Anti Discrimination Clause

“Berlin Dance Institute” is committed to maintaining an environment free from discrimination, harassment, and unlawful unequal treatment. This policy applies to all participants, employees, contractors, volunteers, and visitors (“Participants”) and is aligned with the Allgemeines Gleichbehandlungsgesetz (AGG), the EU General Data Protection Regulation (GDPR/DSGVO), and other applicable German laws.

1. Prohibited Conduct

Berlin Dance Institute expressly prohibits discrimination — direct or indirect — based on:

• racial or ethnic origin
• gender, gender identity, or gender expression
• sexual orientation
• religion or belief
• disability or chronic illness
• pregnancy or parenthood
• marital or family status
• social or economic background
• nationality
• any characteristic protected by applicable law

This prohibition applies to all program-related activities, including admissions, instruction, rehearsals, performances, employment or contracting, facility access, and digital communications.

2. Harassment and Retaliation

1. Harassment, including sexual harassment as defined under §§ 3–4 AGG, is strictly prohibited.
2. Retaliation against individuals who report concerns or participate in investigations is prohibited and may result in disciplinary action.

3. GDPR-Compliant Confidentiality and Data Protection

1. Lawful Basis for Processing
   Personal data collected for reporting, documenting, or investigating discrimination or harassment is processed pursuant to:
   • Art. 6(1)(c) GDPR (legal obligation)
   • Art. 6(1)(f) GDPR (legitimate interest)
   • where applicable, Art. 9(2)(b) GDPR (employment/social protection obligations)

2. Data Minimization
   Only information strictly necessary for handling a report will be collected and processed.

3. Confidential Handling
   All reports, statements, and investigation records are treated as strictly confidential and accessible only to authorized personnel.

4. Storage and Retention
   Data is stored securely and retained only as long as required to meet legal obligations or complete the investigation.

5. Rights of Data Subjects
   Individuals may exercise GDPR rights (access, rectification, restriction, erasure where applicable), subject to limitations necessary to protect the integrity of an investigation.

6. Third-Party Disclosure
   Personal data is not shared with third parties unless:
   • required by law
   • necessary for legal proceedings
   • explicitly consented to by the data subject

4. Reporting and Complaint Procedure

Participants may report discrimination or harassment through:

• Program Directors – Susanna Neff and/or Wendy Taylor
• Confidential written report (physical or digital)

5. Enforcement and Disciplinary Procedure

Berlin Dance Institute follows the process below when handling complaints. The institute may adjust steps as needed for fairness, proportionality, and safety.

Step 1 — Receipt and Initial Assessment

• The program directors receive the complaint.
• An initial assessment determines whether the allegation falls under this policy.
• If immediate safety concerns exist, interim protective measures may be implemented.

Step 2 — Opening of Formal Investigation

• The complainant is informed that an investigation has begun (unless the report is anonymous).
• The respondent is notified and given the opportunity to respond.
• Confidentiality obligations are reiterated to all involved.

Step 3 — Evidence Collection

• Interviews with complainant, respondent, and any witnesses
• Review of relevant physical, digital, or documentary evidence
• Data collection in accordance with GDPR minimization and confidentiality principles

Step 4 — Evaluation and Findings

• The directors evaluate evidence using a “preponderance of evidence” standard unless otherwise required by law.
• A written report is prepared summarising findings and recommended actions.

Step 5 — Decision and Notice

• The program directors review findings and issue a final determination.
• Both complainant and respondent (subject to privacy law) are informed of the outcome.

Step 6 — Disciplinary Measures

Depending on severity, intent, and prior conduct, measures may include:

• verbal or written warning
• mandatory training or mediation
• restriction of participation
• suspension from classes, rehearsals, or facilities
• termination of contract or removal from the program

6. Duty of Cooperation

All participants share responsibility for ensuring compliance with this policy and are expected to cooperate honestly and respectfully during any investigation.