The International School Aberdeen (referred to in this document as “the school”) is the data controller. The school is a charity registered in Scotland (number SC007756) and a limited liability company (number SC071126). Our registered office is at Johnstone House, 52-54 Rose Street, Aberdeen, AB10 1HA.
This notice provides information about how the school will use (or "process") personal data about individuals including: its current, past and prospective staff; its current, past and prospective students; and their parents, carers or guardians (referred to in this policy as "parents"), its visitors and temporary members of the school community.
This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Staff, parents and students are all encouraged to read this Privacy Notice and understand the school’s obligations to its entire community. This Privacy Notice applies alongside any other information the school may provide about a particular use of personal data, for example when collecting data via an online or paper form.
This Privacy Notice also applies in addition to the school's other relevant terms and conditions and policies, including:
Anyone who works for, or acts on behalf of, the school (including staff, volunteers, Board members and service providers) should also be aware of and comply with this Privacy Notice.
The School has appointed Mrs Gayle Veitch as Data Protection Manager, who will deal with all your requests and enquiries concerning the school’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this notice and the EU General Data Protection Regulation 2016/679 (the “GDPR”). The Data Protection Manager may be contacted through the school, by telephone (01224 730300), by email (email@example.com) or in writing at Pitfodels House, North Deeside Road, Aberdeen, AB15 9PN.
In order to carry out its ordinary duties, the school needs to process a wide range of personal data about individuals (including current, past and prospective staff, students and parents) as part of its daily operation.
The school will need to carry out some of these activities in order to fulfil its legal rights, duties or obligations – including those under a contract.
Other uses of personal data will be made in accordance with the school’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
The school expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:
In addition, the school will on occasion need to process special category personal data (concerning health, ethnicity, religion, biometrics or sexual life) or criminal records information (such as when carrying out PVG checks) in accordance with rights or duties imposed on it by law, including safeguarding and employment, or from time to time by explicit consent where required. These reasons will include:
This will include by way of example:
Generally, the school receives personal data from the individual directly or, in the case of students, from their parents. This may be via a form, or simply in the ordinary course of interaction or communication (such as telephone calls, in person, email or written communication or assessments).
However, in some cases personal data will be supplied by third parties (for example another school, or other professionals or authorities working with that individual); or collected from publicly available resources.
Occasionally, the school will need to share personal information relating to its community with third parties, such as:
For the most part, personal data collected by the school will remain within the school, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of:
However, a certain amount of a student’s relevant information will need to be provided to staff more widely in the context of providing the necessary care and education that the student requires, particularly for students with Special Educational Needs (SEN).
Staff, students and parents are reminded that the school is under duties imposed by law and statutory guidance (including GIRFEC) to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as the police. For further information about this, please view the school’s Child Protection Policy.
Some of the school’s processing activity is carried out on its behalf by third parties, such as IT and communications systems, or cloud storage providers. This is always subject to contractual assurances that the third party is compliant with current Data Protection Legislation (GDPR) and that personal data will be kept securely and only in accordance with the school’s specific directions governed by a Data Sharing Agreement where necessary. In order to carry out our day to day activities, some staff and student names, ISA email addresses and performance data is held by a number of third party online learning platforms and websites. These are only used when the school is satisfied that the third party is compliant with current Data Protection Legislation (GDPR). A full list of current third party suppliers is available on request from the Data Protection Manager.
Sometimes we will need to transfer or store your information outside of the United Kingdom, for example, by our Management Information System: PowerSchool (USA); our online learning platform: Google G-Suite for Education (USA) and testing software: International School Assessment (Australia) and MAP Growth (USA).
Countries to which we transfer information may have different standards to control how your information is used and protected and these standards may not be as strict as those in place in the United Kingdom. We will only transfer information to organisations who are working towards compliance with General Data Protection Regulation (EU) 2016/679 (“GDPR”), and are in countries which have laws offering an adequate level of protection for your information. In the case of the USA, we will make sure that the organisation which receives your information is a participant in the Privacy Shield Framework (for more information, please visit the Privacy Shield website). We will put in place appropriate safeguards to protect your information, or otherwise ensure that we can transfer your information in a way that complies with Data Protection Law (for example, in some circumstances we may ask for your explicit consent to make a transfer of your information).
