(a) Rely on your explicit consent for the collection, processing and disclosure of the above Special Categories of Personal Data on behalf of each Student you are responsible for; or
(b) Where a Student you are responsible for is capable of providing consent with respect to the processing of his/her personal data, rely on his or her explicit consent to our collection, processing and disclosure of the above Special Categories of Personal Data.
We may obtain Personal Data from you (or any Student you are responsible for) directly, or from third parties such as other educational or sporting institutions, credit reference and anti-fraud agencies, sanctions and politically exposed persons screening lists, our business partners and public registers.
Security over the internet
No data transmission over the Internet or through a website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Data, and that of any Student you are responsible for, in accordance with data protection legislative requirements.
All information you, or any Student you are responsible for, provide to us is stored on our or our suppliers’ secure servers and accessed and used subject to our security policies and standards. We ask that you, or any Student you are responsible for:
(a) Refrain from sharing any password providing access to certain parts of our websites, applications or systems with any other person; and
(b) Comply with any other security procedures that we may notify you of from time to time.
Export outside the EEA
Your Personal Data, or that of any Student you are responsible for, may be transferred to, stored in or accessed by staff or suppliers in, a destination outside the European Economic Area (EEA). Regardless of location, we will impose the same data protection safeguards that we deploy inside the EEA.
Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export Personal Data to these jurisdictions. In countries which have not had these approvals, (see the full list here
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm) we will transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.
Please contact us if you would like to see a copy of the specific safeguards applied to the export of Personal Data relating to you or any Student you are responsible for.
Storage limits
We will Personal Data for as long as is necessary for the processing purpose(s) for which they were collected and any other permitted linked purpose (for example certain transaction details and correspondence may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data). So if Personal Data is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period one that period expires. We restrict access to Personal Data to those persons who need to use it for the relevant purpose(s).
Our retention periods are based on business needs and relevant laws. Records that are no longer needed are either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.
Your Personal Data obtained on the basis of the above consent will be processed during the term of the contractual relationship between you / Student and NAE and three years after its termination, or until revocation of the given consent.
6. Rights relating to Personal Data
Be aware of the rights that Data Subjects have in relation to their Personal Data
Data Subjects have a number of rights relating to how their personal data is used. Please be aware that certain exceptions apply to the exercise of these rights and so you will not be able to exercise them in all situations. In addition, these will vary slightly between EU member states. If you wish to exercise any of these rights we will check your entitlement and respond within a reasonable timescale.
Students may be able to exercise these rights independently, provided that they have Legal Capacity.
Where applicable, you will have the following rights relating to your Personal Data or the Personal Data of a Student you are responsible for:
Subject Access: Be provided access to any data held about you by NAE. This information will generally be provided within one month of us confirming your identity and understanding scope of your request.
Rectification: Require to have inaccurate Personal Data amended.
Erasure: Require us to erase Personal Data in certain circumstances. If the Personal Data has been made public, reasonable steps will be taken to inform other controllers that are processing the data that you have requested the erasure of any links to, copies or replication of it.
Withdrawal of consent: Withdraw any consents to processing that you have given us and prevent further processing, if there is no other ground under which we can rely to process your Personal Data
Restriction: Require certain Personal Data to be marked as restricted in some circumstances, for example, whilst we resolve any complaint we may have received. Restriction means that whilst we still store the data, we will not process it until such time as the restriction may be lifted.
Portability: Have a copy of any Personal Data you have provided to us returned to you, or transmitted to another controller in a commonly used, machine readable format
Prevent processing: Require NAE to stop any processing based on the legitimate interests ground unless NAE’s reasons for undertaking that processing outweigh any prejudice to your data protection right.
Marketing: Require NAE to prevent processing of your Personal Data for direct marketing purposes.
Raise a complaint: Complain to your local Data Protection Authority about our processing of your Personal Data.
If you have any queries relating to your rights or exercise of your rights, please contact us
7. Changes to our PICS and Cookies Policy
Our PICS and our Cookie Policy may change from time to time in the future. We therefore encourage you to review them when you visit the website from time to time to stay informed of how we are using Personal Data.
