Privacy and Cookie Notices

ELIS VILLAMARTÍN PRIVACY NOTICE FOR PUPILS

 

INTRODUCTION

 

What is this notice? As a school, we are required by data protection law to look after and protect information that we hold about you. This privacy notice sets out the basis on which any personal data we collect from you, or that you give to us, is used by the school.

What is personal information? Personal information is any information which is about you and is capable of identifying you. Examples of this would be your name, where you live and your age.

Please make sure you read this privacy notice carefully and if you have any questions about it, please speak to your teacher.

 

WHAT PERSONAL INFORMATION MIGHT THE SCHOOL HOLD ABOUT YOU?

• Your full name
• Your date of birth and grade
• Your home address and home telephone number
• Your school email address
• Your personal email address
• Your mobile number
• Your photograph
• Your medical records (including allergies and special education needs and/or accidents) (see “Sensitive Personal Data”)
• Your parents’ or guardians’ details
• Your academic records and test results
• Your race, religion or ethnicity (see “Sensitive Personal Data”)
• Your biometric data (see “Sensitive Personal Data”)

 

INFORMATION WE RECEIVE FROM OTHER PEOPLE OR COMPANIES

We might work closely with other institutions such as your previous school, school nurses or doctors, school photographers, the local council, social services, education authorities and the school’s lawyers. We might receive information about you from them. We may also collect information about where you are when using our bus services and how you use our school-issued devices. We may also use CCTV footage to ensure the school is safe.

 

CONTACT US IF YOU HAVE FURTHER QUESTIONS

If you have any questions about this privacy notice then please speak to your teacher who will make sure that your question or query is handled by the right person.

The school has a Data Protection Co-ordinator who can explain in more detail how your information is handled and looked after by the school. The school’s Data Protection Co-ordinator is DOMINIK ANKE.

We have a Data Protection Officer whose contact details are as follows: Group Legal Director (DPO@cognita.com).

 

HOW THE SCHOOL USES YOUR INFORMATION

The school is interested in doing the following things with your information (these are called “legitimate interests”):

• promoting the objects and interests of our school, ensuring the most efficient management of our school; and
• using your photograph as part of a manual ID system.

We will also use the information your parents give us as is necessary to carry out our obligations arising from the contract between the school and your parents and to provide you and them with the information and services that your parents request from us (to manage any queries or disputes you may have with us or that we have with you, look after you, teach you).

Also, we are required by law to take a register, keep a personal file about you, keep a record of your behaviour and provide a written report on your progress.

In order to pursue the legitimate interests above and to fulfil its contractual and legal obligations, the school will rely on software applications and other technology to handle your information. These include virtual learning environments (including the setting of tasks and homework), revision tools, parents evening booking systems, text and email messaging communications, assessments of your progress and co-ordination of school trips. The companies we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your information is kept secure. Some of our key systems include Capita (SIMS), Evolve, NetSuite, Salesforce, Confirmit and Lightspeed. For further information on the kind of technology we use, please speak to your teacher who will liaise with the school’s Data Protection Co-ordinator.

 

SENSITIVE PERSONAL DATA

When we hold details about your medical condition or health, your race, ethnicity or religion, this type of information is called “sensitive personal data” which means the school must adopt higher standards of care to make sure this kind of data is safe and doesn’t fall into the wrong hands. It also means that we need to ask for yours and your parent’s consent to collect and process that data when we ask for it. We will need to hold sensitive personal data about you (a) for carrying out our obligations in the field of social security or social protection law, (b) for medical diagnosis or provision of health care, (c) to protect your vital interests or (d) for identification purposes. In order to achieve this, the school may also use software applications and other technology.

 

INFORMATION WE GIVE TO OTHER PEOPLE OR COMPANIES

We will share information with your parents or guardians to carry out our obligations arising from the contract between the school and your parents.

In order to pursue one of the legitimate interests set out above, we may share your personal information with: Cognita Regional Office (School Community Partners) in Spain, a member of the Cognita group of companies (your school belongs to the Cognita group), local authorities, education authorities (for example, the Independent Schools Inspectorate), the Department for Education, SEN co-ordinators, social services or the police where we have reason to believe there are concerns with your safety.

We may also share your personal information with exam boards in order to successfully administer exams.

If you are British, or national of any other country out of the Schengen area, we may have to provide information about you to the Spanish Immigration authorities.

We may also need to share your information with our head office in Spain and in the UK, professional advisors and suppliers.

