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During High Schools International’s (HSI) activities we may collect, store and process personal information about staff, students, guardians, host families, educational partners, clients and service providers, and recognise the need to treat this data in an appropriate and lawful manner. HSI is committed to complying with its obligations in respect to all personal data it handles.
The types of personal data that HSI may be required to handle includes details of current, past and prospective employees, students, guardians, educational partners, host families, suppliers, customers and others that HSI communicates with. The information, which may be held on paper or on a computer or other media is subject to certain legal safeguards specified in the General Data Protection Regulation(GDPR) (EU) 2016/679 and other regulations. The GDPR impose restrictions on how HSI may collect and process data.
In accordance with GDPR, Declan Millar is the designated ‘Data Protection Lead’ (DPL) within HSI and is responsible for all aspects of the Data Protection Policy and implementation of same.
This policy does not form part of any employee’s contract of employment and it may be amended at any time. Any breach of this policy will be taken seriously and may result in disciplinary action up to and including dismissal.
This policy sets out HSI’s rules on data protection and the legal conditions that must be satisfied in relation to the collection, obtaining, handling, processing, storage, transportation and destruction of personal and sensitive information.
If an individual considers that the policy has not been followed in respect of personal data about themselves or others they should raise the matter with the DPL.
Data – Information which is stored electronically, on a computer, or in certain paper-based filing systems. This includes IT systems and CCTV systems.
Data Subjects – For the purposes of this document includes all living individuals about whom HSI holds personal data.
Personal Data – Data relating to a living individual who can be identified from the data (or from that data and other information that is in, or likely to come into the possession of the data controller).
Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).
Data controllers – The individuals or organisations who control and are responsible for keeping and use of data.
Data users – Employees whose work involves using personal data. Data users have a duty to protect the information they handle by following HSI’s data protection security policies at all times.
Processing – Performing any operation or set of operations on data including: –
Sensitive personal data – Information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health condition or sexual life, criminal convictions or the alleged commission of an offence. Sensitive personal data can only be processed under strict conditions and will usually require the express consent of the person concerned.
Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be: –
GDPR’s are intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the DPL is, in this case Declan MIllar, the purpose for which the data is to be processed by HSI, and the identities of anyone to whom the data may be disclosed or transferred.
For personal data to be processed lawfully, certain conditions must have been met. These may include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, more than one condition must be met. In most cases the data subject’s explicit consent to the processing of such data will be required.
Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for other purposes specifically permitted by GDPR. This means that personal data must not be collected for one purpose and used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose before any processing occurs. Any employee personal data collected by HSI is used for ordinary Human Resources purposes. Where there is a need to collect employee data for another purpose, HSI will notify the employee of this and where it is appropriate will get employee consent to such processing.
Personal data should only be collected to the extent that it is required for the specific purposes notified to the data subject. Any data which is not necessary for that purpose should not be collected in the first place.
HSI and its employees must ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
GDPR requires HSI to put in place procedures and technologies to maintain the security of all personal data. Personal data may only be transferred to a third-party data processor if the third party has agreed to comply with those procedures and policies or has adequate security measures in place.
The following must be maintained: –
Security Policy / Procedures include: –
Personal data must be accurate and kept up to date. Information which is incorrect, or misleading is not accurate, and steps should be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data should be destroyed. Employees should ensure that they notify the DPL and Human Resources of any relevant changes to their personal information so that it can be updated and maintained accurately. Examples of relevant changes to data would include a change of address.
Personal data should not be kept longer than is necessary for the purpose. For guidance in relation to data retention employees should contact their manager. HSI has various legal obligations to keep certain employee data for a specified period. In addition, HSI may need to retain personal data for a period to protect its legitimate interests.
Data must be processed in line with data subject’s rights. Data subjects have a right to: –
A formal request from a data subject for information that HSI holds about them must be made in writing. Any employee who receives a written request in respect of data held by HSI should forward it to the Data Controller.
Any employee dealing with telephone enquiries should be careful disclosing any personal information held by HSI over the phone. The employee should: –
At HSI, it is our policy not to contact any potential individuals without their permission. To comply with this policy, our pre-sales employees are requested to ensure the following: –
HSI will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives on at least an annual basis and more frequently if required considering changes in the law and organisational or security changes.