Your privacy is important to us

High Schools International collects and uses personal information about staff, students, their families, host families, and other individuals who come into contact with the company. This information is gathered in order to enable it to provide guardianship and other associated functions. In addition, there may be a legal requirement to collect and use information to ensure that the company complies with its statutory obligations.

Purpose

This policy is intended to ensure that personal information is dealt with correctly and securely and in accordance with the General Data Protection Regulations 2018 and other related legislation. It will apply to information regardless of the way it is collected, used, recorded, stored and destroyed, and irrespective of whether it is held in paper files or electronically.

All staff involved with the collection, processing and disclosure of personal data will be aware of their duties and responsibilities by adhering to these guidelines.

What is Personal Information?

Personal information or data is defined as data which relates to a living individual who can be identified from that data, or other information held.

Data Protection Principles

The GDPR 2018 establishes six enforceable principles that must be adhered to at all times:

  1. Lawfulness, Fairness & Transparency Personal data shall be processed fairly and lawfully; we will tell you what kind of data we collect. Data will only be shared in ways compatible with the purpose of collecting the data
  2. Purpose Limitation: Personal data shall be obtained only for one or more specified and lawful purposes; and will be shared only in a manner compatible with these purposes
  3. Data Minimisation: Personal data shall be adequate, relevant and not excessive;
  4. Accuracy Personal data shall be accurate and where necessary, kept up to date;
  5. Storage Limitation: Personal data processed for any purpose shall not be kept for longer than is necessary for that purpose or those purposes;
  6. Integrity & Confidentiality Personal data shall be kept secure i.e. protected by an appropriate degree of security;

 

General Statement

HSI in Ireland and the UK is committed to maintaining the above principles at all times.

HSI Ireland and UK collects the following information on those it is contracted to and those who contact the company.  Relevant categories are Students, Natural Parents, Host Families, HSI Staff, Schools and Overseas Partners

  • Personal information on applicant students – names, dates of birth, address(es), nationality, sex, family members and their details (names, addresses, telephone contact details, email addresses, relationships to applicants), school transcripts, medical history as relevant to HSI, personal statements, photographs (both digital and otherwise) of applicants and their family/friends
  • Personal information on actual and potential host families, including names, dates or birth and addresses of all relevant family members, occupations, schools attended, house type and composition, photographs (digital and otherwise) of family and individual members of family, pets, hobbies, interests, transport options
  • HSI is also obliged to request Police Vetting in both jurisdictions on all staff, ancillary staff, host family members resident in the home and over the age of 16 years
  • School information, including name, address, details of relevant staff (head, international officers etc), numbers of staff and students, nationality mixes
  • Actual and Potential host family information and school information is updated on an annual basis
  • HSI collects information, both digital and physical on all staff contracted by it and persons contracted to supply services to clients,.  This information includes CV’s Photographs (digital and physical), work and personal references, certification (degrees etc) and any other information supplied by staff and potential staff
  • HSI ensures that obsolete information is destroyed and that it is done so appropriately and securely
  • HSI ensures that clear and robust safeguards are in place to protect personal information from loss, theft and unauthorised disclosure, irrespective of the format in which it is recorded
  • Share information with others only when it is legally appropriate to do so. HSI shares student information as detailed above with prospective host families and schools.
  • HSI shares appropriate school and host family information with prospective applicants and their local agents
  • All overseas partners have been informed of their obligations under GDPR and have given their consent to abide by all data protection requirements under GDPR
  • HSI has protocols in place to ensure compliance with the duty to respond to requests for access to personal information, known as Subject Access Requests.
  • Ensure our staff are aware of and understand our policies and procedures

Complaints

Complaints will be dealt with in accordance with the company’s complaints policy. Complaints relating to information handling may be referred to the Information Commissioner (the statutory regulator).

 

Review

This policy will be reviewed as it is deemed appropriate, but no less frequently than every 2 years. The policy review will be undertaken by the Managing Director, or nominated representative.

Contacts

If you have any enquires in relation to this policy, please contact Declan Millar (Managing Director) dmillar@hsinet.org  who will also act as the contact point for any subject access requests.


Appendix 1

High Schools International

Procedures for responding to subject access requests made under the Data  Protection Act 1998

Rights of access to information

There is a distinct right of access to information held by HSI about students.

  1. Under GDPR 2018 any individual has the right to make a request to access the personal information held about them.

These procedures relate to subject access requests made under GDPR 2018

Actioning a subject access request

  1. Requests for information must be made in writing (which includes email), and be addressed to Rachelle Nelson (rnelson@hsinet.org) in the UK and Declan Millar in Ireland (dmillar@hsinet.org) If the initial request does not clearly identify the information required, then further enquiries will be made.

 

  • Any individual has the right of access to information held about them. However with children, this is dependent upon their capacity to understand (normally age 12 or above) and the nature of the request. The Operations Manager should discuss the request with the child and take their views into account when making a decision. A child with competency to understand can refuse to consent to the request for their records. Where the child is not deemed to be competent an individual with parental responsibility or guardian shall make the decision on behalf of the child.
  • The company may refuse to provide copy or access to this information if it can demonstrate that the request is manifestly unfounded, of a vexatious nature or excessive. HSI must be able to the justify the grounds for refusal
  • The identity of the requestor must be established before the disclosure of any information, and checks should also be carried out regarding proof of relationship to the child. Evidence of identity can be established by requesting production of:
    • passport
    • driving licence
    • utility bills with the current address
    • Birth / Marriage certificate
    • P45/P60
    • Credit Card or Mortgage statement

    This list is not exhaustive.

  1. Type of Data you may request

Along with the personal information requested you may also request:

  1. The purposes for processing the data.
  2. The categories of personal data concerned.
  3. To whom the data has been or will be disclosed.
  4. Whether the data has been or will be transferred outside of the EU.
    The period for which the data will be stored, or the criteria to be used to determine retention periods.
  5. The right to make a complaint to the Data Protection Commissioner.
  6. The right to request rectification or deletion of the data.
  7. Whether the individual has been subject to automated decision making.The GDPR also includes the right to data portability. In particular, this new right enables an individual to require an organisation to transmit their data to another organisation.
  8. The response time for subject access requests, once officially received, is one month except in the case of
  9. Third party information is that which has been provided by another, such as the Police, Local Authority, Health Care professional or school.

Before disclosing third party information consent should normally be obtained.

There is still a need to adhere to the one month statutory timescale.

Complaints

Complaints about the above procedures should be made to the Director of the Company who will decide whether it is appropriate for the complaint to be dealt with in accordance with the company’s complaint procedure.

Complaints which are not appropriate to be dealt with through the Company’s complaint procedure can be dealt with by the Information Commissioner. Contact details of both will be provided with the disclosure information.

 

Contacts

If you have any queries or concerns regarding these policies / procedures then please contact Rachelle Nelson, Operations Manager.

Further advice and information can be obtained from the Information Commissioner’s Office, www.ico.gov.uk or telephone

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