Політика конфіденційності даних

SP TRIADA PRIVATE SCHOOL LIMITED (with a trademark TRINITY PRIVATE SCHOOL) dedicated to protecting the confidentiality and privacy of information entrusted to it and complies with Personal Data Privacy legislation (GDPR) 169/2016 as currently in force and Cyprus Republic Law 125/2018.

Trinity Private School processes personal data of its prospective, current, and former students and their parents or representatives as part of its educational services. Trinity acknowledges its obligations under data protection legislation and is committed to fulfilling these obligations for both staff and students. The school will adhere to the requirements of the General Data Protection Regulation (GDPR), which is applicable in the European Union.

As the controller of personal data, Trinity Private School determines the purposes and means of processing the data. For the purposes of this privacy policy, "processing" refers to any operation performed on personal data, including collection, recording, storage, adaptation, alteration, consultation, use, disclosure, erasure, or destruction.

The appointed Data Protection Officer (DPO) will ensure the highest standards of data security and confidentiality are upheld during data processing and handling within the school premises. Their responsibilities include coordinating and monitoring data management training, fostering a positive data culture and best practices, providing advice on data-related matters, assessing the severity of data breaches, and implementing data protection policies issued by Trinity Private School. The DPO will also ensure the existence of secure and confidential systems within the school and provide information to authorized entities as required.

We invite you to carefully read this Privacy Notice, which sets out in which context we are processing your personal data and explains your rights and our obligations when doing so.

To exercise any of the rights provided in this policy or to seek further information or clarification regarding the processing of personal data, please contact Trinity Private School through its designated Data Protection Officer at [email protected]. The Data Protection Officer is responsible for ensuring that Trinity Private School adheres to all GDPR requirements. 

At Trinity Private School, we collect and process personal data about various individuals connected to our institution, including prospective, current, and former students, their parents, staff, suppliers, contractors, friends, supporters, and visitors. The personal data we collect can vary depending on the purpose for which it is collected. The types of personal data we may collect include:

• Identification information: such as name, first name, last name, ID card or passport numbers, email address, postal address, fixed and/or mobile phone numbers.
• Family details: including parents' names, telephone numbers, passport numbers, and addresses.
• Financial information: such as bank account details.
• Electronic identification data: where necessary for the delivery of our services, this may include login credentials, access rights, passwords, employee numbers, IP addresses, online identifiers/cookies, logs, and access/connection times.
• Admissions, academic, disciplinary, and other education-related records: this may include information about special educational needs, references, examination scripts, and marks, relating to the students' academic performance, disciplinary records.
• Behavioral data and student preferences/interests.
• Education and employment data.
• Images, audio, and video recordings.
• Details of courses, meetings, or events attended.
• Health data: such as medical history, allergies, immunization records, disorders, medical examination results, and other medical data of the students.

Trinity Private School primarily collects personal data directly from the individuals themselves or their parents/guardians in the case of students. However, in certain instances, we may also gather information from third parties such as referees, previous schools, professionals, or authorities involved with the individual. Additionally, we may obtain data from publicly available sources.

The personal data we hold is processed by designated staff members for the purposes for which it was provided. We have implemented appropriate technical and organizational measures to ensure the security of personal data, including policies regarding the use of technology, devices, and access to school systems. We do not transfer personal data outside the European Union unless we are confident that it will receive an equivalent level of protection.

During the course of school operations, we may share personal data, including special category personal data where necessary, with third parties such as examination boards, professional advisors, and relevant authorities (e.g., Ministry of Education, Department of Statistics, Immigration Office, Tax Department, Social Insurance Services). Some of our systems and services are provided by third-party providers, including hosted databases, the school website, school calendar, school email, platforms, and applications. These arrangements are always subject to contractual assurances ensuring that personal data is securely maintained and used only in accordance with our explicit instructions. We do not disclose or sell personal data to other organizations for their own purposes.