This PICS was last updated on 24 May 2018.
8. Lawful Bases
Use of Personal Data under EU data protection laws must be justified under one of a number of Lawful bases and we are required to set out the Lawful bases in respect of each use in this policy. We note the Lawful bases we use to justify each use of your information next to the use in the “Uses made of your Personal Data” section of this PICS.
These are the principal Lawful bases that justify our use of your Personal Data:
Consent: You have given your consent to the processing of those personal data for one or more specified purposes. You are free to withdraw your consent by contacting us using the details set out at Annex C. Where you do so, we may be unable to provide a service that requires the use of such data.
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Contract performance: where your information is necessary to enter into or perform our contract with you.
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Legal obligation: where we need to use your information to comply with our legal obligations.
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Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
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Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
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These are the principal Lawful bases that justify our use of Special Categories of your Personal Data, in the limited circumstances where it is necessary to do so:
Explicit consent: You have given your explicit consent to the processing of those personal data for one or more specified purposes. You are free to withdraw your consent by contacting us using the details set out at Annex C.. Where you do so, we may be unable to provide a service that requires the use of such data.
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Protection of vital interests of you or another person, where you are unable to consent: Processing is necessary to protect the vital interests of you or of another natural person where you are physically ore legally incapable of giving consent.
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For legal claims: Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
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In the substantial public interest: Processing is necessary for reasons of substantial public interest, on the basis of EU or local law.
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9. Definitions
The following terms are used in this PICS:
Criminal Convictions Data: In the EU, Personal Data relating to criminal convictions or offences or related security measures may only be processed when authorised by Member State or EU law.
Data Controller: this is the person which alone or jointly with others determines the purpose and means of the processing of Personal Data. NAE is the Data Controller of all employment details used in its business.
Data Subject: for the purpose of this policy this includes all living individuals about whom we hold Personal Data, including employees, Students, Parents or Guardians, suppliers and business partners. A Data Subject need not be a national or resident of the country the concerned NAE business is based in. Within the EU, all Data Subjects have legal rights in relation to their Personal Data.
Data Processor: this is the person which processes Personal Data on behalf of the Data Controller (not including employees of the Data Controller). NAE’s suppliers and agencies that handle Personal Data on our behalf will be Data Processors.
Guardians / Parents: this means any parents or guardians responsible for a Student.
NAE, Our, Us, We: Nord Anglia Education (which includes each of the companies and Schools listed on our website).
NAE: our London based Headquarters, Nord Anglia Education, 4th Floor, Nova South, 160 Victoria Street, London, SW1E 5LB .
Our, NAE, Us, We: Nord Anglia Education (which includes each of the companies and Schools listed on our website).
Parents / Guardians: this means any parents or guardians responsible for a Student.
Personal Data: this is defined as any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified (either directly or indirectly) by reference to an 'identifier'. These include names, ID numbers, location data, online identifiers or one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of that person.
School(s): this means any school within the Nord Anglia Education Group.
Special Categories of Personal Data: this type of data is, in the EU and some other countries, subject to more stringent processing conditions than other Personal Data and in the EU includes Personal Data which reveals racial or ethnic origin, political opinion, religious or philosophical beliefs, trade-union membership, and the processing of genetic data, biometric data in order to uniquely identify a person or data concerning health, sex life and sexual orientation. Data concerning health covers Personal Data relating to the physical or mental health of an individual which reveals information about the individual's health status. In the EU, Personal Data relating to criminal convictions or offences or related security measures may only be processed when authorised by Member State or EU law. In other countries the term Special Categories of Personal Data may include other categories of information such as financial information and passwords. If in doubt, please contact the Data Protection Officer.
Student: this means any prospective, past or present student of a School.
Us, NAE, Our, We: Nord Anglia Education (which includes each of the companies and Schools listed on our website).
We, NAE, Our, Us: Nord Anglia Education (which includes each of the companies and Schools listed on our website).