Where we put in place appropriate safeguards to protect information which we transfer, the safeguards may include securing additional Data Sharing Agreements to protect your information. You can obtain a copy of these agreements by contacting the Data Protection Manager.
The school will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep ordinary staff and student personnel files is up to 7 years following departure from the school. However, incident reports and safeguarding files may need to be kept longer, in accordance with specific legal requirements.
If you have any queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Data Protection Manager. Please bear in mind that the school will often have lawful and necessary reasons to hold on to some personal data even following such request.
A limited and reasonable amount of information will be kept, for example for historical or archiving purposes; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").
Further information can be found in our Retention of Records Policy which is available by contacting the Data Protection Manager.
The school will use the contact details of current, past and prospective staff, students, parents, and other members of the school community to keep them updated about the activities of the school, news and events of interest, including by sending updates and newsletters, by email, SMS message and by post.
The school will share contact details of the representatives of the Parent Teacher Organisation (PTO) who can be contacted in order to receive information, for example about PTO activities, reminders about school events and requests for assistance.
Should you wish to limit or object to any such use, or would like further information about them, please contact the Data Protection Manager in writing. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the school is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
Individuals have various rights under Data Protection Law to access and understand personal data about them held by the school, and in some cases ask for it to be erased or amended or have it transferred to others, or for the school to stop processing it – but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the Data Protection Manager using the Subject Access Request form.
The school will endeavour to 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). The school will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, the school may ask you to reconsider, or require a proportionate fee (but only where Data Protection Law allows it).
You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals (and parents need to be aware this may include their own children, in certain limited situations), or information which is subject to legal privilege (for example legal advice given to or sought by the school, or documents prepared in connection with a legal action).
The school is also not required to disclose any student examination scripts (or other information consisting solely of student test answers), provide examination or other test marks ahead of any ordinary publication, nor share any confidential reference given by the school itself for the purposes of the education, training or employment of any individual.
We will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your (or your child's) personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.
A person with parental responsibility will generally be entitled to make a subject access request on behalf of younger students, but the law still considers the information in question to be the child’s. Students aged 12 and above are generally assumed to have sufficient maturity to make a request themselves, although this will depend on both the child and the personal data requested, including any relevant circumstances at home
In line with the Fee Agreement and school policy, parents will in general receive educational and pastoral updates about their children. The school 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 behaviour, and in the interests of the student's welfare. All information requests from, on behalf of, or concerning students – whether made under subject access or simply as an incidental request – will be considered on a case by case basis.
It may in some cases be necessary or appropriate – given the nature of the processing in question, and the student's age and understanding – to seek the student's consent. Parents should be aware that in such situations they may not be consulted, depending on the interests of the student, the parents’ rights at law or under their contract, and all the circumstances.
In a situation 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, the school may be under an obligation to maintain confidentiality unless, in the school's 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 if required by law.
Where the school is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Examples where we do rely on consent are with use of images and events outwith the normal school operations, eg Summer Camp. Please be aware however that the school may not be relying on consent but have another lawful reason to process the personal data in question even without your consent. Students are required to respect the personal data and privacy of others, and to comply with the school's Technology Acceptable Use Policy and the school rules. Staff are under professional duties to do the same covered under the relevant Faculty/Staff Policy Handbook and school Data Protection Policy.
The school will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the relevant Head of School of any significant changes to important information, such as contact details, held about them.
The school will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, access to school systems, and destruction of data at the end of the relevant retention period. All staff and Board Members will be made aware of this policy and their duties under Data Protection Law and receive relevant training.
The school will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
Any comments or queries on this policy should be directed to the Data Protection Manager through the school by telephone (01224 730300), by email (firstname.lastname@example.org) or in writing at Pitfodels House, North Deeside Road, Aberdeen, AB15 9PN.
If an individual believes that the school has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the school complaints / grievance procedure and should also notify the Data Protection Manager. You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the school before involving the regulator.
Last Updated: 25th May 2018