Privacy Policy

We may collect and process the following Personal Data about you and any Student you are responsible for.

1. What Personal Data do we process?

We may collect and process the following Personal Data about you and any Student you are responsible for:

Biographical and identification information ► including name, gender, nationality, date and place of birth, details of family members, passport and national identity information;

Contact information ► including address(es), telephone number(s), email address(es), emergency contacts;

Student information ► this includes admission information (e.g. tests scores), start date, year group, class information, school ID, grades, notes, timetables, transport routes, photographs and communications with Parents or Guardians, teachers and other Students and information relating to reports made by/concerning Student (e.g. bullying reports etc.).

Payment information ► including bank account and credit/debit card information;

Our correspondence ► where we are contacted by you or a Student you are responsible for, we will keep a record of that correspondence;

Website and communication usage ► details of visits to our websites and information collected through cookies and other tracking technologies including, but not limited to, IP address and domain name, browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that are accessed;

Information you have provided to us ► any additional information that you or a Student you are responsible for may provide to us, such as through completing enquiry or feedback forms.


2. How we use your Personal Data

Your Personal Data (and that of any Student you are responsible for) will only be processed where we have a specific purpose, and a lawful basis, for doing so. These purposes and bases are listed below. An explanation of the scope of the grounds available can be found at Lawful Bases.

(a) To select, onboard and enrol Students ► to process application forms, tests, interviews, travel arrangements and all activities relating to the Student’s enrolment in a School. This may in certain limited circumstances include Special Categories of Personal Data, for example, photographs and video footage of Students, (eg. for identification or security purposes); or Criminal Conduct Data, for understanding the background of potential Students;

Lawful bases: contract performance; legitimate interests (to enable us to perform our obligations and provide our services). In the limited circumstances where we need to process Special Categories of Personal Data or Criminal Convictions Data, we may also rely on explicit consent.

(b) To manage the Student’s academic, sporting and boarding timetable and to provide access to the School’s communication networks► to schedule the Student’s activities and provide access to the School’s intranet and other information storage communication tools;

Lawful bases: contract performance; legitimate interests (to enable us to perform our obligations and provide our services)

(c) To develop and support Students ► To assess and coach Students through dialogue and record keeping and suitability for current and future internal and external opportunities. This may in certain limited circumstances include Special Categories of Personal Data, such as:

(i) Political opinions, religious beliefs, ethnicity and race, so that Students can observe religious/cultural celebrations; and
(ii) Sex life or orientation, so that we can advise and respond to any sensitive issues that may arise.


3. Use of Special Categories of Personal Data and Criminal Conduct Data

As a general rule, we do not process Special Categories of Personal Data or Criminal Convictions Data of Students, Parents or Guardians. However, in order to provide our education and schooling services (including extra-curricular activities) effectively to you and any Student you are responsible for, we are, in certain very limited circumstances, required to collect, process and disclose Special Categories of Personal Data of Students, including but not limited to:

(a) Health/medical information (e.g. allergies, disabilities, dietary requirements, records of accidents and illnesses) so that we can maintain a safe environment for all Students;
(b) Political opinions, religious beliefs, ethnicity and race, so that Students can observe religious/cultural celebrations;
(c) Sex life or orientation, so that we can advise and respond to any sensitive issues that may arise;
(d) Details of criminal offences, so that we can deal with serious behavioural issues and authorities appropriately; and
(e) Photographs and video footage of Students, (eg. for identification or security purposes)

In addition to the usual appropriate technical and organisational measures we implement to ensure the security and integrity of the personal data processed by us, we may implement additional measures in relation to Special Categories of Personal Data, as appropriate. These may include segregation, pseudonymisation or restriction of access to the data.

Where we must process Special Categories of Personal Data and Criminal Convictions Data, we will generally do so on the basis that we are protecting the vital interests of a Student or that it is necessary for reasons of substantial public interest.

Where we cannot rely on an alternative legal basis to justify necessary processing of the data listed above we will either:

(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.

Where a Student you are responsible for is capable of providing consent with respect to the processing of his/her personal data, you agree that you have procured his or her consent to our collection, processing and disclosure of the above Special Categories of Personal Data. Once a Student is competent to provide this consent, we will reaffirm with them any consent previously provided by you on their behalf.

In any instance where a Student who was deemed to be capable of providing consent acts against his/her own best interests, we will revert to you to obtain your consent on his/her behalf.

You (or the Student you are responsible for, as applicable) are free to withdraw your consent at any time by contacting us. However, where you do so we may not be able to provide a service that requires the use of such data.