Privacy Policy
DATA PROCESSOR (PARENTAL COMPANY):
INTERNATIONAL SCHOOL OF EUROPE S.P.A.
Sede legale: Via Manfredo Camperio,
14 - 20123 Milano
Cod. Fisc. - P.IVA e registro imprese di Milano n. 12932001006 - REA (MI) n. 2046718
Data Protection Officer (also referred as “DPO”) can be contacted at: dataprivacy@internationalschoolofeurope.it.
DATA CONTROLLERS:
ISE SCHOOLS are:
- INTERNATIONAL SCHOOL OF MILAN (Baranzate), DPO email address: dataprivacy@ismilano.it;
- INTERNATIONAL SCHOOL OF MONZA, DPO email address: dataprivacy@ismonza.it;
- INTERNATIONAL SCHOOL OF TICINO, DPO email address: dataprivacy@isticino.com;
- INTERNATIONAL SCHOOL COMO, DPO email address: dataprivacy@iscomo.com;
- INTERNATIONAL SCHOOL OF MODENA, DPO email address: dataprivacy@ismodena.it;
- INTERNATIONAL SCHOOL OF SIENA, DPO email address: dataprivacy@issiena.it;
- INTERNATIONAL SCHOOL OF BERGAMO, DPO email address: dataprivacy@isbergamo.com;
- ISE KIDDY ENGLISH, DPO email address: dataprivacy@isekiddyenglish.it.
INTERNATIONAL SCHOOL OF EUROPE S.P.A. is part of Inspired Education Holdings Ltd., which is a company registered in United Kingdom with number 09268120 and registered address at Sixth Floor, 3 Burlington Gardens, London, W1S 3EP. 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 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and the Italian implementation by Legislative Decree n. 101 dated 10 August 2018.
Our Data Protection Officer can also be contacted by email at dataprivacy@internationalschoolofeurope.it if you have any queries regarding the processing of your personal data.
2. TYPES OF PERSONAL DATA WE PROCESS
We process personal data from our students and their families and / or their legal representatives and also from our employees, candidates, suppliers, contractors, prospective customers and third parties interested in finding out more about ISE SCHOOLS.
The personal data processed are mainly the following:
- Names, addresses, telephone numbers, e-mail addresses and other contact details;
- Family details;
- Safeguarding information (such as court orders and professional involvement);
- Education and employment data;
- Nationality, language (s) and location;
- Images, audio and video recordings, including CCTV footage (video images);
- Financial information;
- Educational centres previously attended.
Other types of data we may collect and process, according to the school purposes, are related to health condition, criminal records and other sensitive information related to an individual, such as:
- Information about health status or provision of health care linked to a specific individual;
- Behavioural information;
- Special educational needs;
- Criminal records linked to a specific individual;
- Biometric information;
- Ethnicity;
- Religion or ideology;
- Sexual orientation.
3. HOW WE COLLECT AND PROCESS PERSONAL DATA
ISE SCHOOLS collect information in several ways, including:
- Personally and over the phone;
- Through our website, not only through our forms but also from our cookies;
- From email and hand delivery paper documentation including job applications, invoices, letters or consent forms;
- Through online tools such as apps, educational platforms and other software used by our Schools;
- Through any CCTV cameras located at our premises or sites;
- Through third parties, such as legally authorised individuals, professionals or authorities working with or on behalf of the individual.
4. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
ISE SCHOOLS process personal data to lawfully and legitimately carry out the schools’ educational activity. Our schools collect and keep students and parents’ information when necessary to:
- Attend enquiries correctly;
- Manage the Schools’ admission process;
- Support University admissions service;
- Provide educational services including the support of pupil learning, monitor and report on pupil progress;
- Make provision to the students of welfare and pastoral care services;
- Ensure to the students medical and nurse attention, nutritional programme, school uniforms and bus service, among other necessary services;
- Meet the educational, social, physical and emotional requirements of the students;
- Manage the Summer Camp activities;
- To enable parents/guardians to be contacted in the case of emergency or in the case of school closure, or to inform parents of their child’s educational progress or about school events, etc.
