The American International School of Rotterdam (“AISR”) processes personal data on its prospective, current and former students and their parents or legal guardians, as part of its everyday operations of providing educational services.
AISR handles your personal data according to the General Data Protection Regulation no. 679 / 2016 applicable in the European Union (“GDPR”). For these purposes, AISR acts as controller with regard to your personal data and the personal data of students (“Personal Data”), meaning AISR establishes the purposes and means of processing the Personal Data.
AISR wishes to be completely transparent with regard to the processing of Personal Data and therefore, we have presented below all the information you may need on this subject matter.
1. The purposes for which AISR processes your Personal Data:
AISR processes Personal Data that pertain to you or to the students for the following purposes:
- Provision of educational services, starting with the application process, enrolling students, administration of classes and timetable, teaching activities, administration of internal and public examinations, assistance regarding the application process to various universities, issuance of academic records.
- Provision of educational ancillary services: career and personal counselling, library services, extracurricular activities, school trips, managing school’s publications, setting up the virtual learning environment and granting access to AISR’s Parent Portal, Intranet and Internet network as well as monitoring the use of AISR’s network.
- Ensuring campus security: monitoring access on campus, performance of video surveillance.
- Provision of the medical care and counselling that students may need.
- School administration: handling student records and other academic documentation, administration of fees and accounts, internal audits and controls, reporting and statistics creation, implementing school policies, ensuring collaboration with other schools, archiving, assessing the quality of our services, facilitating research activities.
- School related communications (e.g. AISR Newsletters and direct emails): conveying various messages related to the students and AISR’s activities by any communication means.
- Organizing fundraising activities and other school events (e.g., concerts, theatre productions, movie nights), including marketing communications related to the fundraising activities organized by AISR.
- Dispute resolution and litigations.
2. The categories of Personal Data that AISR processes, include, but are not limited to the following:
- Identification and contact information (first and last name, citizenship, country of birth, address, phone number, email, information included in ID’s / passports etc.); Bank details, school photos;
- Health data: medical history, allergies, immunization records, disorders, medical examination results and other medical data of the students;
- Data related to the educational background and regarding school performance of the students: report cards plus any other academic, disciplinary or educational related records, academic references, special needs, co-curricular activities, results of educational diagnosis testing, test results, feedbacks, evaluations etc.;
- Behavioral data as well as data on preferences / interests of students;
- Family information: household information, language background, profession and workplace of parents etc.;
- Authentication and access data: e-mail, passwords, student ID number, location data, other on-line identifiers etc.;
- Photos and videos.
Generally, the Personal Data held by AISR were provided directly by the parents or resulted from the interaction the parents and the students have with the school. In some cases, third parties (e.g., representatives of former schools attended by students) supply data.
3. The lawful basis for the processing operations we conduct with regard to the Personal Data
AISR collects and further processes Personal Data, based on one of the following legal grounds, expressly laid down by the GDPR:
- For the performance of the enrollment contract, as well as in order to take steps at your request for entering into the enrollment contract and to further provide the educational services.
- The consent you have granted us, prior to any processing of the personal data, for:
- the use of students’ photographs and videos in various school publications, on AISR’s website and social media pages;
- the use of your contact details for direct marketing communications on AISR’s fundraising and other activities;
- other consents that may be granted from time to time for various processing activities.
Please note that there are some mandatory categories of personal data necessary to AISR in order to conclude the enrollment agreement and provide the educational services to students at a high standard and in the best interest of the students.
The mandatory categories of personal data are included in the application form, which you have filled in on-line and listed in the enrollment contract you already have/will sign with AISR. All the categories of data that are compulsory for contract conclusion are marked accordingly in the application form.
Please take into consideration, that all the mandatory categories of data are necessary for AISR to be able to evaluate your application and finally to enroll your child. Failure to provide all the information marked as mandatory will lead to the impossibility of AISR to process your application and to enter into a contract with you.
- A legal obligation that requires AISR to process your Personal Data (e.g. performance of video surveillance).
- For the performance of a task carried out in the public interest, considering that AISR provides educational services, regarded as a service of public interest, according to the Dutch applicable provisions on education, many processing operations conducted by AISR that are strictly related to educational purposes will be founded on this lawful basis for processing. We refer here mainly to:
- issuing and storing academic records, evaluating students’ performance etc.
- The legitimate interest pursued by AISR.
AISR relies on this legal ground in order to provide the educational services it has committed to deliver and additional services related to this scope at the highest standards, always for the benefit of the students and without outweighing the parents or the students’ rights and liberties.
AISR may invoke the legitimate interest legal ground in the following cases:
- monitoring use of the AISR’s digital learning environment and network, including monitoring the use of e-mails account provided by AISR;
- conducting fundraising activities, including marketing of such activities;
- satisfaction surveys;
- enforcement of legal claims, addressing complaints and third party controls;
- management, control, reporting and performing statistics on schools activity;
- ensuring security;
- maintaining close relationships with alumni and AISR’s community;
- collaboration with other schools and educational institutions;
- performance of agreements with suppliers, including insurance suppliers;
- access to grants and other funding sources.
With respect to the processing of the special categories of personal data under the GDPR, respectively health data, please take into consideration that AISR processes health data based on the following legal grounds:
- The necessity of the Medical Office to process such data for the purpose of preventive and occupational medicine, medical diagnosis and the provision of health or social care or treatment on the basis of European Union or national law;
- Processing is necessary for reasons of substantial public interest, on the basis of European Union or national law. Such a legal ground is used especially in those situations where the school has to assess the learning capacity of a student and adapt the teaching activities to the special needs of a student.