 

WHERE WE NEED YOUR CONSENT

We will seek yours or your parent’s permission if we decide to post any photographs of you on any of our marketing materials (including our prospectus or website). If you are under the age of 14, we need your parent’s permission. If you are over the age of 14, then we need your permission (and not your parent’s permission). Where you or your parent have given permission, you can withdraw this permission at any time.

You or your parent or guardian do not have to give us details about your race, religion or ethnicity if you do not want to. If you do provide us with this information, we only intend to use these details to assist us with the day-to-day running of the school (for example, if your religion means that you have particular dietary requirements then we will of course be much better informed if we have this information to cater to your needs) and equal opportunities monitoring purposes. Where you have given this information to the school, you can ask us to withdraw this information at any time.

 

TRANSMISION OF PERSONAL INFORMATION OUTSIDE THE COUNTRY

Sometimes your information will need to be transferred to, and stored at, a destination outside the EEA. We try to limit this where possible but it may be necessary where, for example, one of our suppliers has a data storage centre outside Europe. We will take all steps reasonably and legally necessary to ensure that your information is treated securely and in accordance with this privacy notice.

 

YOUR RIGHTS

Under data protection law, you have the following the rights:

Request access to your personal information (commonly known as a “subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.

Object to processing of your personal information.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another organisation (e.g. another school) (portability right).

Request a copy of or access to the safeguards under which your data is transferred outside of the EEA (if it is transferred outside the EEA).

Right to complain to the competent authority (AEPD) about any complaints or queries you may have, although please contact us first.

 

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will not keep any personal information about you for any longer than is necessary for the purposes for which the personal data are used.

As a general rule, we keep your pupil record file for 6 years after you leave the school, at which point we destroy the file.

We follow a data retention policy which determines how long we keep specific types of personal information for. For further information, please speak to your teacher who will liaise with the school’s Data Protection Co-ordinator where necessary.

 

CHANGES TO THIS PRIVACY NOTICE

We might decide to make changes to this privacy notice and we will let you know about those changes when they are made.

Dated 15 October 2020

ELIS VILLAMARTÍN PRIVACY NOTICE FOR PARENTS

 

1 INTRODUCTION

 

1.1 We are committed to protecting and respecting yours and your child’s privacy. In this privacy notice, references to “we”, “us” or “our” is a reference to ELIS Villamartín S.A and the school which your child is attending, may be attending or has attended.

1.2 This privacy notice sets out the basis on which any personal data we collect from you or your child, or that you provide to us, is handled by us. We also have a privacy policy for our pupils, this is available on our website.

1.3 Please read the following carefully to understand our views and practices regarding your and your child’s personal data and how we will treat it.

1.4 For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and the Ley Orgánica 3/2018, de Protección de Datos Personales y Garantía de los Derechos Digitales, we are the data controller and our address is ELIS Villamartín, Las Filipinas, 15., Urb. Blue Lagoon, 3193 San Miguel de Salinas, Alicante, Spain.

1.5 If you are reading this privacy notice online, we recommend that you print and retain a copy for future reference.

 

2 INFORMATION WE COLLECT ABOUT YOU AND YOUR CHILD

Information you give us

2.1 You may give us personal data about you or your child, in a number of ways; these include:

2.1.1 using, visiting or interacting with our website (such as filling out forms or registering on our website);

2.1.2 visiting our school;

2.1.3 corresponding with us by phone, e-mail or post; and

2.1.4 sending information directly to us, for example when paying our fees, giving us medical records or information about your child’s health, completing school admission forms, signing our parent contract or providing information as requested by us and/or which is necessary from time to time.

2.2 The information you give us may include the following information about you and your child:

2.2.1 full name of all the parents and the child/children;

2.2.2 date of birth and year group of the child/children;

2.2.3 parents’ and children’s contact details (including home address, e-mail address, and mobile, home and/or work phone number);

2.2.4 parent login information (i.e. username and password) for the website;

2.2.5 parents’ financial and credit card information;

2.2.6 photograph of the child/children;

2.2.7 passport details, nationality and other information relating to immigration status of the parents and the child/children;

2.2.8 education and health records (including special education needs, medical or physical conditions and/or accidents) of the child/children;

2.2.9 previous educational records and achievements of the child/children;

2.2.10 (where appropriate) family circumstances (including your relation to the child and your marital status);

2.2.11 race, religion and ethnicity (see paragraph 4.14); and

2.2.12 biometric data (including fingerprint data).

Information we receive from other sources

2.3 We may be working closely with third parties (including, for example, your child’s previous or new school(s), medical practitioners, photographers, local authorities, education authorities, business partners, payment and delivery services, debt collectors, lawyers and credit reference agencies) and may receive information about you from them.

