Prem Tinsulanonda International School (hereafter referred to as “Prem”) will collect, process and store the personal data of parents, students, staff, service providers, volunteers, candidates and interns.
Prem has adopted the following policy in line with international privacy standards and applicable data protection regulations on the protection of privacy in relation to the processing of personal data.
1. How we use personal data
The School collects Personal Data and sensitive categories of Personal Data of students, parents, employees and alumni to provide a safe and caring international environment for teaching, learning and general educational purposes. We use the information you provide for purposes that are necessary and required to undertake the performance of the contract into which you are entering or have entered into and do so as we are required to do by law.
We use the information you provide in the following ways:
- to provide a safe learning environment
- to undertake and manage Prem admissions and enrollment
- to comply with child protection requirements
- to support and enable the academic, pastoral and personal objectives of children, including the monitoring and reporting of progress
- to provide support and care for emotional and psychological wellbeing (pastoral and counselling)
- to protect the health of the students and employees we serve
- to provide a tailored learning environment and make evidence based education decisions for the children we serve
- to enable students to take part in standardised or external assessments
- to enable the children we serve to continue or progress their education at other educational organisations
- to monitor (where appropriate) the responsible and safe use of IT and communication systems
- to support and develop our employees in the performance of their duties
- for financial planning to help in the future planning and resource investment purposes
- to meet our statutory reporting requirements to the education and other authorities
- to help investigate any concerns or complaints you may have
- to ensure campus security including video surveillance
- to make you aware of services, information, news, events and activities that are undertaken at or in association with Prem
- to maintain relationships with alumni and the extended Prem community
- to respond to requests from former employees, parents and students for information related to their time at Prem
2. Basis on which Prem processes personal data
We process personal data to carry out the education services as prescribed above. We do so under the lawful basis that the processing is necessary for the performance of a contract in which you are entering or have entered into. In some circumstances, we may have to process data for other purposes that are not necessary for the performance of the contract. In such cases, the processing may be based upon (i) our legitimate interests, such as providing a safe learning environment, maintaining the Prem community, fundraising, etc., (ii) on the protection of you or your children’s vital interests, (iii) on the compliance with our legal obligations and/or (iv) on the consent you or your children may have provided to us.
3. Categories of personal data processed by Prem
- personal information (such as name, unique number and address)
- special categories of data (such as health information, ethnicity)
- educational and evaluation data (such as assessments, relevant medical information, special educational needs information, exclusions / behavioural information and psychological reports and assessments)
- attendance information (such as sessions attended, number of absences and absence reasons)
- logging and audit in the use of IT systems and education technology apps, applications and cloud based systems
- communication and correspondence data (such as emails, letters and other types of correspondence)
- photographs and videos
Special categories of data
The education services we provide require us to collect and process special categories of data for the purposes of safeguarding, the protection of vulnerable children, and wellbeing of those within our care. We do not disclose or share special categories of data without explicit and unambiguous consent unless we have to do so where we are required to by law, or where we have good reason in protecting the vital interests of an individual, or where not doing so would place someone else at risk.
Special categories of data such as nationality or health may be used from time to time in forecasting and planning for education service provision. Where used in this way, the data will be anonymised.
4. Photographs and Videos
Photographs and videos are a key medium through which to record and share everyday life at Prem to the parents, students, employees, alumni, the extended Prem community, prospective families and the general public. Prem uses such media for promotional purposes, including but not limited to: the Prem website, printed publications, electronic newsletters and Prem social media. Photographs and video are also generated for educational purposes (records of lessons, field trips, sports, events, staff professional development) by faculty and students and play an important role in the delivery of our teaching and learning programme. As members of the Prem community, parents, students, employees and alumni may be photographed or filmed and these photographs or film used for promotional or educational purposes.
Photographs or videos used for promotional purposes will not identify individuals by their full name. If individuals are identified by name then this will only be done with prior consent.