- With the aim to celebrate school’s achievements and to keep a record of the history of the student, ISE SCHOOLS may take photographs and recorded images of students to be shared in, e.g., yearbooks, school website and or social networks etc, always based on informed consent from parents or students of legal age; ISE SCHOOLS may also share these images with Inspired Education Group under parents or students of legal age consent.
- To send commercial communications if previously requested and authorised by the data subject. You will be able to unsubscribe from the receipt of such commercial communications by clicking in the “unsubscribe” section.
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 the corresponding ISE SCHOOL where the application was submitted. The corresponding ISE SCHOOL Human Resources department will process your data with the purpose to include your candidacy in our selection processes.
5. LAWFUL BASIS TO PROCESS YOUR DATA
ISE SCHOOLS collect and process your data under the following lawful 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 from our ISE SCHOOLS, as well as to carry out satisfaction surveys to modify in the operation of our Schools 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 our Schools’ activities, or for promotional campaigns.
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 of our ISE SCHOOLS or even 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 or, where appropriate, of the student over legal age.
Your personal data shall be neither rented nor sold to third parties.
7. INTERNATIONAL DATA TRANSFERS
In the event that, for legitimate reasons such as student exchange programs, or in the execution of the educational contract (which could even include the use of computer tools offered from outside the EEA), personal data are transferred to countries outside the European Economic Area (EEA), including countries that may offer a lower level of data protection than in the EEA, we will implement the necessary safeguarding measures to ensure adequate protection of your personal data in accordance with applicable data protection regulations.
8. CONSERVATION OF DATA
Personal information will only be retained for the period of time required to fulfil the purpose for which it was collected unless for a longer time for public interest archiving, scientific or historical research, or statistical purposes. Once the personal information is no longer required or permitted to be retained for legal or business purposes, it will be safely destroyed or made anonymous.
9. YOUR RIGHTS
Under the data protection regulations, you have rights regarding the processing of your personal data. These rights are, however, subject to certain exemptions and limitations.
You have the right to:
- Be informed, at the time when personal data is collected, about the data processing.
- Access 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;
- Ask for the erasing of the personal data we hold about you without undue delay considering the legal limitations and exceptions;
- Obtain the rectification of your personal data providing a supplementary statement;
- Obtain restriction of processing of your personal data when it is inaccurate, illegal, unnecessary or not verified, considering the legal limitations and exceptions;
- Obtain data portability of your personal information in a structured, commonly used and machine-readable format. This allows the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided;
- Object to processing for direct marketing purposes;
- Withdraw your consent at any time and freely to the processing of your personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You can request the exercise of your rights by sending a written request, along with a copy of your ID card, to the our ISE SCHOOLS Data Protection Officer’s email address dataprivacy@internationalschoolofeurope.it or to the particular DPO of the ISE SCHOOL affected.
10. CONSENT
You will have the right and possibility to 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.
11. MINORS
ISE SCHOOLS will not collect and process, under any concept, data from individuals under legal age. Consent from parents or legal representatives will be always required.
12. STORING AND SECURING INFORMATION
ISE SCHOOLS shall use the appropriate technical and organisational measures to ensure the security, confidentiality, integrity and privacy of the personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the files.
13. COMMON USE WITH SOCIAL NETWORKS
This website contains links to parent’s portal and other educational platforms in addition to social networks like Instagram, YouTube, 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.
14. 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 data 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.internationalschoolofeurope.it/en/cookies-policy.
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 Officer at: dataprivacy@internationalschoolofeurope.it or you can address your request for mediation to the Italian data protection authority, Garante per la Protezione dei Dati Personali, addressed at Piazza Venezia 11, IT-00187, Roma, with email: rpd@gpdp.it. or visiting the link: https://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-tuoi-dati-personali,although it is recommended that previous steps are taken to resolve the matter with the school before involving the authority.
16. PRIVACY NOTICE UPDATES
ISE SCHOOLS 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 May 2023