2.4 We may also use a third party to collect:

2.4.1 location data to track, for example, your child on our bus services; and

2.4.2 information relating to monitoring, for example, your child’s usage of our school-issued devices.

2.5 We may also use CCTV footage to ensure the school is safe. We may receive information about you if you use any of the other websites we operate or the other services we provide.

 

3 CONTACT US

3.1 Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at DPO@Cognita.com or Plaza Doctor Letamendi 1-2, 4th Floor, 08007, Barcelona, Spain.

3.2 We have also appointed within each school a Data Protection Co-ordinator. Please contact the school for further details about the Data Protection Co-ordinator overseeing data protection matters at your child’s school.

 

4 USES MADE OF THE INFORMATION

Information you give to us

4.1 We will use the information you give to us to pursue the following legitimate interests:

4.1.1 to promote the objects and interest of our schools, and ensure the most efficient management of the schools;

4.1.2 to store this information on the school’s chosen management information system;

4.1.3 to use your child’s photograph as part of a manual ID system on the school management information system;

4.1.4 to contract with other companies and organisations for the purposes of fraud protection and credit risk reduction;

4.1.5 where your child is attending one of our schools, to provide you with information about other similar services (for example, after school activities or open days) we offer as part of the education and overall development of your child at the school (you will be able to opt-out this at any time);

4.1.6 once your child has left the school, to keep you up to date with key school news and upcoming events (you will be able to opt-out this at any time); and

4.1.7 to send out surveys to you by email as part of our Voice of the Parent campaign which is our school improvement tool (you will be able to opt-out this at any time).

4.2 Our schools also rely on software applications and other technology to process personal data about you and your children. These include the school’s management information system, virtual learning environments (including the setting of tasks and homework), revision tools, parents evening booking systems, text and email messaging communications, assessments of pupils’ progress, our group-wide billing system and co-ordination of school trips. The third parties we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your and your child’s personal data is kept secure. Some of our key systems include Capita (SIMS), Evolve, NetSuite, Salesforce, Confirmit and Lightspeed. For further information on the kind of technology we use, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).

4.3 We will also use the information you give to us as is necessary to carry out our obligations arising from the contract (or potential contract) between you and us and to provide you with the information and services that you request from us. We will provide education services to your child and will use personal data where necessary to deliver these services. We will also use your personal information to invoice you for our services pursuant to the contract between you and us. We will also require a certain amount of personal information about you and your child at the pre-contract enquiry and application stage, please see our admissions protocol regarding which information we collect at this stage.

4.4 In addition, we may be required by corresponding applicable law to do the following (which is not an exhaustive list):

4.4.1 keep an admissions and attendance register;

4.4.2 keep pupil files (including, where relevant, special education needs and child protection files);

4.4.3 keep a record of behaviour sanctions; and

4.4.4 provide an annual written report on pupil progress and attainment.

4.5 Inevitably, there will be an overlap between what we do that is necessary to (a) perform our contract with you, (b) carry out our legal obligations and (c) pursue a legitimate interest although we have tried our best to distinguish these as set out above. If you have any questions about these please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).

Information we collect about you from our website

4.6 We will use this information for the following legitimate interests:

4.6.1 to inform you about available places in the future;

4.6.2 to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

4.6.3 to improve our website to ensure that content is presented in the most effective manner, and your online experience is as effective and appropriate as possible, for you and for your computer;

4.6.4 to allow you and your child to participate in interactive features of our service, for example virtual learning environments, when you choose to do so; and

4.6.5 as part of our efforts to keep our website safe and secure.

Information we receive from other sources

4.7 We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for one of the purposes set out above (depending on the types of information we receive). For example, we may receive a court order relating to you which impacts on our use of your and your child’s information to protect the welfare of the child.

4.8 Also, social services or health practitioners may provide us with information (particularly sensitive personal data) about your child which may need to be added to the school’s child protection or special educational needs file. This kind of processing of sensitive personal data may be necessary (a) for the purposes of carrying out our obligations in the field of social security or social protection law, (b) for medical diagnosis or provision of health care and/or (c) to protect the vital interests of your child or another person taking into account the mental and physical capacity of your child.