At Trinity Private School, we collect and process personal data based on the legal grounds established by the GDPR. These legal bases include:

1. Consent: We obtain consent from parents/pupils prior to processing personal data for specific purposes, such as the use of students' photographs and videos in school publications, website, and social media, as well as for direct marketing communications regarding fundraising activities. Additional consents may be requested for other processing activities.
2. Performance of Enrolment Contract: We process personal data to fulfill the enrolment contract and provide educational services. Certain mandatory categories of personal data are required for the conclusion of the contract and to ensure high-quality education in the best interest of the students. These mandatory categories are clearly indicated in the application form and enrolment contract.
3. Legal Obligation: Trinity Private School may process personal data to comply with legal obligations, such as performing video surveillance in accordance with legal requirements.
4. Task Carried out in the Public Interest: As an educational institution, many processing operations at Trinity Private School are carried out in the public interest. This includes issuing and storing academic records, evaluating student performance, and other educational purposes in accordance with applicable Cypriot provisions on education.
5. Legitimate Interest: Trinity Private School relies on legitimate interest as a legal basis for providing educational services and related activities at the highest standards, always prioritizing the students' benefits without outweighing the rights and freedoms of parents or students. Examples include monitoring the use of our virtual learning environment and network, conducting fundraising activities, enforcing legal claims, ensuring security, maintaining alumni relationships, collaborating with other schools and educational institutions, and accessing grants and funding sources.

For the processing of special categories of personal data (e.g., health data), we adhere to the following legal grounds:

• Necessity for Medical Purposes: The Medical Office processes health data for preventive and occupational medicine, medical diagnosis, and the provision of health or social care/treatment based on European Union or national law.
• Substantial Public Interest: Processing of special categories of personal data may be necessary to assess a student's learning capacity and adapt teaching activities to their special needs, based on European Union or national law.
• Explicit Consent: We obtain explicit consent for the disclosure of personal data related to student allergies.

At Trinity Private School, we handle personal data in accordance with the applicable legal bases, ensuring compliance with data protection regulations and safeguarding the privacy and rights of our students and parents.

Trinity Private School processes personal data of parents and students for various purposes, including:

1. Provision of educational services: This includes the application process, student enrollment, class administration, timetable management, teaching activities, internal and public examinations administration, assistance with university applications, and issuance of academic records.
2. Provision of educational ancillary services: Trinity Private School offers pastoral care, career and personal counseling, library services, extracurricular activities, school trips, management of school publications, setup of the virtual learning environment, and granting access to Trinity Private School's Intranet and Internet network. Trinity Private School also monitors the use of its network to ensure its appropriate usage. 
3. Campus security: Trinity Private School ensures campus security by monitoring access on campus and employing video surveillance as necessary.
4. Provision of medical care and counseling: Trinity Private School provides necessary medical care and counseling services to students as needed. 
5. School administration: This involves handling student records, academic documentation, administration of fees and accounts, conducting internal audits and controls, generating reports and statistics, implementing school policies, collaborating with other schools, archiving, assessing service quality, and facilitating research activities.
6. School-related communications: Trinity Private School communicates various messages related to students and the school's activities through different means of communication.
7. Organizing fundraising activities and school events: Trinity Private School organizes fundraising activities and other school events such as concerts, theatre productions, talent shows. This may include marketing communications related to fundraising activities organized by Trinity Private School.
8. 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; 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 archives and other operational purposes;
9. Staff administration including the recruitment of staff and/or engagement of sub-contractors; 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;
10. The promotion of Trinity Private School through its own website, the prospectus and other publications and communications (including through our social media channels); and
11. Dispute resolution and litigations: Trinity Private School may process personal data in relation to dispute resolution and legal proceedings, as necessary.

At Trinity Private School, we adhere to the laws and regulations of Cyprus and the European Union when processing your personal data. We ensure that there is a proper justification or legal basis for processing your personal data, which may include the following:

1. Performance of a contract: We process your personal data when it is necessary to fulfill our obligations under a contract that we have with you or your legal representative.
2. Legal obligation: We may process your personal data to comply with a legal obligation imposed on us, such as keeping records for tax purposes or providing information to relevant public bodies or law enforcement agencies.
3. Legitimate interests: We may process your personal data based on our legitimate interests, as long as it does not override your interests and fundamental rights and freedoms.
4. Vital interests: In certain situations, we may process your personal data when it is necessary to protect the vital interests of yourself or another individual.
5. Public interest: We may process your personal data when it is necessary to perform a task that is carried out in the public interest.
6. Your consent: In some cases, we may ask for your explicit consent to process specific categories of your personal data. We will only process your personal data in this manner if you provide your consent voluntarily. You have the right to withdraw your consent at any time by contacting us using the provided contact information.

