PRIVACY POLICY

DATA CONTROLLER:

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

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 in accordance with 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 appropriate 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; and
  • Religion or ideology.
     

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

We process your information on the basis of the consent provided by you, as well as for the performance of a contract and to comply with the legal obligations that may derive from it. We may also process your information on the basis of a legitimate interest of King’s College School The Bahamas when sending commercial communications about our activities.
 

5. PURPOSES AND LEGITIMATION FOR WHICH WE PROCESS PERSONAL DATA

We collect your personal data with the following purposes:

  • To attend your queries or any type of request made through the contact form that is available on our website.
  • To ensure that the student meets the School’s admission criteria;
  • To manage the admission and application process; 
  • To provide educational services including the support of pupil learning, monitor and report on pupil progress;
  • To manage and provide the activities for the Inspired Summer Camp and Global Exchange Programme; 
  • To provide to the students welfare, medical and nurse attention, catering service and school transportation, among other additional School’s services;
  • To administrate the Parent Portal and other platforms; 
  • To meet the educational, social, physical and emotional requirements of our students;
  • To 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.;
  • To 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 history of the 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 express consent from parents or students of legal age;
  • Carry out market research and statistical analysis.
     

6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We do not share your personal information with third parties unless it is necessary for the purposes previously exposed or when it is required by law. The personal data object of processing may only be communicated to other Schools within Inspired Education Group with the prior written consent of the data subject and the personal data will be processed with the same legitimate purposes mentioned herein.
 

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 dpo@inspirededu.com. 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.  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.
 

13. 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.
 

14.  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 dpo@inspirededu.com. 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.
 

15. 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 on October 2022.