Privacy Notice for the Personal Data
The relationship that the International School of Latvia (“ISL” or the “School”) has with contractors implies performing various processing operations with regard to the personal data pertaining to contractors and other data subjects related to contractors, such as dependents. ISL processes personal data on its prospective, current and former students and their parents or legal representatives, as part of its everyday operations of providing educational services.
The general legal framework that regulates the protection of personal data is the General Data Protection Regulation no. 679/2016 (the “GDPR”) applicable in the European Union.
In this notice, the School has enclosed all the information necessary for understanding the data processing activities that are conducted with regard to the personal data of contractors and other data subjects related to contractors at the level of ISL. This Privacy Notice is mainly dedicated to ISL’s contractors that have concluded a teaching and administrative services contract with the School. This Privacy Notice covers also the data processing operations that are conducted with regard to data subjects related to contractors, such as dependents (i.e., family members). Therefore, the School processes the personal data of dependents in order to perform the contract with the contractor. For this situation, the contractor who discloses personal data on dependents has the obligation to provide the dependents with information on the disclosure of their data to ISL and the reasons for such disclosure, and even if the case may be to present them this Privacy Notice.
For the purpose of this Privacy Notice, please consider that the terms listed below shall have the following meaning.
|personal data||means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person|
|processing||means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction|
ISL wishes to be completely transparent with regard to the processing of Personal Data and therefore, we have presented below all the information you may need on this subject matter.
Please take a little of your time to read this privacy notice to understand the data processing operations carried out by ISL.
1. The purposes for which ISL processes your Personal Data:
- ISL processes Personal Data that pertain to you or to the students for the following purposes:
- Provision of educational services, starting with the application process, enrolling students, administration of classes and timetable, teaching activities, administration of internal and public examinations, assistance regarding the application process to various universities, issuance of academic records.
- Provision of educational ancillary services: pastoral care, career and personal counselling, library services, ASA extracurricular activities, school trips, managing school’s publications and granting access to ISL’s Intranet and Internet network as well as monitoring the use of ISL’s network.
- Ensuring campus security: monitoring access on campus, performance of video surveillance.
- Provision of the medical care and counselling that students may need.
- School administration: handling student records and other academic documentation, administration of fees and accounts, internal audits and controls, reporting and statistics creation, implementing school policies, ensuring collaboration with other schools, archiving, assessing the quality of our services, facilitating research activities.
- School related communications: conveying various messages related to the students and ISL’s activities by any communication means.
- Organizing fundraising activities and other school events (e.g., concerts, theatre productions, talent shows), including marketing communications related to the fundraising activities organized by ISL.
- Dispute resolution and litigations.
2. The categories of Personal Data that ISL processes, include, but are not limited to the following:
- Identification and contact information Data: name, surname, identity code, nationality, date of birth, country of origin, social security number, other personal data that may result from passports/identity cards or other types of identification documents, phone number, Latvian address, address in the home country; e-mail etc.);
- Bank details;
- Health data: medical history, allergies, immunization records, disorders, medical examination results and other medical data of the students and staff;
- Data related to the educational background and regarding school performance of the students: academic, disciplinary or other educational related records, academic references, special needs, hobbies, results of educational diagnosis testing, test results, feedbacks, evaluations etc.;
- Behavioral data as well as data on preferences / interests of students;
- Family information: household information, language background, profession and workplace of parents etc.;
- Authentication and physical access data: e-mail, passwords, badge number, location data, other on-line identifiers, car details etc.;
- Photos and videos.
- Generally, the Personal Data held by ISL were provided directly by the parents or resulted from the interaction the parents and the students have with the school. In some cases, third parties (e.g., representatives of former schools attended by students) supply data.
3. The lawful basis for the processing operations we conduct with regard to the Personal Data ISL collects and further processes Personal Data, based on one of the following legal grounds, expressly laid down by the GDPR:
- The consent you have granted us, prior to any processing of the personal data, for:
- the use of students’ photographs and videos in various school publications, on ISL’s website and social media pages; the use of your contact details for direct marketing communications on ISL’s fundraising activities; other consents that may be granted from time to time for various processing activities.
