Privacy | FFL - Foundations for Learning

INTRODUCTION

Welcome to the website of the Foundations for Learning (“FFL”, “we”, “our”). We respect the privacy of the users of our website and are committed to protecting personal data according to data protection laws and best practices.

This document applies to all visitors to our website. The FFL website includes both the publicly accessible and login protected pages under the domain foundationsforlearning.ch

USE OF PERSONAL DATA

We do not collect any personal information through this site unless you voluntarily provide it. Unless otherwise stated, we use personal data such as name, address, phone number or email to update your profile, to respond to a request that you have made or to contact you.

ANALYTICS

We use website statistic packages such as Google Analytics to analyse trends in how our website is accessed and utilised. Information monitored includes internet protocol (IP) addresses, geographic location of visitors (country, city), browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, time spent on pages, and keywords used to find our site via search engines. This information is anonymous and cannot be directly linked to individual users. We may use it to identify high-use or low-use areas of the site, pinpoint problem areas of the site, analyse broad demographic trends in our visitors and make decisions about how to make it easier for people to find and navigate our website.

A cookie is a small text file stored by your browser that allows the website to “remember” your preferences (such as calendar settings and site bookmarks) on the site from visit to visit, or to maintain your “logged in” status when visiting protected areas. Usage of a cookie is in no way linked to any personally identifiable information while on our site. Web browsers have settings allowing you to reject cookies or selectively accept cookies, or delete cookies previously accepted. More information about cookies, including how to block them on all sites or delete them, can be found at https://www.aboutcookies.org. Please be aware that rejecting or deleting cookies from our website may make certain functions unavailable to you.

If you don’t want Analytics to be used in your browser, you can install the Google Analytics browser add-on. More information about the ways in which Google Analytics collects and processes personal data can be found here: https://www.google.com/policies/privacy/partners.

LINKS

This website may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.

SECURITY

This website takes every precaution to protect the personal data of our site users. Whenever users submit personal data, it is encrypted via the highest level of SSL (Secured Sockets Layer) available and remains secure during all stages of transmission.

FFL complies with the relevant national data protection regulations. We are committed to keeping Personal Data accurate, up-to-date, safe, secure and will not keep Personal Data longer than necessary. This privacy notice explains how we use the Personal Data of parents, students, employees, alumni and the extended FFL community, who we share it with and the ways in which we protect and account for the protections to privacy. This notice applies to all Personal Data collected for and on behalf of Foundations for Learning. This pertains to information collected in analogue (forms, documents, in writing) and through technological means such as information systems and email. For these purposes, FFL acts as data controller which means it determines how an individual’s Personal Data is processed and for what purposes.

From time to time, we will make you aware when we require additional Personal Data for processing through a separate specific privacy notice.

FFL parents, students, employees, alumni and the extended FFL community are all encouraged to read this Privacy Notice and understand FFL’s obligations regarding data protection to its community.

FFL reserves the right to amend this privacy notice. In such case the ‘last updated’ date at the bottom of this page will be amended accordingly.

HOW WE USE PERSONAL DATA

FFL collect Personal Data and sensitive categories of Personal Data of students, parents, employees and alumni to provide a safe and caring 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 undertake and manage FFL admissions and enrolment
to provide a safe learning environment
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 make you aware of services, information, news, events and activities that are undertaken at or in association with FFL
to maintain relationships with alumni and the extended FFL community including direct marketing or fundraising activities
to respond to requests from former employees, parents and students for information related to their time at FFL.

BASIS ON WHICH FFL 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. Where this is the case, we will either have legitimate interest to do so, need to as there is a legal requirement, we have your consent, or because it is in the vital interests of the individual for us to process or share information.

CATEGORIES OF PERSONAL DATA PROCESSED BY FFL

Categories of personal data processed by FFL

personal data (such as name, AHV number, address, telephone contacts and e-mail address as well as employment information including employer, position and work contacts)
special categories of data (such as health and nationality) (see below)
other relevant categories for the performance of our services (such as assessment, relevant medical information, languages spoken, special educational needs information, exclusions / behavioural information and psychological reports and assessments)
attendance information (such as lessons 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
photographs and videos (see below).

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.

Photographs and Videos
Photographs and videos are a key media through which to record and share everyday life at FFL to the parents, students, employees, alumni, the extended FFL community, prospective families and the general public.

Images/videos of students will only be taken with written permission of parents. Parents will receive copies of any image made.

