Privacy Policy

1. Introduction

At The British International school Ukraine, (LLC Kyiv Private Comprehensive school of “British International school–Kyiv and LLC “Education Establishment “Dnipro Secondary Comprehensive school “British International school — Dnipro”) we take our responsibilities as a data controller seriously and are committed to using the personal data we hold in accordance with the law. This privacy notice provides detailed information about how we process personal data. Please read it carefully and, if you have questions regarding your personal data or its use, please contact the IT and Learning Technologies Manager, Pechersk Campus, 1 Dragomirova St, Kyiv.

2. Types of personal data we process

We process personal data about prospective, current and past: students and their parents; staff, suppliers and contractors; donors, friends and supporters; and other individuals connected to or visiting our campuses (including students enrolled on our holiday courses). The personal data we process takes different forms – it may be factual information, expressions of opinion, images or other recorded information which identifies or relates to a living individual. Examples include:

• names, addresses, telephone numbers, e-mail addresses and other contact details;
• family details;
• admissions, academic, disciplinary and other education related records, information about special educational needs, references, examination scripts and marks;
• education and employment data;
• images, audio and video recordings;
• financial information (eg for bursary assessment);
• courses, meetings or events attended.

As a school, we need to process special category personal data (eg concerning health, ethnicity, religion or biometric data) and criminal records information about some individuals (particularly students and staff). We do so in accordance with applicable law (including with respect to safeguarding or employment) or by explicit consent. 

3. Collecting, handling and sharing personal data

We collect most of the personal data we process directly from the individual concerned (or in the case of students, from their parents). In some cases, we collect data from third parties (for example, referees, previous schools, the Disclosure and Barring Service – or equivalent in other countries – or professionals or authorities working with the individual) or from publicly available resources. Personal data held by us is processed by appropriate members of staff for the purposes for which the data was provided. We take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems.  In the course of school business, we share personal data (including special category personal data where appropriate) with third parties such as examination boards, the school medical staff, the school’s professional advisors and relevant local and international authorities. Some of our systems are provided by third parties. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with our specific directions. 

4. Purposes for which we process personal data 

We process personal data to support the school’s operation as an independent school for students aged 3 – 18, and in particular for:

• The selection and admission of students;
• The provision of education to students including the administration of the school curriculum and timetable; monitoring student progress and educational needs; reporting on the same internally and to parents; administration of students’ entries to public examinations, reporting upon and publishing the results; providing references for students (including after a student has left);
• The provision of educational support and related services to students (and parents) including the maintenance of discipline; provision of careers and library services; administration of sports fixtures and teams, school visits and residentials; provision of the school’s IT and communications system and virtual learning environment (and monitoring the same) all in accordance with our IT policies; 
• The provision of educational courses and visits during school holidays to students enrolled on such courses;
• The safeguarding of students’ welfare and provision of pastoral care, welfare, health care services by school staff.
• The research into and development of effective teaching and learning methods and best practice; 
• Compliance with legislation and regulation including the preparation of information for inspections, submission of required information to appropriate government ministries and official bodies/organisations;
• Operational management including the compilation of student records; the administration of invoices, fees and accounts; the management of the school’s property; the management of security and safety arrangements (including the use of CCTV and monitoring of the school’s IT and communications systems in accordance with our Acceptable Use Policy); management planning and forecasting; research and statistical analysis; the administration and implementation of the school’s rules and policies for students and staff; the maintenance of historic archives and other operational purposes;
• Staff administration including the recruitment of staff/ engagement of contractors (including compliance with DBS and equivalent procedures); administration of payroll, pensions and sick leave; review and appraisal of staff performance; conduct of any grievance, capability or disciplinary procedures; and the maintenance of appropriate human resources records for current and former staff; and providing references;
• The promotion of the school through its own websites, the prospectus and other publications and communications (including through our social media channels); and 
• Maintaining relationships with former students, families and the wider school community by communicating with the body of current and former students and/or their parents or guardians and organising events.