4.9 In order to achieve the purposes described in paragraph 4.8, our schools may do the following:

4.9.1 keep a list of your child’s allergies or medical requirements within the classroom or staffroom in case of emergency. It is necessary for the school to have a list readily available to our staff so that we are able to look after your child promptly in the event of a medical emergency; and

4.9.2 rely on software applications and other technology to process medical information (such as allergies, accidents and injuries) about you and your children. For further information on the kind of technology we use, particularly in the context of processing sensitive personal data about your child, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).

When we disclose information

4.10 We may share your and your child’s personal information with:

4.10.1 Cognita Regional Office [School community Partners/SCP] in Spain;

4.10.2 a member of the Cognita group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in article 44 of the Code of Commerce;

4.10.3 local authorities, education authorities (for example, National Association of British Schools in Spain (NABSS)), COBIS, Ministry of Education (or local equivalents) SEN co-ordinators, social services or the police where we have reason to believe there are safeguarding concerns in respect of your child;

4.10.4 exam boards (for example, Cambridge Assessment and Pearson) in order to successfully administer exams;

4.10.5 where your child is not British or a national of the Schengen area, we may have to provide information about you or your child to the Spanish immigration authorities;

4.10.6 professional advisors, debt collector, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

4.10.7 credit reference agencies for the purpose of assessing your credit score where this is a condition for us entering into a contract with you.

4.11 We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use the terms of the parents’ contract (between us and you) and other agreements. We may also rely on a legitimate interest to share your information with a third party, for example exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we need to get your consent

4.12 We will not market services to you (other than in accordance with paragraph 4.1.5, 4.1.6 and 4.1.7 above) without your consent and you have the right to ask us not to use your contact details for marketing.

4.13 We will seek your express permission to post any photographs of your child on any of our marketing materials (including our prospectus, advertisements or website). Consent is based on the age and degree of maturity of the child:

4.13.1 where a pupil is under the age of 14 or does not have a sufficient degree of maturity, we require consent from all legal guardians to use images of the pupil on marketing materials, social media and/or within the school; and

4.13.2 where a pupil is over the age of 14 and has a sufficient degree of maturity, we require consent exclusively from the pupil to use images of the pupil on marketing materials, social media and/or within the school.

4.14 You or your child do not have to give us details about your child’s race, religion or ethnicity if you do not want to. If you do provide us with this information, we only use these details to assist us with the day-to-day running of the school (for example, if your child’s religion means that he or she has particular dietary requirements then we will of course be much better informed if we have this information to cater to your child’s requirements) and for equal opportunities monitoring purposes.

Where you have given consent to the above, you can withdraw this consent at any time by contacting the Data Protection Coordinator (see paragraph 3).

 

5 SENSITIVE PERSONAL DATA

When we hold details about you or your child’s medical condition or health, race, ethnicity or religion, this type of information is called “sensitive personal data” which means the school must adopt higher standards of care to make sure this kind of data is safe and doesn’t fall into the wrong hands. It also means that we need to ask for your consent to collect and process that data when we ask for it. We will need to hold sensitive personal data about you or your child (a) for carrying out our obligations in the field of social security or social protection law, (b) for medical diagnosis or provision of health care or (c) to protect your or your child’s vital interests (d) for equal opportunities monitoring (e) for dietary requirements (f) for facilitating religious customs and practices e.g. prayer, dress and holidays / festivals or (g) for identification purposes. Every time we collect sensitive data from you about you or your child, we will inform you and collect your consent to the processing of that data. In order to achieve this, the school may also use software applications and other technology.

 

6 TRANSMISSION OF PERSONAL INFORMATION OUTSIDE THE EEA

6.1 The data that we process about you and your child may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). We try to limit this where possible but it may be necessary where, for example, one of our suppliers, has a data centre outside the EEA. We will take all steps reasonably necessary to ensure that your and your child’s data is treated securely and in accordance with this privacy notice and that the appropriate legal safeguards are in place prior to the transfer, for example ensuring that any contracts between us and the recipient of the information have EU-approved standard data protection clauses, or the country we are transferring the data to is deemed by the EU Commission a country with adequate protection.

 

7 YOUR RIGHTS

7.1 Under the GDPR, you and your child have the following rights:

7.1.1 Right to correction. You have the right to have inaccurate personal data about you or your child rectified.

7.1.2 The right to be forgotten. The right to be forgotten. You have the right to request that we delete yours and your child’s personal data where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 7.1.5 for more details); (d) the personal data has been unlawfully processed; and (e) we are required to erase the personal data in order to comply with the law.

7.1.3 Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 7.1.5 for more details).

7.1.4 Right to data portability. In certain circumstances, you have the right to receive personal data from us in a structured, commonly used and machine-readable format and the right to transmit it to a third party organisation.