Please note that the above list serves as examples, and the specific legal basis for processing your personal data may vary depending on the circumstances. We ensure that all processing activities are conducted in compliance with applicable data protection laws and regulations.

At Trinity Private School, we prioritize the confidentiality and security of your personal data. We do not share personal data with unrelated third parties, unless it is necessary for legitimate professional and business purposes, to fulfill your requests, or as required or permitted by law or professional standards.

In order to provide our services effectively, we may engage reputable partners, service providers, or agencies to process your personal data on our behalf. Before transferring any personal data to them, we ensure that they meet our stringent standards for data processing and security. We enter into contractual agreements with these external service providers, imposing obligations to maintain the confidentiality and security of the information they have access to.

Confidentiality is a core principle at Trinity Private School, and it is reflected in our General Terms of Business, which includes a confidentiality clause. At times, we may also sign confidentiality or non-disclosure agreements with third parties, such as external service providers who have access to confidential information.

Within Trinity Private School, access to personal data is granted only to those members of our staff and collaborators who require it to ensure the provision of educational and ancillary services. For instance, the Medical Office, the Principal, and authorized staff have access to students' medical records. Other departments may have access to specific health data based on your expressed consent (e.g., allergies) or to protect substantial public interest as required by Union or national law (e.g., special learning needs related to certain medical conditions).

When it comes to disclosing personal data to third parties outside of Trinity Private School, such disclosures are made solely within the regular activities of the school. The categories of recipients may include:

• IT providers, including educational applications and online tools, server hosting suppliers.
• Providers of on-campus meal services.
• Other educational institutions or organizations, not limited to schools, such as travel agencies, catering and transportation providers.
• Trinity Private School's photographer and video crew.
• Courier service providers.
• Utilities service providers.
• Public authorities and institutions, both national and foreign, including judicial courts and foreign embassies or diplomatic missions.
• Tax, legal, and accounting consultants.

Please note that apart from the mentioned categories, we do not release information to any other third parties unless required by law or with your express consent as the data subject. We take the privacy and confidentiality of your personal data seriously and ensure that it is handled in accordance with applicable regulations and best practices.

At Trinity Private School, we retain personal data for legitimate and lawful reasons, and only for as long as necessary or required by law. If you have any questions about our record retention periods or if you would like to request the erasure of your personal data, please contact our Data Protection Officer.

Trinity Private School adheres to applicable laws and regulations regarding the retention of personal data. We have established the following practices:

• We retain your Personal Data throughout the duration of your contract with us, and for an additional standard period of 3 years thereafter, as deemed necessary by Trinity Private School. This retention allows us to evaluate the school's activities, maintain the quality of services provided, and address any future requests from students regarding their academic history at Trinity Private School, which often arise after graduation.
• It is important to note that academic records and other relevant documents related to student activities are kept indefinitely to fulfill legal obligations imposed on Trinity Private School. Additionally, if any specific legal requirements stipulate a minimum retention period, Trinity Private School will retain Personal Data for at least the duration mandated by law. We prioritize the security and compliance of your Personal Data throughout its retention period.
• We maintain a systematic process to identify and track the types and locations of personal data held by the school.
• We provide individuals with the ability to access their personal data maintained by Trinity Private School. You have the right to review and correct any inaccuracies in your personal information, as required by applicable laws and regulations.

We prioritize the responsible handling and storage of personal data at Trinity Private School, ensuring compliance with legal requirements and maintaining transparency and accountability in our data practices. 

Students at Trinity Private School can submit requests for their educational records by contacting the school administration. We aim to respond to all requests regarding educational records within 15 school days. For requests pertaining to information held outside the educational record, we will respond within one month.

It is important to note that members of staff at Trinity Private School act as representatives of the school, and any information they create, collect, or retain in records or mark books regarding students is considered data under our policy. Such information is not confidential to the individual teacher but is subject to the school's data protection policies.