- The explicit consent granted by you for the disclosure of the personal data of students related to the allergies they suffer from.
4. Disclosure of Personal Data
AISR discloses your Personal Data only to those members of AISR, staff and collaborators, who need access to the personal data mainly for ensuring the provision of the educational and ancillary services. In this respect, please take into account that only the Medical Office has access to the students’ medical records. Other departments of the school have access to specific health data based on the consent you have expressed (i.e. for allergies) or in order to protect a substantial public interest based on E.U. or national law (e.g., various medical conditions triggering special learning needs).
With respect to the disclosure of your Personal Data to third parties, outside AISR, please note that such disclosure is performed solely in the regular activity of the school. The categories of recipients include the following:
- IT providers, including educational applications, on-line tools, server hosting suppliers such as ManageBac etc.
- Cafeteria Owner in its capacity of independent provider of meal services on campus;
- Other educational institutions or organizations, not limited to other schools;
- Transportation providers;
- AISR’s official school photographer;
- Courier services providers;
- Public authorities and institutions, national or foreign, judicial courts and foreign embassies or other forms of diplomatic missions;
- Tax, legal and accounting consultants.
5. Third country transfers
AISR transfers your personal data to companies outside of the EEA, as follows:
- United States of America – to third parties that have obtained EU – US Privacy Shield certification or operate under a Model Clause (i.e. Faria Systems LLC as provider of the ManageBac and Open Apply applications, MailChimp, Google as provider of GSuite).
6. Retention of Personal Data
AISR holds all your Personal Data for as long as you are in a contractual relation with us, and afterwards for a standard period of the date of the student’s graduation (or date of leaving the school) plus 3 years, the period for which AISR can justify a need in storing such personal data. AISR keeps the student file and all the data related to the student interaction with AISR mainly for the scope of assessing the school’s activity and the quality of services provided but also for addressing potential request of students with regard to their school trajectory within AISR, which usually appear after the students have graduated.
Notwithstanding the retention period mentioned above, please be informed that all the academic records and other school acts and documents related to study activities are kept for a period of the student’s date of birth plus 25 years according to the legal obligations that AISR has in this respect. Moreover, in any case where a legal provision imposes a minimum retention period, AISR will keep the Personal Data for at least that mandatory period.
7. Your rights related to the processing of Personal Data by AISR
The GDPR provides certain rights related to the processing of personal data, that both you and the students have. In this respect, please be informed that students that have an appropriate level of understanding could exercise the rights listed in this section, individually.
AISR respects all the rights mentioned under the GDPR and is committed to furnishing the appropriate means by which you can exercise these rights, according to the details mentioned below:
- The right of access, which entails your possibility to obtain the confirmation from AISR whether your Personal Data is being processed by AISR or not, and if the case may be you are entitled to solicit access to this data, as well as additional information regarding the Personal Data, such as: the purposes of processing, the categories of recipients the Personal Data are being disclosed to and the envisaged retention period. In the situations where you may need to exercise the right of access, please consider contacting AISR and requesting confirmation by e-mail at email@example.com. Please consider that there might be specific situations that are exempted from the right of access, such as information that identifies other individuals or which is subject to confidentiality obligations.
- The right to rectification, that allows you to request AISR rectification of any inaccurate Personal Data that AISR may hold, as well as to have your incomplete Personal Data to be completed.
- The right to erasure meaning that in the situations expressly regulated by law, you may request erasure of your personal data. Please take into account, that the cases where the law provides for the possibility of erasure of personal data amount to the situations where the processing is unlawful or where the processing is based on your consent, and you have withdrawn such consent.
- The right to restriction of processing, signifying your right to obtain restriction of processing your Personal Data from AISR’s part. Please bear in mind that this right can be exercised only in specific situations laid down by the GDPR such as when you challenge the accuracy of your Personal Data. During the period necessary for us to rectify your data, you may ask us to restrict the processing of your Personal Data.
- The right to data portability implying your right to receive the personal data in a structured, commonly used and machine-readable format and further to transmit such data to another controller. This right to data portability shall be applicable only to the personal data you have provided to us and where the processing is carried out by automated means based on your consent or for the performance of the contract you have concluded with AISR.
- The right to object to the processing of your Personal Data by AISR, on grounds relating to your particular situation. The right to object applies to the situations where AISR relies on consent as legal basis for processing (e.g. using your e-mail address for conveying fundraising related messages).
- The right to lodge a complaint designates your right to challenge the manner in which AISR performs processing of your Personal Data with the competent data protection authority.
- The right to withdraw your consent given for various processing operations, in cases where the consent represents the lawful basis for processing. In cases where you withdraw your consent to processing your Personal Data, please note that the processing will end from the moment the withdrawal takes place without any effect on the processing that took place prior such withdrawal.
AISR creates various profiles through automated means based on the Personal Data that pertain to students. Generally, such profiles are created via various applications used in the on-line education environment such as: MAP Testing Tool and Learning Analytics Collaborative.
AISR creates and uses such profiles to evaluate the performance of its students, to identify gaps in their development or to assess specific traits that characterize students’ personality, preferences, and behavior or professional inclinations.
9. Video Surveillance
AISR has implemented a video surveillance system on the campus, in order to ensure security of its students, staff and all the other persons that enter our premises. The security and wellbeing of our students is our primary concern and these video cameras allow us to offer real time protection.
Signs are posted on the entrances to the campus signaling that video surveillance is being used.
10. Contact Point
Contact Details of AISR’s Data Protection Officer:
E-mail address: firstname.lastname@example.org
Phone Number: +31(0)104225351
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