We collect information in the form of camera footage via our CCTV-systems to ensure the safety and security of students and staff. We retain these CCTV images for 25 days after which they are deleted, unless we need to retain the images for further investigation or law enforcement purposes.
6. Cookies & Tracking
Prem utilizes Google Analytics in tracking visitors to the Prem website. This information is not used to identify personal information, nor is it used for any purpose other than improvement of the website based on identifiable trends. Cookies – small pieces of information stored on your computer to indicate sites that you have visited – are used only in conjunction with Google Analytics for the purpose of enhancing the Prem website. These cookies are not used to gather personal information about visitors, and no other visitor tracking is conducted. Additional information about Google Analytics and privacy is available on the Google Support website.
7. Sharing and Transfers of personal data
Your personal data will be shared internally within Prem for the purposes of delivering the services required.
For the purposes described in Article 2 of this Notice, Prem may need to share your personal data externally with certain recipients, as well as with third parties processing your data on behalf of Prem. More specifically, this includes the following categories of recipients:
- Schools, colleges or universities that the students attend after leaving Prem; Other international schools (amongst others for the purposes of trips, sports and activities);
- Family nurses, doctors or social service organisations (amongst others where sharing is in the vital interests, or where not sharing could have a negative impact on the individual);
- Providers of information systems that are necessary for Prem to deliver the admissions, administration, teaching and learning, pastoral development, and child protection services;
- Providers of IT hosting and maintenance services;
- Government organisations, police, health and social care (where we are required to do so by law, or where we have obtained your consent to do so).
Personal data may also be transferred to other data processors. For such transfers of personal data, Prem has implemented suitable safeguards.
8. Your rights
Parents and students may exercise a number of rights with regard to the processing of their personal data.
The first point of contact in connection with the processing of personal data and the exercise of the rights described below is the Data Protection Officer at Prem. Prem shall respond to such requests and may or may not act upon them as soon as is reasonably practicable and in any event within statutory time-limits of a period of one month, all in accordance with applicable data protection legislation.
The rights which you may have under applicable data protection legislation are:
- Right to be informed – be informed of how we are processing your Personal Data – this Privacy Notice serves to explain this.
- Right of access – right to request access to information about you that we hold. Note that certain data is exempt from the right to access. This includes information that identifies other individuals or any confidential reference given by Prem for the purpose of the education, training or employment of an individual.
- Right to rectification – have your data corrected if it is inaccurate or incomplete
- Right to erasure – allows you to be able to request the erasure of personal data in some circumstances such as where it is no longer needed by us for the purpose for which it was collected or you have withdrawn your consent. The right to erasure is not an absolute right.
- Right to restrict processing – the right to request the restriction or suppression of your personal data in certain circumstances for example, where you have told us the data is inaccurate and we are in the process of checking this. In such circumstances we will continue to store your data but will not process it further until we have checked and confirmed whether the data is inaccurate. Not, like the right to erasure, the right to restrict processing is not an absolute right.
- Right to data portability – allows you to receive personal data that you have provided us in a structured, commonly used machine readable format. It also allows you the right to request us to transmit this data to another controller.
- Right to object – allows you, in certain circumstances, to object to the processing of your personal data. For example, you may object to processing of your data for direct marketing or to object to automated individual decision-making (making a decision solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain things about an individual). Another example would be to object to processing of Personal Data that is likely to cause, or is causing, damage or distress.
Where the processing of your personal data is based upon consent, you and/or your child have the right to withdraw consent at any time. Such withdrawal of consent shall not affect the lawfulness of the processing based on consent before the withdrawal.
There may be instances where you may not want us to process or share your personal information. In these cases, we may not be able to fulfil the service you need, or do so in a limited way, or be able to comply with a statutory obligation. In those instances, we will not be able to comply with your request and we will tell you if this is the case.
For any questions or concerns relating to this Notice or the processing of your personal data by or on behalf of Prem, as well as for the exercise of any of the rights described in Article 10 of this Notice, please contact the Data Protection Officer (firstname.lastname@example.org)