The processing set out above is carried out to fulfil our legal obligations (including those under our parent contract and staff employment contracts). We also expect these purposes to form our legitimate interests.

5. Maintaining contact

We keep in touch with former students, current or former parents or other members of the school community. We may use contact details to keep them updated about our activities and invite you to events of interest by email and by post. We ask you to let us know your data preferences so that we can ensure our communications are relevant to you. 

6. How long we keep personal data

We retain personal data only for a legitimate and lawful reason and only for so long as necessary or required by law. We have adopted Records Retention Guidelines which set out the time period for which different categories of data are kept. Currently we retain all boy files given the ongoing Independent Inquiry into Child Sexual Abuse. If you have any specific queries about our record retention periods or wish to request that your personal data is considered for erasure, please contact the IT and Learning Technologies Manager.   7.    Your rights You have various rights under data protection laws to access and understand the personal data we hold about you, and in some cases to ask for it to be erased or amended or for us to stop processing it, but subject to certain exemptions and limitations.   You always have the right to withdraw consent, where given, or otherwise object to receiving generic communications. Please be aware however that the school may have another lawful reason to process the personal data in question even without your consent. That reason will usually have been asserted under this Privacy Notice or may exist under some form of contract or agreement with the individual (e.g. an employment or parent contract). If you would like to access or amend your personal data or would like it to be transferred to another person or organisation, or have some other objection to how your personal data is used, please make your request in writing to the IT and Learning Technologies Manager.  We will to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits. We will be better able to respond quickly to smaller, targeted requests for information. If the request is manifestly excessive or similar to previous requests, we may ask you to reconsider or charge a proportionate fee, but only where relevant data protection law allows it. You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal privilege. We are also not required to disclose any student examination scripts (though examiners’ comments may fall to be disclosed), nor any confidential reference given by the school for the purposes of the education, training or employment of any individual.

8. Student data

The rights under data protection legislation belong to the individual to whom the data relates. However, we will often rely on parental consent to process personal data relating to students (if consent is required) unless, given the nature of the processing in question, and the student’s age and understanding, it is more appropriate to rely on the student’s consent.  Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents’ rights at law or under their contract, and all the circumstances. In general, we will assume that students’ consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the student’s activities, progress and behavior, and in the interests of the student’s welfare, unless, in the school’s opinion, there is a good reason to do otherwise. However, where a student seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, we may be under an obligation to maintain confidentiality unless, in our opinion, there is a good reason to do otherwise; for example where the school believes disclosure will be in the best interests of the student or other students, or is required by law. Students can make subject access requests for their own personal data, provided that they have sufficient maturity to understand the request they are making. Our students are generally assumed to have this level of maturity. A person with parental responsibility will generally be entitled to make a subject access request on behalf of students, but the information in question is always considered to be the child’s at law. A student of any age may ask a parent or other representative to make a subject access request on their behalf. Moreover (if of sufficient maturity) their consent or authority may need to be sought by the parent making such a request.  

9. Change of details

We try to ensure that all personal data held in relation to an individual is as up to date and accurate as possible.  Please notify Reception Desk teams of any significant changes to important information, such as contact details, held about you.   

10. This policy

Our privacy notice should be read in conjunction with our other policies and terms and conditions which make reference to personal data, including our Safeguarding Policy, Health & Safety Policies and Acceptable Use Policies  We will update this Privacy Notice from time to time. Any substantial changes that affect how we process your personal data will be notified on our website and to you directly, as far as practicable. If you believe that we have not complied with this policy or have acted otherwise than in accordance with data protection law, you should notify the IT and Learning Technologies Manager. You can also make a referral to the Principal and/or Chair recommends that steps are taken to resolve the matter with us before involving them. 

Date of policy and date of next review

This policy will be reviewed every two years, or earlier if required.

Date of Policy:     November 2019

Date of Review:   November 2021 and then every two year