7.1.5 Right to object. You have the right to raise an objection to any of our processing in paragraphs 4.1 and 4.2, including profiling and to decisions which are based solely on automated processing. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.

7.1.6 Right to object to marketing. If you do not want us to process your personal data for direct marketing and particularly you do not want to receive commercial communications trough electronic means, please send us an email to the following e-mail address: DPO@cognita.com and we will ensure that you will not receive any direct marketing communications.

7.1.7 Right to complain to the competent authority. Whilst we would always prefer it if you approached us first about any complaints or queries you may have, you always have the right to lodge a complaint with the AEPD.

7.1.8 Right to request access. You have the right to access personal data we hold about you. We encourage you to contact the school’s Data Protection Co-ordinator and request our standard SAR form for you to complete in order to help us process your request.

 

8 HOW LONG WE KEEP PERSONAL INFORMATION

8.1 We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data are processed.

8.2 As a general rule, we keep your child’s education records during the life of the contractual relationship with us and for 6 years afterwards, with access restricted, at which point we destroy the file.

8.3 We follow a personal data retention policy which determines how long we keep specific types of personal information for. For further information about the criteria we use to determine what periods we keep specific information, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).

 

9 USE OF OUR WEBSITE

9.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict risk-based procedures and security features to try to prevent unauthorised access.

 

10 CHANGES TO OUR PRIVACY NOTICE

10.1 Any changes we make to this privacy notice in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice. 

Dated 15 October 2020

ELIS VILLAMARTÍN ONLINE LEARNING SUPPLEMENTARY PRIVACY NOTICE FOR PARENTS AND PUPILS

 

1 INTRODUCTION

1.1 We are continuously committed to protecting and respecting the privacy of our parents and pupils and our staff regardless of whether our learning environment is onsite or online. We may consider it necessary or desirable to provide online education via our virtual learning programme (“VLP“).

1.2 Please read this supplementary privacy notice in conjunction with the Parent Privacy Notice, the Pupil Privacy Notice, and the School’s Photo and Video Consent Form (“Existing Notices”). This supplementary notice (together with the Existing Notices) sets out the basis on which any personal data we collect from parents and pupils, is handled by us when taking part in our VLP.

 

2 USES MADE OF THE INFORMATION

2.1 To ensure that educational content is presented in the most effective manner, and our pupils’ online experience is as appropriate as possible, our VLP will involve:

2.1.1 pupils participating in live, online, face-to-face interactive lessons and tutorials with other pupils and teachers;

2.1.2 pupils participating in live video calls and tutorials with other pupils and teachers;

2.1.3 online chat services;

2.1.4 one-on-one sessions between teachers and pupils in specific cases for example for SEN, or for A-Level tuition;

2.1.5 pupil to pupil interaction;

2.1.6 peer review: teachers reviewing other teachers’ lessons for quality assurance;

2.1.7 recordings of the remote classes being made by the School and stored on the VLP (“Recordings”); and

2.1.8 Recordings being shared between Cognita schools in Spain.

 

3 BASIS OF PROCESSING

3.1 We will use the information we receive to pursue the following legitimate interests:

3.1.1 to deliver educational services to your child and other pupils;

3.1.2 to comply with our obligations under the parent contract;

3.1.3 to comply with the Covid 19 containment measures ordered by the government authorities in the educational field, ordering the temporary suspension of the face to face activities, but having to maintain during this suspension the educational activities through the modalities at a distance and “on line”.

3.1.4 to promote the objects and interest of our schools and ensure the most efficient management of the schools; and

3.1.5 to safeguard our children whilst they are taking part in the VLP.

 

4 THIRD-PARTY SOFTWARE PLATFORMS

4.1 We use third party software platforms including, but not limited to, Teams, Seesaw and Tapestry, to facilitate our VLP; please also read the privacy notices provided by third parties. The third-party notices will set out the data collection, use, and retention for the service they are providing. This notice only sets out how the School uses your data for its VLP.

 

5 HOW LONG WE KEEP PERSONAL INFORMATION

5.1 The Recordings shall be retained by the School for so long as the VLP is maintained by the School and thereafter in accordance with the School’s Retention Policy.

 

6 QUESTIONS

6.1 If you have any questions about this supplementary privacy notice, please contact the School’s DPC.

 

7 CHANGES TO THIS POLICY

7.1 The School reserves the right to update this supplementary notice at any time, you will be notified of any material change.