We emphasize the significance of diligent data security to our staff, and they receive appropriate training to ensure the risk of any data breaches is minimized. We prioritize safeguarding personal information and maintain a strong commitment to protecting the privacy and security of our students' data.

At Trinity Private School, we respect your privacy and uphold your rights as outlined in the General Data Protection Regulation (GDPR). We are committed to ensuring the protection and transparency of your personal data. Here are your privacy rights:

1. Right of Access to Data: You have the right to request access to your personal data, as stated in Article 15 of GDPR. This includes information about the purposes of processing, categories of personal data, recipients of the data, and the storage period.
2. Right to Rectification: If you believe that any of your personal data is inaccurate or incomplete, you have the right to request its correction or completion under Article 16 of GDPR.
3. Right to Restriction of Processing: Under the conditions specified in Article 18 of GDPR, you can request the restriction of processing your personal data.
4. Right to Object to Processing: You have the right to object to the processing of your personal data based on Article 6(1)(e) or (f) of GDPR. This right applies if the processing is causing you specific and legitimate concerns related to your situation.
5. Right to Be Forgotten: If you no longer wish for us to process or retain your personal data, you have the right to request its deletion, unless there are legitimate grounds for us to keep the data, as stated in Article 17 of GDPR.
6. Right to Data Portability: You can request to receive your personal data in a machine-readable format or transfer it to another controller, as described in Article 20 of GDPR.
7. Right to Withdraw Consent: You have the right to withdraw your consent for the processing of your personal data at any time, particularly for generic or fundraising communications.

Please note that there may be lawful exemptions and limitations to these rights. Trinity Private School will respond to your written requests regarding your personal data as soon as reasonably practicable, within the statutory time-limits. For access requests, the response time is one month. Please make any requests or address objections in writing to our Data Protection Officer.

It's important to be aware that certain data may be exempt from the right of access, such as information identifying other individuals or data protected by legal privilege. Additionally, we are not required to disclose student examination scripts, although examiners' comments may be shared. Confidential references provided by the school for educational, training, or employment purposes are also exempt from disclosure.

At Trinity Private School, we prioritize the protection and privacy of your personal data and strive to fulfill your privacy rights in accordance with GDPR.

At Trinity Private School, we understand the importance of protecting student data and respecting their rights under Data Protection legislation. In most cases, we rely on parental consent to process personal data relating to students, unless it is more appropriate to rely on the student's consent based on the nature of the processing and the student's age and understanding.

Parents should be aware that depending on the child's interests, parental rights at law or under their contract, and the circumstances involved, they may not always be consulted regarding the processing of their child's personal data.

In general, we assume that ordinary disclosure of students' personal data to their parents is not dependent on the student's consent. This includes sharing information about the student's activities, progress, behavior, and welfare. However, if a student specifically requests confidentially and withholds consent for their personal data to be disclosed to their parents, we may have an obligation to maintain confidentiality unless there is a good reason to do otherwise. This may include situations where disclosure is in the best interests of the student or other students or is required by law.

Students who have sufficient maturity to understand the request they are making can make subject access requests for their own personal data. A person with parental responsibility may also make a subject access request on behalf of a student, but it is important to note that the information is always considered to belong to the child at law. If a parent makes a subject access request on behalf of their child, the consent or authority of the child (if of sufficient maturity) may need to be obtained.

We strive to keep all personal data held about individuals as accurate and up to date as possible. If there are any changes to important information, such as contact details, please notify us by sending an email to [email protected] .

Please ensure that you read our Privacy Policy in conjunction with our other policies and terms and conditions that reference personal data, including our School Application Admission Form.

We may update this Privacy Policy from time to time, and any significant changes that affect how we process your personal data will be notified on our website and communicated to you directly, as far as practicable.

If you have any concerns regarding your data protection rights, you can address them to the School's Data Protection Officer by sending an email to [email protected] .

If you believe that your rights under GDPR have been violated, you have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection. You can visit their website at www.dataprotection.gov.cy or contact them through the Call Center: 22 818 456, Fax: 22 30 45 65, or via email at [email protected].

At Trinity Private School, we are committed to safeguarding your privacy and ensuring the protection of your personal data.