FFL may use such media for promotional purposes on, including but not limited to: the FFL website, printed publications, electronic newsletters and FFL social media. Photographs and video are also generated for educational purposes (records of lessons, field trips, sports, events, staff professional development) by staff and students and play an important role in the delivery of our teaching and learning programme.

With written consent, members of the FFL 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.

PARTICIPATING IN OUR COMMUNITY

We are keen to ensure all individuals associated with FFL can participate in the community. To do so we will use the Personal Data you have provided to make you aware of services, information, news, events and activities that are undertaken at or in association with Foundations for Learning and do so under the lawful basis of legitimate interests. We may invite you to sign up for information or to be contacted on other activities such as campus development. For the purposes of fundraising we will require your explicit consent. If at any point you do not wish to receive these updates, you can let us know by contacting the Data Protection Officer (contact details below).

COMMUNICATING WITH YOU

Where we need to contact you we may keep a record of emails, letters and other types of correspondence. Where we need to communicate sensitive or confidential information to you we may use additional and proportionate security measures to do so.

COLLECTING STUDENT INFORMATION AND CONSENT

Whilst the majority of student information you provide to us is required for the performance of a contract or by law, some of it is provided to us on a voluntary basis. In order to comply with the General Data Protection Regulation, we will inform you when we require consent to process the information. Where consent is provided you or your child are free to withdraw consent at anytime. You can contact our Data Protection Officer (contact details below) if you or your child wish to withdraw consent.

STORING PERSONAL DATA

We keep Personal Data for as long is as reasonable given the requirement of our staff and students to request historic information pertaining to their time at FFL. We do so as it would be accepted that a foundation would hold data on the achievements and experiences of the child for the purposes of their benefit in later life should they need access to that information.

SECURITY

Whilst we store and use your Personal Data we will ensure the appropriate security of your Personal Data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

SHARING AND TRANSFERS OF PERSONAL DATA

The information we collect is shared within FFL for the purposes of delivering the services required. The information we collect may also be shared with other organisations only with the explicit consent of the person or persons we are contracted to provide services for or unless we are legally obliged to do so. Any third party processors undertaking a service or contract in the delivery of the services we provide will be subject to the same confidentiality and data protection rules and procedures as FFL staff.

Example of who we may share data with assuming consent has been provided:

schools, colleges or universities that the students attend after leaving us
our local education authorities in Switzerland
family nurses, doctors or social service organisations 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 FFL to deliver the admissions, administration, teaching and learning, pastoral development, and child protection services
government organisations, police, health and social services (where we are required to do so by law, or where we have your consent to do so).

Personal Data is transferred to organisations outside Switzerland and outside the European Union for the purposes of student application for college or university. Various teaching and learning applications are also used that are based outside Switzerland. Information on these and the protections afforded by these data processors can be requested from the Data Protection Officer (contact details below).

Sharing of information of clients

IT SYSTEMS

All the Personal Data we process is processed by FFL. For the purposes of IT hosting and maintenance this information is located on servers within the premises of Foundations for Learning, Google GSuite and within hosted servers provided by our service providers. No 3rd parties have access to your Personal Data unless the law allows them to do so. Where the law allows and information is shared with 3rd parties, we ensure they have the same protections in place as we do. We cannot deliver our education services without processing the data we collect and share.

In following the principles of Article 32 – Security of Processing of the GDPR, we have in place proportionate organisational and technical measures to protect Personal Data.

YOUR RIGHTS

Under data protection legislation, individuals have certain rights related to the processing of personal data. These rights include:

Right to be informed– be informed of how we are processing your Personal Data – this Privacy Notice serves to explain this to you but do contact us if you have any questions (see Point of Contact details below).
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 FFL 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– also known as ‘right to be forgotten’ 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.
Right to withdraw consent– in those instances in which the processing of your personal data is based on consent, you have the right (subject to age provisions) to withdraw that consent.Please note that the processing will end from the moment the withdrawal takes place without any effect on the processing that took place prior such withdrawal.
Right to complain– while the first point of contact related to the processing of your personal data or in exercising any of the rights identified above should be us (see Point of Contact below), you also have the right to directly contact the Supervisory Authority in Switzerland which is:

Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1
CH- 3003 Berne
Switzerland

There may be instances where you may not want us to process or share your Personal Data. In these cases, we may not be able to fulfill 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 that’s the case.

FFL, in responding to any requests related to the processing of your personal data will do so within a month in accordance to the applicable data protection legislation.

POINT OF CONTACT:

If you would like to discuss anything in this privacy notice, or if you wish to exercise any of the rights listed under section 12 above then please contact:

Data Protection Officer dpo@foundationsforlearning.ch

August 2018