English 31 (E31) requires certain personal data-including some that is sensitive-about its past and present employees, students, parents, legal guardians, alumni, and other community members, in order to function well as international school, and as an employer in France.
This policy is intended to ensure that E31 protects all personal data in accordance with the EU General Data Protection Regulation (EU-GDPR), and other related legislation. It applies to dara regardless of the way it is collected, used, recorded and shared, and irrespective of whether it is held in paper files or electronically.
This policy applies to all employees, trustees, volunteers, and other working on behalf of E31 ("members of the E31 working community"). All members of the E31 working community involved with the collection, processing and disclosure of personal data should be aware of their duties and responsibilities and adhere to these guidelines.
Individuals at English 31 may have access to a wide range of personal and sensitive data regarding other individuals, depending on their role.
Personal data means any information about, or that may be used to identify, a living person. E31 recognizes that any such data belongs to that individual ("data subject"), and NOT to E31 or any other person or organization with whom we may share it. The data subject must be provided with complete information concerning the use of their data, and have ultimate control over its use.
Personal data includes, but is not limited to:
- information about members of the school community, suh as their name, address, email address, phone numbers, health records and disciplinary records;
- curricular or academic daa such as attendance records, grades, comments on progress and achievement, reports and recommendations;
curricular or academic data such as attendance records, grades, comments on progress and achievement, reports and recommendations;
professional records such as employment history, taxation and social insurance records, confidential employee files and references;
data held as photographs, video clips (including CCTV footage) or as sound recordings;
any expression of opinion about an individual kept in a school file or system, or any indication of the school' or someone else's intentions towards an individual;
any other information that might be disclosed by parents, or by other individuals or agencies working with families or employees.
Under the EU-GDPR, special categories of personal data ("sensitive data") require additional protection: information that concerns or reveals a person's political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, sate of health, and sex life or sexual orientation. Data concerning children under the ager of 15 is also subject to special protections.
Data Protection Principles
The EU–GDPR establishes six principles to which E31 is held accountable whenever it handles personal data. Personal data shall be:
processed lawfully, fairly and in a transparent manner in relation to the data subject;
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
accurate and, where necessary, kept up to date;
kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
The E31 director is ultimately responsible for ensuring that the necessary systems, policies and procedures are in place to ensure that all personal data is appropriately protected, and that all employees, trustees, volunteers, and others working on behalf of E31 who process or use personal data follow these principles at all times. To that end, E31 has instituted this Data Protection Policy.
This policy does not form part of any employee's contract, although it forms part of the policies accepted as a condition of employment and may be amended at any time. Any breach of this policy by employees may result in disciplinary action.
In order to protect personal data from loss, theft and unauthorized access or disclosure, E31 will deploy necessary physical and technological security systems.
These systems and backup systems will be fully documented, regularly tested, and periodically audited.
All individuals whose use technology provided by E31 will be required to comply fully with the respective protocols and procedures.
We take any complaints about our collection and use of personal information seriously. If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance. To make a complaint, please contact the director of English 31 at firstname.lastname@example.org
Alternatively, you can make a complaint to the CNIL (Commission Nationale de l'Information des Libertés):
- report at concern online at https://www.cnil.fr/en/contact-cnil
- call 01 53 73 22 22
- or write to : CNIL, 3 Place de Fontenoy, TSA 80715, 75334 Cedex 07
This policy will be reviewed as it is deemed appropriate, but no less frequently than annually by the Committee of Elected Parents or a nominated representative.
Published by: "Association des parents d'élèves English 31"
Publishing Director: Garett Smith, English 31 President
Integration and Development: e4 education
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