DATA PROCESSOR (PARENTAL COMPANY):
INTERNATIONAL SCHOOL OF EUROPE S.P.A.
Sede legale: Via Manfredo Camperio,
14 - 20123 Milano
Cod. Fisc. - P.IVA e registro imprese di Milano n. 12932001006 - REA (MI) n. 2046718
DPO Email address: email@example.com.
ISE SCHOOLS (Monza, Milán, Ticino, Como, Modena, Siena, Bergamo, and Kiddy).
INTERNATIONAL SCHOOL OF EUROPE S.P.A. is part of Inspired Education Holdings Ltd., which is a company registered in United Kingdom with number 09268120 and registered address at Sixth Floor, 3 Burlington Gardens, London, W1S 3EP. Inspired operates numerous affiliated schools globally via its regional offices in Europe, Africa, Middle East, Asia-Pacific and Latin America.
This policy is drafted in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and the Italian implementation by Legislative Decree n. 101 dated 10 August 2018.
Our Data Protection Officer can be contacted by email at the address firstname.lastname@example.org if you have any queries regarding the processing of your personal data.
2. TYPES OF PERSONAL DATA WE PROCESS
ISE SCHOOLS, as Data Controllers, collect and process directly personal data from the students and their families and / or legally authorised individuals on their behalf and also from job applicants, employees, candidates, suppliers, contractors, prospective customers and third parties interested in finding out more about ISE Schools.
The personal data processed are mainly the following:
- Names, addresses, telephone numbers, e-mail addresses and other contact details;
- Family details;
- Safeguarding information (such as court orders and professional involvement)
- Education and employment data;
- Images, audio and video recordings, including CCTV footage (video images);
- Financial information;
- Educational centres previously attended
- Language, nationality and location.
Other types of data we may collect and process, according to the ISE Schools’ purposes, are related to sensitive information related to an individual, such as:
- Information about health status or provision of health care linked to a specific individual;
- Behavioural information;
- Special educational needs
- Criminal records linked to a specific individual;
- Biometric information;
3. HOW WE COLLECT AND PROCESS PERSONAL DATA
ISE Schools collect information in several ways, including:
- Personally and over the phone;
- Through our webpage, including information received through the following sections: Application form for admission process, general enquiries form, Contact Us, Work With Us (recruitment) and subscription to our newsletters or communications;
- From email and hand delivery paper documentation: including job applications, emails, invoices, letters, consent forms;
- Through online tools: such as apps, educational platforms and other software used by our staff;
- Through any CCTV cameras located at our premises or sites;
- Through third parties, such as referees, professionals or authorities working with the individual;
4. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
ISE Schools process personal data to lawfully and legitimately carry out the school’s educational activity. The school collects and keeps students and parents’ information when necessary:
- To ensure that the student meets the school’s admission criteria;
- To provide educational services including the support of pupil learning, monitor and report on pupil progress;
- To provide to the students welfare and pastoral care services;
- To provide to the students medical and nurse attention, catering service and school transportation, among other necessary services;
- To manage Summer Camps activities;
- To meet the educational, social, physical and emotional requirements of the student;
- To comply with legislative or administrative requirements;
- To enable parents/guardians to be contacted in the case of emergency or in the case of school closure, or to inform parents of their child’s educational progress or about school events, etc.
- With the aim to celebrate school’s achievements and to keep a record of the history of the school, ISE Schools may take photographs and recorded images of students to be shared in, e.g. yearbooks, school website, etc, always based on informed consent from parents or students of legal age;
- To send commercial communications if previously requested and authorised by the data subject. Such communications will include: newsletters and advertisements through e-mail, social networks or any other electronic or physical means, present or future. You will be able to unsubscribe from the receipt of commercial communications by clicking in the “unsubscribe” section found in all these kind of e-mails sent by the school.
- In the case of a CV received through our webpage, in the section “Work With Us”, with the purpose to include the job applicant in a current selection process or to consider their application for future positions; In this regarding, the school also collects information about staff and prospective staff when necessary for:
- Conducting the selection process;
- Assessing the suitability of the candidate for the position;
- Administration of staff records;
- Recruitment of staff;
- Administration of payroll, pensions and sick leave;
- Staff appraisal;
- Disciplinary procedures;
- Administration of human resources records;
The personal data object of processing may only be communicated to other schools within the Inspired group with the prior written consent of the data subject and the personal data will be processed with the same legitimate purposes mentioned herein.
5. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
ISE Schools may be lawfully required to share personal information with relevant authorities or third parties as permitted on statutory grounds, to comply with legal obligations or on the basis of a specific consent given by the individual concerned.
We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party.
The parties to whom we may disclose your personal data as above referred may be located in countries outside the ISE Schools’ location, including countries which may offer a lower level of data protection.
In such cases, we will implement appropriate measures to ensure adequate protection of your personal data in accordance with applicable data protection legislation.
Your personal data shall be neither rented nor sold to third parties.
6. CONSERVATION OF DATA
Personal information will only be retained for the period of time required to fulfil the purpose for which it was collected unless for a longer time for public interest archiving, scientific or historical research, or statistical purposes. Once the personal information is no longer required or permitted to be retained for legal or business purposes, it will be destroyed or made anonymous.
7. YOUR RIGHTS
Under the data protection regulations, you have rights regarding the processing of your personal data. These rights are, however, subject to certain exemptions and limitations.
You have the right to:
- Be informed, at the time when personal data is collected, about the data processing.
- Access the information we process and how we process it as well as to obtain a copy of the personal data considering the legal limitations and exceptions;
- Ask for the erasing of the personal data we hold about you without undue delay considering the legal limitations and exceptions;
- Obtain the rectification of your personal data providing a supplementary statement;
- Obtain restriction of processing of your personal data when it is inaccurate, illegal, unnecessary or not verified, considering the legal limitations and exceptions;
- Obtain data portability of your personal information in a structured, commonly used and machine-readable format. This allows the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided;
- Object to processing for direct marketing purposes;
- Withdraw consent at any time and freely to the processing of your personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Therefore, individuals will be able to exercise their rights by sending a written specific request, along with a copy of their ID card, to the Data Protection Officer’s email address email@example.com.
You will have the right and possibility to withdraw your consent for any specific purpose granted at any given time without prejudice of the legality of processing according to the consent given before withdrawal.
9. STORING AND SECURING INFORMATION
ISE Schools shall use the appropriate technical and organisational measures to ensure the security, confidentiality, integrity and privacy of the personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the files.
ISE Schools will not collect and process data from minors (children under 14). Parental consent or authorisation from a legal representative will be required.
If you consider we didn’t attend your request, you also have the right to lodge a complaint before the Garante per la Protezione dei Dati Personali, at: firstname.lastname@example.org. or visiting the link: https://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-tuoi-dati-personali, although it is recommended that previous steps are taken to resolve the matter with ISE Schools before involving the authority.
12. PRIVACY NOTICE UPDATES
ISE Schools may need to update this privacy notice periodically so we recommend that you review this information from time to time.
This version was last updated on May 2022