, pending the verification of that objection. Where processing has been
restricted on this basis, we may continue to store your personal data. However, we will only
otherwise process it: with your consent; for the establishment, exercise or defence of legal claims;
for the protection of the rights of another natural or legal person; or for reasons of important public
7.7 You have the right to object to our processing of your personal data on grounds relating to your
particular situation, but only to the extent that the legal basis for the processing is that the
processing is necessary for: the performance of a task carried out in the public interest or in the
exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by
us or by a third party. If you make such an objection, we will cease to process the personal
information unless we can demonstrate compelling legitimate grounds for the processing which
override your interests, rights and freedoms, or the processing is for the establishment, exercise or
defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing
purposes (including profiling for direct marketing purposes). If you make such an objection, we will
cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical
research purposes or statistical purposes on grounds relating to your particular situation, unless the
processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured,
commonly used and machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws,
you have a legal right to lodge a complaint with a supervisory authority responsible for data
7.12 To the extent that the legal basis for our processing of your personal information is consent,
you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us, in
addition to the other methods specified in this Section 7.
8. Our details
8.1 This website is owned and operated by The DaCapo Music Foundation.
8.2 We are registered in England under registration number 06698862 and with the charities
commission: 1136051. Our registered office is at Wren Academy, Hilton Avenue, London, England,
8.3 Our principal place of business is at Wren Academy, Hilton Avenue, London, England, N12 9HB
8.4 You can contact us: (a) by post, to the postal address given above; (b) using our website contact form; (c) by telephone, on the contact number published on our website from time to time; or (d) by email, using the email address published on our website from time to time.
9. Data protection officer
9.1 Our data protection officer’s contact details are: Michelle Groves, Chief Executive, email:
Approved 15 June 2022