PRIVACY POLICY

DATA CONTROLLER:

KINGS COLLEGE SCHOOL, THE BAHAMAS 
WESTERN ROAD 
NASSAU, NEW PROVIDENCE 
THE BAHAMAS 

Data Protection Coordinator’s email: DataPrivacy@kingscollegeschool.bs  

King’s College School The Bahamas is part of Inspired Education Holdings Limited, which is part of Inspired Education Holdings Limited (also referred as “Inspired Education Group”). Inspired is a company registered in England with number 09268120 and registered address at Sixth Floor, 3 Burlington Gardens, London, W1S 3EP, United Kingdom. Inspired operates numerous affiliated schools globally via its regional offices in Europe, Africa, Middle East, Asia-Pacific and Latin America.

1. INTRODUCTION

This policy is drafted following the Data Protection (Privacy of Personal Information) Act 2003 (also known as “DPA”) and it is aimed to provide you information about the processing of your personal data.  
As a Data Controller we have a statutory duty of care to data subjects as regards the collection and handling of their personal data, subject to certain legal exceptions. With regard to the collection, processing, keeping, use and disclosure of personal data, data controllers are obligated under Section 6 of the DPA to ensure that data are: 

  • Collected by means which are both lawful and fair; 

  • Accurate, and where necessary, kept up to date; 

  • Kept only for one or more specified and lawful purposes; 

  • Not used or disclosed in any manner incompatible with that purpose/those purposes; 

  • Adequate, relevant and not excessive in relation to that purpose/those purposes; 

  • Not kept longer than is necessary for that purpose/those purposes (except in the case of personal data kept for historical, statistical or research purposes). 

Further, we are obliged to utilise proper security measures that will prevent against unauthorised access to, or alteration, disclosure, destruction or accidental loss of data.

2. TYPES OF PERSONAL DATA WE COLLECT AND PROCESS

The personal information collected and processed from our students and their families or their legal representatives is the following: 

  • Contact details, including familiar or emergency information; 

  • Nationality and location; 

  • Language (s);  

  • Personal and familiar situation, siblings; 

  • Safeguarding information (such as court orders and professional involvement); 

  • Education and employment data; 

  • Schools previously attended, qualifications, reports, records, recommendations and references;  

  • Images, audio and video recordings, including CCTV footage (video images); 

  • Financial information. 

Other types of information we may collect and process, according to our purposes and the individuals’ informed consent, are related to sensitive information, such as: 

  • Medical records; 

  • Behavioural information; 

  • Special needs; 

  • Food intolerances or allergies; 

  • Sexual orientation; 

  • Criminal records linked to a specific individual; 

  • Ethnicity; 

  • Religion or ideology; 

  • Sexual identity.  

3. HOW WE COLLECT AND PROCESS PERSONAL DATA

King’s College School The Bahamas collects information directly from the individuals or legal authorised parties acting on their behalf in several ways, including: 

  • Interviews, assessments, previous schools’ reports;  

  • Over the phone; 

  • Through our website forms;  

  • Through cookies used on our website we can collect login data, browsing behaviour, settings and actions in web applications;  

  • From email and hand delivery paper documentation, including job applications, invoices, letters, consent forms; 

  • Through online tools such as apps, educational platforms and other software used by our School;  

  • Through any CCTV cameras located at our premises or sites; 

4. LAWFUL BASIS FOR PROCESSING YOUR INFORMATION

Our School processes personal data under the following basis:  

1. Execution of a contractual relationship of which the interested party is part: Student admission and enrolment, provision of educational, academic, nursing, safeguarding and related services as well as sending communications related to educational activity as well as administrative and billing management necessary for the provision of the aforementioned services; 

2. Compliance with our legal obligations: We must manage and store students’ parents and providers records as well as to attend requirements from the relevant competent authorities, in addition to the filing of legal actions;  

3. Our legitimate interest: We may need to have statistical information, as well as to carry out satisfaction surveys and to promote our activities by sending commercial communications (in addition to your consent); 

4. Your consent: We may need the consent of parents / legal guardian, or of the student over legal age to send commercial communications as well as taking and use images and videos to disseminate the student's participation in the School’s activities, or for promotional campaigns.. 

5. PURPOSES AND LEGITIMATION FOR WHICH WE PROCESS PERSONAL DATA

We collect your personal data to: 

  • Attend your queries or any type of request made through the contact form that is available on our website. 