 

Dated 15 October 2020

ELIS VILLAMARTÍN S.A. GENERAL PRIVACY NOTICE

 

1 INTRODUCTION

1.1 We are committed to protecting and respecting your privacy. Cognita is a group of independent schools. In this privacy notice, references to “we”, “us”, “our”, or “Cognita” is a reference to ELIS Villamartín.

1.2 This privacy notice deals with any personal data we process which is not covered in our parent and pupil privacy notices or our employee notice. It sets out the basis on which any personal data we collect from you is handled by us in the course of our relationship with you. For example, this notice applies to you if you are a potential recruit, next of kin, supplier, or potential supplier, alumni, or prospective pupil or parent of a prospective pupil.

1.3 For prospective parents and pupils, please also see our parent and pupil privacy notices. These are also available on our website. For candidates, please also see our Privacy Notice for Employees, Workers, Candidates and Interns this can be provided on request / will be made available to you as applicable during the requirement process.

1.4 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1.5 For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and the Ley Orgánica 3/2018, de Protección de Datos Personales y Garantía de los Derechos Digitales, we are the data controller and our address is ELIS Villamartín, Las Filipinas, 15., Urb. Blue Lagoon, 3193 San Miguel de Salinas, Alicante, Spain.

1.6 If you are reading this privacy notice online, we recommend that you print and retain a copy for future reference.

2 INFORMATION WE COLLECT ABOUT YOU

Information you give us

2.1 You may give us personal data about you, in a number of ways; these include:

2.1.1 using, visiting or interacting with our website (such as filling out forms or registering on our website);

2.1.2 visiting our offices or schools;

2.1.3 during an interview or meeting;

2.1.4 corresponding with us by phone, e-mail or post; and

2.1.5 sending information directly to us, or providing information as requested by us and/or which is necessary from time to time (for example providing your job application form, CV or business card).

2.2 The information you give us may include the following information about you:

2.2.1 full name;

2.2.2 photograph (for which we will obtain your specific consent to use, when this is collected);

2.2.3 marital status;

2.2.4 social security number;

2.2.5 salary;

2.2.6 employment history;

2.2.7 contact details (including home address, e-mail address, and mobile, home and/or work phone number);

2.2.8 financial information (for example payee details);

2.2.9 passport details, nationality and other information relating to immigration status;

2.2.10 previous educational records and achievements;

2.2.11 information received via safeguarding forms when visiting a site;

2.2.12 references (as an applicant or potential supplier);

2.2.13 information about your physical or mental health, or disability status, to ensure your health and safety at our sites and to assess your fitness to work and to provide appropriate adjustments;

2.2.14 information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation (for which it is optional to disclose); and

2.2.15 certificate of sexual convictions / offences from candidates.

Information we receive from other sources

2.3 We may be working closely with third parties (including, for example, recruitment agents, previous employers, medical practitioners, education authorities, government bodies, regulators, suppliers, payment and delivery services) and may receive information about you from them.

2.4 We may also use CCTV footage to ensure our sites are safe. We may receive information about you if you use any of the other websites we operate or the other services we provide, please see our Cookie Notices for further information.

 

3 CONTACT US

3.1 Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at DPO@Cognita.com or Data Protection Officer, 4th Floor, Plaza Doctor Letamendi, 1-2, 08007, Barcelona, Spain.

 

4 USES MADE OF THE INFORMATION

Information you give to us

4.1 We will use the information you give to us to pursue the following (as applicable to our relationship with you):

4.1.1 promote the objects and interest of our schools, ensure the most efficient management of the schools and ensure that the schools’ legal obligations are adhered to (legitimate interest);

4.1.2 to store this information on our management information system/s (legitimate interest);

4.1.3 to enforce our terms of use with you or any other contract we may have with you;

4.1.4 for the purposes of recruitment (legitimate interest);

4.1.5 to enable us to receive your services; and

4.1.6 where you have attended one of our schools, to keep you up to date with key school news and upcoming events.

4.2 In order to pursue the objectives referred to above, we rely on software applications and other technology to process personal data about you. These include the school’s management information system and our HR and finance systems. The third parties we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your information is kept secure. Some of our key systems include Capita (SIMS), Evolve, NetSuite, Cornerstone, Salesforce, Confirmit and Lightspeed. For further information on the kind of technology we use, please contact our Data Protection Officer (see paragraph 3).

4.3 In addition, we may be required by law to do the following (which is not an exhaustive list):

4.3.1 keep an accounting record of payment;

4.3.2 comply with safer recruitment procedures; and

4.3.3 keep a record to evidence fair recruitment processes.

