Privacy Policy is the personal website for Joe Barefoot (JB) – an independent musician, music tutor and audio engineer operating as a for-profit sole trader in the United Kingdom. I respect your privacy and am committed to protecting your personal data. This privacy notice will inform you as to how I look after your personal data when you visit my website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 


Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important Information and About Joe Barefoot

Purpose of this privacy notice

This privacy notice aims to give you information on how I collect and processes your personal data through your use of my website, including any data you may provide through this website when you ask me to send you information. 


It is important that you read this privacy notice together with any other privacy notice or fair processing notice provided on specific occasions when collecting or processing personal data about you, so that you are fully aware of how and why I am using your data. This privacy notice supplements any other notices and is not intended to override them. 


Joe Barefoot is the controller of and is responsible for your personal data (collectively referred to as “JB”, “I”, “me” or “my” in this privacy notice).

I am the Privacy Manager of data on my website, responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise YOUR LEGAL RIGHTS (which are set out at the end of this privacy notice) please contact me using the contact details below. 

Contact details

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance. 

Changes to the privacy notice and your duty to inform me of changes

This version was last updated on 7 March 2021.

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit.

2. The Data I Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

I may collect, use, store and transfer different kinds of personal data about you which I have grouped together follows:

  • Identity Data includes first name, last name, marital status (if relevant), title, date of birth and gender of intended pupil and parent or guardian. 
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 
  • Profile Data includes purchases or orders made by you, your preferences and feedback.  
  • Usage Data includes information about how you use my website, products and services. 
  • Communications Data includes your communication preferences.

I also collect, use and share Aggregated (Anonymous) Data such as statistical or demographic data for any purpose. Aggregated (Anonymous) Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated (Anonymous) Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy notice.


I do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do I collect any information about criminal convictions and offences.

If you fail to provide personal data

Where I need to collect personal data by law, or under the terms of a contract I have with you and you fail to provide that data when requested, I may not be able to perform the contract I have or are trying to enter into with you (for example, to provide you with goods or services). In this case, I may have to cancel a product or service you have with me but I will notify you if this is the case at the time. 

3. How is Your Personal Data Collected?

I use different methods to collect data from and about you including through:

  • Direct interactions. You may give me your Identity and Contact Information by filling in forms on this website or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for my products or services;
  • subscribe to my service or publications; 
  • request marketing to be sent to you; or
  • give me some feedback. 
  • Automated technologies or interactions. As you interact with my website, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. Please see my cookie policy – a link can be found in the footer (at the bottom) on every page of my Website:, for further details.
  • Third parties or publicly available sources. I may receive personal data about you from various third parties as set out below.
  • Contact information from local music organisations, such as Milton Keynes Music Faculty (part of Milton Keynes Council) and members of Milton Keynes Music Co-op (MKMC) based in the UK. These may be given to me to contact you about music tuition.
  • Financial and Transaction Data from providers of payment and delivery services such as my bank, based in the UK.  

4. How I Use Your Personal Data

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:


Where I need to perform the contract I am about to enter into or have entered into with you.


Where it is necessary for my legitimate interests and your interests and fundamental rights do not override those interests.


Where I need to comply with a legal or regulatory obligation.

Purposes for which I will use your personal data

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.


Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer
  • Identity
  • Contact
  • Profile
  • Performance of a contract with you

To process and deliver services to you including:


  • managing payments, fees and charges
  • collecting and recovering money owed to me
  • Identity
  • Contact
  • Financial
  • Transaction
  • Communications
  • Performance of a contract with you
  • Necessary for my legitimate interests (to recover debts due to me)

To manage my relationship with you which will include:


  • Notifying you about changes to my terms or privacy policy
  • asking you to give information on your communication preferences
  • Identity
  • Contact
  • Profile
  • Communications 
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for my legitimate interests to keep my records updated

To administer and protect my business and this website including:


  • Troubleshooting
  • Data analysis
  • Testing
  • System maintenance
  • Support
  • Reporting
  • Hosting of data
  • Identity
  • Contact
  • Technical
  • Necessary for my legitimate interests 
    (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies I use, please see my cookie policy, a link can be found in the footer (at the bottom) on every page of my Website: 

Change of purpose

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me. 


If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.


Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of Your Personal Data

I may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary below.
  • Specific third parties listed in paragraph 4 above.
  • Third parties to whom I may choose to sell, transfer, or merge parts of my business or assets. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy notice. 
  • If I seek to acquire other businesses or merge with them, then the new owners may use your personal data in the same way as set out in this privacy notice.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. 


I use a Content Management System (CMS) provided by My Music Staff ( to organise, manage, contact and process personal data of my customers to provide my Services. The data stored in this system may be stored on computers located internationally. Please read the My Music Staff privacy policy ( for more information.


I do not rent or sell your personal information to other companies or individuals.

If you choose to provide information to me, please note that I transfer the data, including Personal Data, to Canada and/or the United States and process it there.


Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.


I will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

7. Data Security

I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 


I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so.

8. Data Retention

How long will you use my personal data for?

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 


To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.


In some circumstances you can ask me to delete your data: see Request erasure below for further information.


In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you. 

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. For further information please see the paragraph at the end of this Privacy Notice referring to Your Legal Rights. If you wish to exercise any of your legal rights regarding your data, please contact me. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights relating to your personal data). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

What I may need from you

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

Time limit to respond

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated. 

10. Glossary

Lawful Basis

Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me.


Performance of Contract means processing your data where it is necessary for the performance of a contract, to which you are a party, or to take steps at your request before entering into such a contract.


Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.

External Third Parties

Service providers: Milton Keynes Music Faculty (part of Milton Keynes Council) , Milton Keynes Music Co-op (MKMC) and My Music Staff ( acting as processors of new contact information. 


Professional advisers acting as processors, including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.


HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:


Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.


Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.


Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 


Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.


Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data’s accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it. 


Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you. 


Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.