  • Ensure that the student meets the School’s admission criteria; 

  • Manage the admission and application process;  

  • Provide educational services including the support of pupil learning, monitor and report on pupil progress; 

  • Manage and provide the activities for the Inspired Summer Camp and Global Exchange Programme;  

  • Provide to the students welfare, medical and nurse attention, catering service and school transportation, among other additional School’s services; 

  • Administrate the Parent Portal and other platforms;  

  • Meet the educational, social, physical and emotional requirements of our students; 

  • Enable parents/guardians to be contacted in the case of an emergency or school closure, to keep them informed of their child’s educational progress, school events, etc.; 

  • Send Newsletters by e-mail if the individual has previously authorised such communications and until consent withdrawal. These communications will be strictly related to our educational products and services, or our collaborators or suppliers, with whom we can reach a promotion agreement. In this case, third parties will never have access to your personal data. The data processing is fairly legitimised by the consent of the user regarding the sending of commercial communications and by the legitimate interest of the data controller to attend the data subject’s request and carry out market studies or statistical analysis according to section 6 (2) of the DPA; 

  • With the aim to celebrate school’s achievements and to keep a record of the student's stay in our school, King’s College School The Bahamas 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; With your consent, we can also share such images with Inspired Education Group for marketing purposes;  

  • Carry out market research and statistical analysis. 
      

If you want to send us your CV through the section “Careers”, you will have to create an account to make use of the employment platform and to send us your employment application. Your information will be shared with Inspired Education Group as the owner of the platform Global Careers Site in the terms exposed at: https://careers.inspirededu.com/data-privacy-statement   and incorporated in the files owned by King’s College School The Bahamas as the data controller. The King’s College School The Bahamas Human Resources department will process your data with the purpose to include your candidacy in our selection processes. 

6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

When necessary to provide the services, or for compliance with a legal and / or contractual requirement, we must share your personal data with third parties such as service providers and / or public authorities, such as the Ministry of Education or other official entities. 

Personal data may also be communicated to other school within Inspired Education Group, when necessary (for example, a language exchange with other school), which may use them for the same purposes already mentioned. 

We may also communicate personal data to other third parties, in circumstances other than the above referred if there is the consent of the parents or legal guardian. 

Your personal data shall be neither rented nor sold to third parties. 

7. CONSERVATION OF DATA

Personal data shall be kept only for one or more specified purposes and for no longer than it is necessary, unless for historical, statistical or research purposes. Once the data are no longer required or not permitted to be retained, they will be destructed with the adequate security measures. 

8. YOUR RIGHTS

Pursuant to sections 8-11 of the DPA, you have rights regarding the processing of your personal data. These rights are: 

  • Access to 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; 

  • Obtain the rectification or, where appropriate, erasure of your personal data providing a supplementary statement relating to the matters dealt with the data; 

  • Right to prohibit processing for purposes of direct marketing, requesting to cease using any data for that purpose. 

Therefore, data subjects will be able to exercise their rights by sending a written specific request along with a copy of their ID card, to our Data Protection Co-coordinator at: DataPrivacy@kingscollegeschool.bs  

We will respond to your request not later than 40 days in the terms and procedure stipulated in Section 6 et seq. of the DPA. 

9. CONSENT

You will have the right to easily 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. 

10. MINORS

King’s College School The Bahamas will not collect and / or process information from individuals under legal age. Consent from parents or legal representatives will be always required. 

11. STORING AND SECURING INFORMATION

Appropriate security measures shall be taken to ensure the security, confidentiality, integrity and privacy of your personal data, preventing from unauthorised access, alteration, disclosure or destruction of the data and against their accidental loss, destruction or damage of the files. 

12. COMMON USE WITH SOCIAL NETWORKS AND PLATFORMS

This website contains links to parent’s portal and other useful links in addition to social networks like LinkdIn, Instagram, and Facebook. Our School is not responsible for the privacy practices or the content of such sites. You should be aware that the processing of your personal information is carried out by those sites and governed by their respective privacy policies.  

If you do not want these sites to collect and process your information, please review their corresponding privacy policies and / or disconnect from it before using our Services. 

13. COOKIES USED IN OUR WEBSITE

We use cookies to provide you with a better experience in the use of our website, as well as to store information about our visitors. This information is related to your session ID and are a way of monitoring single user access. 

The Web server is allowed to remember some information concerning the user, such as his preferences for visiting the pages of this server, name and password, products that are more interesting, etc. 

The Cookies that we use in our website and that require informed consent by the user are the functional cookies and the targeting cookies. Consent is not required for required cookies, which are those of a technical nature necessary for the operation of the website or the provision of services expressly requested by the user. 

You can find more information about our Cookies policy at: https://www.kingscollegeschool.bs/cookies-policy. 

14. TRANSFER OF PERSONAL DATA OUTSIDE BAHAMAS

The data shall not be transferred to a country outside The Bahamas unless that country has an appropriate level of protection under conditions stipulated in section 17 of DPA. 

15. COMPLAINTS

If you are not satisfied with our response, you would like to discuss anything regarding this privacy notice, or you believe we are processing your personal data disregarding the data protection regulations in force, please contact our Data Protection Coordinator at DataPrivacy@kingscollegeschool.bs. You can also file a complaint to the Data Protection Commissioner (https://www.bahamas.gov.bs/wps/portal/public/Complaints/) by sending a privacy complaint form at dataprotection@bahamas.gov.bs although it is recommended that previous steps should be taken to resolve the matter with the data controller before involving the Commissioner. 

16. PRIVACY NOTICE UPDATES

King’s College School The Bahamas 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 in June 2023.