4.4 Inevitably, there will be an overlap between what we do that is necessary to (a) perform our contract with you, (b) carry out our legal obligations and (c) pursue a legitimate interest although we have tried our best to distinguish these as set out above. If you have any questions about these please contact our Data Protection Officer (see paragraph 3).

Information we receive from other sources

4.5 We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for one of the purposes set out above (depending on the types of information we receive). For example, we may receive a reference from a previous employer relating to you, which may impact a recruitment decision.

When we disclose information

4.6 In order to pursue one of the purposes set out in 4.1.1 to 4.1.6, 4.2, 4.3, 4.4 and / 4.5 above, we may share your personal information with:

4.6.1 Cognita Regional Office in Spain;

4.6.2 A member of the Cognita group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in article 44 of the Code of Commerce;

4.6.3 local authorities, education authorities (for example, National Association of British Schools in Spain (NABSS)), COBIS, Ministry of Education (or local equivalents), SEN co-ordinators, social services or the police where we have reason to believe there are safeguarding concerns in respect of a child;

4.6.4 professional advisors, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

4.7 We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce our contract (between us and you) and other agreements.

Where we need to get your consent

4.8 We will not market services to you (other than in accordance with paragraph 4.1.6 above) without your consent and you have the right to ask us not to use your contact details for marketing. Please contact DPO@Cognita.com if you no longer wish to be contacted by us.

4.9 Where we need to process your sensitive personal data (as detailed in 2.2.13, 2.2.14 and 2.2.15) we will inform you and will collect your explicit consent to that processing at the time at which the data is collected. We may also need to process sensitive personal data about you (a) for carrying out our obligations in the field of social security or social protection law, (b) for identifying medical problems, (c) to protect your vital interests (d) for equal opportunities monitoring. To achieve this, we may also use software applications and other technology.

 

5 TRANSMISSION OF PERSONAL INFORMATION OUTSIDE THE EEA

5.1 The data that we process about you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). We try to limit this where possible but it may be necessary where, for example, one of our suppliers has a data centre outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice and that the appropriate legal safeguards are in place prior to the transfer, for example ensuring that any contracts between us and the recipient of the information have EU-approved standard data protection clauses, or the country we are transferring the data to is deemed by the EU Commission as a country with adequate protection.

 

6 YOUR RIGHTS

6.1 Under the GDPR, you have the following rights:

6.1.1 Right to correction. You have the right to have inaccurate personal data about you rectified.

6.1.2 The right to be forgotten / right of erasure.  You have the right to request that we delete your personal data where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 6.1.5 for more details); (d) the personal data has been unlawfully processed; and (e) we are required to erase the personal data in order to comply with the law.

6.1.3 Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 6.1.5 for more details).

6.1.4 Right to request transfer. In certain circumstances, you have the right to receive personal data from us in a structured, commonly used and machine-readable format and the right to transmit it to a third-party organisation.

6.1.5 Right to object. You have the right to raise an objection to any of our processing in paragraphs 4.1.1, 4.1.2 and 4.2. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.

6.1.6 Right to object to marketing. If you do not want us to process your personal data for direct marketing and particularly you do not want to receive commercial communications trough electronic means, please send us an email to the following e-mail address: DPO@cognita.com and we will ensure that you will not receive any direct marketing communications.

6.1.7 Right to complain to the AEPD. Whilst we would always prefer it if you approached us first about any complaints or queries you may have, you always have the right to lodge a complaint with the AEPD.

6.1.8 Right to request access. You have the right to access personal data we hold about you. Please contact our Data Protection Officer if you wish to do so at DPO@Cognita.com.

 

7 HOW LONG WE KEEP PERSONAL INFORMATION

7.1 We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data are processed.

7.2 We follow a personal data retention policy which determines how long we keep specific types of personal information for. For further information about the criteria we use to determine what periods we keep specific information, please contact our Data Protection Officer (see paragraph 3).

 

8 USE OF OUR WEBSITE

8.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

9 CHANGES TO OUR PRIVACY NOTICE

9.1 Any changes we make to this privacy notice in the future will be posted on our website and, where possible and appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Dated 15 October 2020

ELIS VILLAMARTÍN COOKIE NOTICE

 

What is a cookie?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer’s hard drive. To find out more about cookies, visit aboutcookies.org.

 

About our use of cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

When you visit our website, we may automatically collect the following information:

• technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our number.