- For the performance of the Enrollment Contract, as well as in order to take steps at your request for entering into the enrolment contract and to further provide educational services.
- Please note that there are some mandatory categories of personal data necessary to ISL in order to conclude the enrolment agreement and provide the educational services to students at a high standard and in the best interest of the students.
- The mandatory categories of personal data are included in the application form, which you have filled in.
- Please take into consideration, that all the mandatory categories of data are necessary for ISL to be able to evaluate your application and to enroll your child. Failure to provide all the information marked as mandatory will lead to the impossibility of ISL to process your application and to enter into a contract with you.
- A legal obligation that requires ISL to process your Personal Data (e.g. performance of video surveillance).
- For the performance of a task carried out in the public interest, considering that ISL provides educational services, regarded as a service of public interest, according to the applicable provisions on education, many processing operations conducted by ISL that are strictly related to educational purposes will be founded on this lawful basis for processing. We refer here mainly to: issuing and storing academic records, evaluating students’ performance etc.
- The legitimate interest pursued by ISL.
- ISL relies on this legal ground in order to provide the educational services it has committed to deliver and additional services related to this scope at the highest standards, always for the benefit of the students and without outweighing the parents or the students’ rights and liberties.
- ISL may invoke the legitimate interest legal ground in the following cases: monitoring use of the ISL’s virtual learning environment and network, including monitoring the use of e-mails account provided by ISL; conducting fundraising activities, including marketing of such activities; enforcement of legal claims, addressing complaints and third party controls; management, control, reporting and performing statistics on schools activity; ensuring security; maintaining close relationships with alumni and ISL’s community; collaboration with other schools and educational institutions; performance of agreements with suppliers, including insurance suppliers; access to grants and other funding sources.
- With respect to the processing of the special categories of personal data under the GDPR, respectively health data, please take into consideration that ISL processes health data based on the following legal grounds:
- The necessity of the Medical Office to process such data for the purpose of preventive and occupational medicine, medical diagnosis and the provision of health or social care or treatment on the basis of European Union or national law;
- Processing is necessary for reasons of substantial public interest, on the basis of European Union or national law. Such a legal ground is used especially in those situations where the school has to assess the learning capacity of a student and adapt the teaching activities to the special needs of a student.
- The explicit consent granted by you for the disclosure of the personal data of students related to theallergies they suffer from.
4. Disclosure of Personal Data
- ISL discloses your Personal Data only to those members of ISL, staff and collaborators, who need access to the personal data mainly for ensuring the provision of the educational and ancillary services. In this respect, please take into account that only the Medical Office has access to the students’ medical records. Other departments of the school have access to specific health data based on the consent you have expressed (i.e. for allergies) or in order to protect a substantial public interest based on Union or national law (e.g., various medical conditions triggering special learning needs).
- With respect to the disclosure of your Personal Data to third parties, outside ISL, please note that such disclosure is performed solely in the regular activity of the school. The categories of recipients include the following: IT providers, including educational applications, on-line tools, server hosting suppliers such as ManageBac, Acamadigo, NWEA and College Board etc. food provider in its capacity of independent provider of meal services on campus; Other educational institutions or organizations, not limited to other schools; Travel agencies, catering and transportation providers; ISL’s photographer and video crew; Courier services providers; Utilities services providers; Public authorities and institutions, national or foreign, judicial courts and foreign embassies or other forms of diplomatic missions; Tax, legal and accounting consultants and auditors.
5. Third country transfers
- ISL transfers your personal data to the third countries, as follows:
- United States of America – to third parties that have obtained EU – US Privacy Shield certification (i.e. Faria Systems LLC as provider of the ManageBac and Open Apply applications).
- If you wish to consult the appropriate safeguards put in place by ISL about the transfers of personal data to the USA, please refer to the contact point at the end of this Privacy Notice.
6. Retention of Personal Data
- ISL holds a hard copy of your Personal Data for as long as you are in a contractual relation with us, and afterwards for a standard period of five years, or for a period which ISL can justify a need in storing such personal data. ISL keeps the student file and all the data related to the student interaction with ISL mainly for the scope of assessing the school’s activity and the quality of services provided but also for addressing a potential request of students with regard to their school trajectory within ISL, which usually appear after the students have graduated.
