1.  INTRODUCTION

We are committed to using the personal data we hold in accordance with the law as we take our responsibilities as a data controller very seriously.

This privacy notice gives 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 email your enquiries at gdpr@gcsc.ac.cy

 

  1.  TYPES OF PERSONAL DATA WE PROCESS

We process personal data about prospective, current and past: pupils and their parents; staff, suppliers and contractors; donors, friends and supporters; and other individuals connected to our schools.

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 or for fund-raising);
  • courses, meetings or events attended.

As educational institutions, we need to process special category personal data (eg concerning health, ethnicity, religion or biometric data) ,We do so in accordance with applicable law (including with respect to safeguarding or employment) or by explicit consent.

 

  1. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

We process personal data to support the Schools’ operations and in particular for:

  • The selection and admission of pupils;
  • The provision of education to pupils including the administration of the school curriculum and timetable; monitoring pupil progress and educational needs; reporting internally and to parents; administration of pupils’ entries to examinations, reporting upon and publishing the results; providing references for pupils (including after a pupil has left);
  • The provision of educational support and related services to pupils (and parents) including the maintenance of discipline; provision of careers and library services; administration of sports fixtures and teams, school trips; provision of the school’s IT and communications system and virtual learning environment.
  • The provision of educational/activity based courses during summer holidays to students enrolled on such courses;
  • The research into and development of effective teaching and learning methods and best practice
  • Operational management including the compilation of pupil records; the administration of invoices, fees and accounts; the management of security and safety arrangements (including the use of the school’s IT and communications systems); management planning and forecasting; research and statistical analysis; the administration and implementation of the Schools’ rules and policies for pupils and staff; the maintenance of historic archives and other operational purposes;
  • Staff administration including the recruitment of staff; engagement of contractors; administration of payroll; Provident Fund and sick leave; review and appraisal of staff performance; disciplinary procedures; and the maintenance of appropriate human resources records for current and former staff; and providing references;
  • The promotion of the Schools through our websites, the prospectus and other publications and communications (including through our social media channels); and
  • Maintaining relationships with Graduates and the wider school community by communicating with the body of current and former pupils 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.

 

  1.  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 pupils, from their parents). In some cases, we collect data from third parties (for example, referees, previous schools)

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. We do not transfer personal data outside of the European Economic Area unless we are satisfied that the personal data will be afforded an equivalent level of protection.

In the course of school business, we share personal data (including special category personal data where appropriate) with third parties such as the alumni association, examination boards,  the school’s professional advisors and relevant authorities (eg the Ministry for Education and Social Insurance Department). Some of our systems are provided by third parties, eg hosted databases, school website, school post and school portal or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with our specific directions.

 

  1.  COMMUNICATION

We communicate with Alumni, current or former parents or other members of the school community. We will use your contact details to keep you updated about our charitable activities, invite you to events of interest, inform you about our educational institutions programs, provide you with promotional material and various school publications by email and/or by post.

 

  1.  HOW LONG WE KEEP PERSONAL DATA

We retain personal data only for a legitimate and lawful reason and only for so long as necessary. Some records such as copies of Apolytiria are kept indefinitely or until you notify us for erasure. Most records are erased 7 years  after graduation/ termination of studies.

Any personal data held by us for marketing and service update notifications will be kept by us until you notify us that you no longer wish to receive this information.

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 gdpr@gcsc.ac.cy

 

  1.  YOUR RIGHTS

You have various rights under GDPR 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 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 send your request to gdpr@gcsc.ac.cy

We will respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits, which is one month in the case of requests for access to information. 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 GDPR 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 confidential reference given by the school for the purposes of the education, training or employment of any individual.

 

  1.  PUPIL DATA

The rights under GDPR legislation belong to the individual to whom the data relates. However, we will often rely on parental consent to process personal data relating to pupils (if consent is required) unless, given the nature of the processing in question, and the pupil’s age and understanding, it is more appropriate to rely on the pupil’s consent.

In general, we will assume that pupils’ 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 pupil’s activities, progress and behaviour, and in the interests of the pupil’s welfare, unless, in the school’s opinion, there is a good reason to do otherwise.

A pupil of any age may ask a parent or other representative to make a subject access request on their behalf.

 

  1.  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.  For any significant changes to important information, such as contact details, held about you, please notify the administration or email the changes to gdpr@gcsc.ac.cy

 

  1.  THIS POLICY

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 GDPR, you should notify us. You can also make a referral to or lodge a complaint with the Commissioner’s Office of Personal Data Protection although it is recommended that steps are taken to resolve the matter with us before involving them.

 

May 2018