 

Cookies we use and why

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
• Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising around the web more relevant to you. We may also share this information with third parties for this purpose.
• You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie	Name	Purpose	More information
PHP Session ID	PHPSESSID	A random unique number or string of letters and numbers.	As you browse around the pages on this site, the session cookie tells the website that you are the same person requesting the webpages, and not a new visitor to each page. This cookie does not identify you personally and is not linked to any other information we store about you.
CMS Cookie	wordpress_test_cookie	We set this cookie when you navigate to the login page. The cookie is used to check whether your web browser is set to allow, or reject cookies.
CMS Cookie	wordpress_xxxxx	We use these cookies to store your authentication details, and their use is limited to the admin console area.
CMS Cookie	wordpress_logged_in_xxxxx	We use this cookie to indicate when you’re logged in, and who you are, for most interface use.
CMS Cookie	wp-settings-xxxxx,wp-settings-time-xxxxx	We use this cookie to customize your view of admin interface, and possibly also the main site interface.
Wordfence Security Cookies	wordfence_verifiedHuman wfvt_XXXXXX	Cookie set by the Wordfence Security WordPress plugin to protect the site against malicious attacks.
Google Analytics Cookie	_ga	Used to distinguish users	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google Analytics Cookie	_gid	Used to distinguish users	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google Analytics Cookie	_gat	Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google Analytics Cookie	AMP_TOKEN	Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google Analytics Cookie	_gac_	Contains campaign related information for the user.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google Analytics Cookie	__utma __utmt __utmb __utmc __utmz __utmv	Several cookies are set but all serve the same purpose: to see how people reached the site and used it, including search terms used and referring sites.	https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
Google Maps Cookie	S PREF NID	This is a unique identifier used by Google applications to store user preferences.	https://policies.google.com/technologies/types
Lucky Orange Cookie	_lo_u	Tell if the user is a unique visitor to the site.	https://help.luckyorange.com/article/173-what-cookies-does-lucky-orange-set
Lucky Orange Cookie	_lo_rid lo_session_in	The user’s recording ID. This is auto extended as the visitor visits pages.	https://help.luckyorange.com/article/173-what-cookies-does-lucky-orange-set
Lucky Orange Cookie	_lo_v	Total number of visits from this user.	https://help.luckyorange.com/article/173-what-cookies-does-lucky-orange-set
Lucky Orange Cookie	__lotr	Original Referrer the visitor came to the site from.	https://help.luckyorange.com/article/173-what-cookies-does-lucky-orange-set
Lucky Orange Cookie	_lo_cid	The chat ID of the current chat, if any	https://help.luckyorange.com/article/173-what-cookies-does-lucky-orange-set
Ad Tracking Cookie	utm_source utm_medium utm_campaign utm_term utm_content	These cookies are used to store information about the ad referral networks.
Cookie Notice	cookie_notice_accepted	This stores the consent of the cookie notice for the visitor
vimeo.com player.vimeo.com	vuid player __utma __utmb __utmc __utmz __utmt_player	Vimeo is a video-sharing website allowing users to upload, share and view videos.	https://vimeo.com/cookie_list
facebook.com	fr	Facebook is an online social media and social networking service	https://en-gb.facebook.com/policies/cookies/
http://bing.com bat.bing.com c.bing.com/	MUID MUIDB ANONCHK MR	Bing is a web search engine owned and operated by Microsoft.	https://privacy.microsoft.com/en-gb/privacystatement
google.com	NID	Google is a technology company specialising in internet-related services and products.	https://www.google.com/policies/technologies/types/

 

We have no control over third party cookies

• Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
• Our website may also contain links to and from the websites of our partner networks, advertisers, suppliers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own cookie notices and privacy notices and that we do not accept any responsibility or liability for these notices.  Please check these notices before you submit any personal data to these websites.

 

How do I change my cookie settings?

Generally, browsers allow some control of most cookies through the browser settings. To find information relating to the browser you are using, please visit the browser developer’s website, below are links to some of the most common browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Apple Safari

 

What happens if you block cookies?

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site and your user experience may be seriously downgraded whilst browsing the site.

 

Expiry of Cookies 

When we send a cookie, we instruct your browser to keep that cookie for a certain period of time, for example, we may instruct your browser to keep the cookie for the period you are on the website; this is known as a “session cookie”. You can override the cookie expiration periods set by us, or any other website, by changing your cookie settings. If you do not change your settings, then, all cookies set by us will expire after 6 months. Default expiration settings will vary for third-party cookies; you can find out more about these by following the links in section 3.5.

 

Contact us

If you have any questions regarding this Cookie Notice please contact servicedesk@cognita.co.uk.