10. Contact Us
Entity name
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Address
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Contact for data protection (and role)
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EEA Data Protection Authority
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Nord Anglia Education Limited
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4th Floor, Nova South, 160 Victoria Street, London, SW1E 5LB
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Jon Townsley
Global Compliance Officer
+44 20 7131 0139
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Nord Anglia International School LLC
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Office No. 001, Level 100, Arenco Tower, Media City, Dubai
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As above
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N/A
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Collège Champittet SA
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Chemin de Champittet, c/o Collège Champittet Switzerland
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As above
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N/A
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NAE Hong Kong Limited
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18th Floor, Edinburgh Tower, The Landmark, 15 Queen’s Road Central, Hong Kong
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As above
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N/A
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Cookie Policy
Consent
By using this website (the Website) of Nord Anglia Education, a company within the group of Nord Anglia Education Limited (NAE, we, our or us), you consent to the use of cookies in accordance with this Cookies Policy. You will have seen a pop up to this effect on your first visit to this Website; and although it will not usually appear on subsequent visits you may withdraw your consent at any time by following the instructions below.
What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. Most web pages contain elements from multiple web domains so when you visit the Website, your browser may receive cookies from several sources.
We use the cookies on this website to help you navigate our website efficiently, perform certain functions and to collect site statistics. These cookies do not store any personal information that would, on its own, allow us to identify individual users of this service without your permission. Please be aware that restricting cookies may impact on the functionality of the website and could mean that key features do not work properly. We strongly recommend allowing cookies from this website so that we can provide you with a full service.
What type of cookies do we use?
We use a number of suppliers (3rd Party) who also set cookies on our website on our behalf in order to deliver the services that they are providing. If you would like more information about the cookies used by these suppliers, as well as information on how to opt-out, please see the information in the tables provided below.
To help you make an informed decision, we have categorised the cookies used on this site into two categories;
Necessary cookies – these cookies are fundamental to ensure the site works correctly.
Optional cookies – These cookies could help us track how you use the website so that we can improve the information and experience provided to you. They may also provide additional features by 3rd party providers to allow you to socially share content or comment on this website.
Necessary cookies
Provider
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Cookie
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Expires
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Description/Purpose
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Nord Anglia Education Limited
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ASP.NET_SessionId
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End of Session
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This session cookie is used to store anonymous details about the pages visited by you on this website and is required to provide this functionality to you. If you do not allow this cookie this website will not work correctly
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Nord Anglia Education Limited
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AcceptCookies
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Never
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This cookie that tells us that you have accepted cookies from this site and allows us to stop showing you the same message each time you visit the site.
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Optional Cookies
Provider
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Description/Purpose
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Google Analytics
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These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. We use this Plug-in to allow us to provide a better user experience to you and only use it on the basis that Google adheres to its own Privacy Policy.
The Google Privacy policy
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Add This
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These Cookies are used to collect information from visitors to our site. The cookies will gather analytics on how often the webpage is shared. We use Add This to help us market our business using Social Sharing functionality. We use this Plug-in as a convenience for our users and only use it on the basis that Add This adheres to its Privacy Policy.
The Add This Privacy Policy
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YouTube videos
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These Cookies are used by YouTube follow your preferences and track the usage of content supplied by YouTube. The Cookies collect information in an anonymous form to help you keep your preferences when viewing content and to supply you with tailored relevant search results. If you have a Google account and are logged in this data can be linked to your personal profile.
YouTube Privacy Policy
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How to control and delete cookies
We will not use cookies to collect personally identifiable information about you unless you willing provide it. However, if you wish to restrict or block the cookies which are set by this website, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how.
Alternatively, you may wish to visit
www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
We do not use ’spyware’, that is web bugs or hidden identifiers or other similar devices to gain access to information, store hidden information or to trace your activities.
Traffic data
We keep a record of traffic data which is logged automatically by the server. This includes your IP address, the website address you visited before ours, the website address you visit after leaving our site and which pages you visit on our site. We do not store or analyse this traffic data in a way that identifies any individual. We also use Google Analytics for site statistics – see 'Cookies’ above for details of how this works.