- Notwithstanding the retention period mentioned above, please be informed, that all the academic records and other school acts and documents related to study activities are kept for an indefinite period of time, according to the legal obligations that ISL has in this respect. Moreover, in any case where a legal provision imposes a minimum retention period, ISL will keep the Personal Data for at least that mandatory period.
7. Your rights related to the processing of Personal Data by ISL
- The GDPR provides certain rights related to the processing of personal data, that both you and the students have. In this respect, please be informed that students that have an appropriate level of understanding could exercise the rights listed in this section, individually.
- ISL respects all the rights mentioned under the GDPR and is committed to furnishing the appropriate means by which you can exercise these rights, according to the details mentioned below:
- The right of access, which entails your possibility to obtain the confirmation from ISL whether your Personal Data is being processed by ISL or not, and if the case may be you are entitled to solicit access to this data, as well as additional information regarding the Personal Data, such as: the purposes of processing, the categories of recipients the Personal Data are being disclosed to and the envisaged retention period. In the situations where you may need to exercise the right of access, please consider contacting ISL requesting confirmation by e-mail at firstname.lastname@example.org Please consider that there might be specific situations that are exempted from the right of access, such as information that identifies other individuals or which is subject to confidentiality obligations.
- The right to rectification, that allows you to request ISL rectification of any inaccurate Personal Data that ISL may hold, as well as to have your incomplete Personal Data to be completed.
- The right to erasure meaning that in the situations expressly regulated by law, you may request erasure of your personal data. Please take into account, that the cases where the law provides for the possibility of erasure of personal data amount to the situations where the processing is unlawful or where the processing is based on your consent, and you have withdrawn such consent.
- The right to restriction of processing, signifying your right to obtain restriction of processing your Personal Data from ISL’s part. Please bear in mind that this right can be exercised only in specific situations laid down by the GDPR such as when you challenge the accuracy of your Personal Data. During the period necessary for us to rectify your data, you may ask us to restrict the processing of your Personal Data.
- The right to data portability implying your right to receive the personal data in a structured, commonly used and machine-readable format and further to transmit such data to another controller. This right to data portability shall be applicable only to the personal data you have provided to us and where the processing is carried out by automated means based on your consent or for the performance of the contract you have concluded with ISL.
- The right to object to the processing of your Personal Data by ISL, on grounds relating to your particular situation. The right to object applies to the situations where ISL relies on consent as legal basis for processing (e.g. using your e-mail address for conveying fundraising related messages).
- The right to lodge a complaint designates your right to challenge the manner in which ISL performs processing of your Personal Data with the competent data protection authority.
- The right to withdraw your consent given for various processing operations, in cases where the consent represents the lawful basis for processing. In cases where you withdraw your consent to processing your Personal Data, please note that the processing will end only from the moment the withdrawal takes place without any effect on the processing that took place prior such withdrawal.
- ISL creates various profiles through automated means based on the Personal Data that pertain to students. Generally, such profiles are created via various applications used in the on-line education environment such as: MAP Testing Tool and Acadamigo.
- ISL creates and uses such profiles to evaluate the performance of its students, to identify gaps in their development or to assess specific traits that characterize students’ personality, preferences, and behavior or professional inclinations.
9. Video Surveillance
- ISL has implemented a video surveillance system on the campus, in order to ensure security of its students, staff and all the other persons that enter our premises. The security and wellbeing of our students is our primary concern and these video surveillance cameras allow us to offer real time protection.
- All areas of the campus are covered by a video camera are signalized on campus through specific banners, informing you with regard to the video surveillance conducted by the ISL.
10. Contact Point
In the situation where you may wish to exercise any of the rights listed under point 7 of this Privacy Notice or to obtain additional information or clarifications on the subject of processing your Personal Data please contact ISL, via its appointed Data Protection Officer, responsible for ensuring that ISL complies with all the requirements of the GDPR.
Contact Details of ISL’s Data Protection Officer:
E-mail address: email@example.com
Phone Number: +371 67755146