IES INTERNATIONAL HOUT BAY SCHOOL: PRIVACY POLICY
INTRODUCTION
IES International Hout Bay School (“the School”) is a registered Independent school and registered as such in accordance with the South African Schools Act,84 of 1996 (“Schools Act”).
The School respects your right to Privacy as well as your right to access to information and as such is committed to protecting the privacy of visitors to this site and treats all Personal Information in its possession with the utmost discretion.
As part of our commitment to protecting your Personal Information, and as required by the law, the Schools processing activities (which involve Personal Information) are all aligned with the Protection of Personal Information Act, 4 of 2013 (“POPIA”).
All processing activity, carried out by the School, will be as per this Privacy Policy.
For the sake of clarity, this Privacy Policy is to be read in conjunction with POPIA and in no way is this Policy intended to replace and/or circumvent the requirements on the School when acting as a Responsible Party and as required by POPIA.
The School is committed to the upholding of Data Subject’s rights to Privacy as well as Access to Information as enshrined in the South African constitution.
In compliance with this commitment, this Privacy Policy sets out how the School will use Personal Information, and this will apply to any information collected by the School, including Personal and Special Personal Information , that you give to the School or the School collects from third parties.
Please read this Privacy Policy carefully prior to providing the School with any Personal Information (whether such Personal information is processed from you as a Data Subject or where Personal Information pertaining to a student (who is a minor child under the age of 18 years) and has been provided by such minor child’s parents and/or legal guardian (acting in the capacity as a Competent Person).
What is Personal Information?
Processing means the process of collecting, receiving, recording, organising, collating, storing, updating , change, retrieve, read, process, analyse, use and share your Personal Information for any purpose as set out in this policy or which you may consent to (from time-to-time).
Where the School carries out one or more of the items described in this clause, the School will be deemed to be processing your Personal Information.
Personal Information means private information about an identifiable person (which shall include natural persons as well as juristic persons).
Personal Information does not include information which does not identify a living person (which shall include cases where the information has been de-identified).
Your Personal Information includes the following:
- Identifying Information: which may include information concerning your name and surname, username (or similar), marital status, title, date of birth, gender, race, identity documents, photographs, registration number and qualifications achieved;
- Contact Information: which includes cellular number, home landline, addresses and email address;
- Transaction Data: which includes payment method details, bank account and any other payment information in regards to payment to and from you. For the purpose of this clause, Financial Information shall refer to details which include Bank Account details and financial statements;
- Security Data: which may include records of your access to our facilities, as well as CCTV camera footage or you on or near to our premises;
- Technical Data: including your Internet Protocol (IP Address), your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating systems and platform , as well as other technology on the device you use to access the School’s website.
- Marketing and Communicating Data: which includes your preferences in regard to receiving marketing from the School, as well as your communication preferences.
Any direct marketing received from the School will provide you with an option to opt out should you no longer wish to receive direct marketing from the School.
Special Personal Information may be collected in certain circumstances, with your prior written consent. Such information may include:
- Your race or ethnicity or religion;
- Your health;
- Criminal behavior (relating to offences allegedly committed or pending proceedings against you).
Collection of Personal Information and why is it needed?
In order for the School to offer you its education services and other ancillary services, we are required to collect, use, share and store (Process) Personal Information about you or your child (where you are acting as a Competent Person) so that the School can:
| COLLECTION OF INFORMATION | INFORMATION COLLECTED | USE FOR SUCH INFORMATION |
|---|---|---|
| On enrolment and collected throughout the academic year, with your prior consent | Full Name, Identity Number, Email Address, Contact details (Cell/Phone). Minor Child Information, which may include: Previous academic results; Health information; Dietary Requirements. | In order for the School to contractually engage in an admission agreement for the upcoming academic year. Personal Information may be used to market the Schools Services to you as well as to verify your identity and assess your financial standing in so far as the payment of School Fees is concerned. |
| When engaging with Third Party | Full Name, Identity Number, Email Address, Contact details (Cell/Phone). Minor Child Information, which may include: Previous academic results; Health information; Dietary Requirements. | Personal Information. Will only be shared with a Third Party where there is a need to share such Personal Information with the third party. However the sharing of such Personal Information shall be on condition that the School has a lawful reason to do so. Lawful reason for sharing Personal Information will be as follows: – With the prior informed consent of the Data Subject or a Competent person; – We have an existing obligation to share such Personal Information in order to execute and comply with the terms of an agreement concluded between you and the School; – The School is required by law to process such Personal Information; – The processing protects your legitimate interest. |
When using the School website
| COLLECTION OF INFORMATION | USE FOR SUCH INFORMATION | Security |
|---|---|---|
| Cookies. we may send to your computer and from web beacons on our website. | From this process the School collects information which allows us to track how you engage with our website, with the view of constantly improving your experience and services we provided to you. | You can turn off cookies in your browser. |
| Optional/Promotional Information | From time-to-time we may share promotions, competitions or other events aimed at promoting the School’s Services or in regard to raising funds for an approved School activity. You will have the ability to opt out from future communications by emailing io@iesmail.com. | You can opt-out of marketing communications with us by clicking on unsubscribe link in any marketing email or by emailing io@iesmail.com. |
Processing of Personal Information of Children
Where any information which is collected from you contains Personal Information pertaining to Children (minors under the age of 18 years), the processing of such Personal Information of Children will only be carried out where this Personal Information has been provided to the School with the prior consent of a competent person , such as a Parent and/or Legal Guardian. The above will not be applicable in the event of a lawful need to process such information, provided that such information is maintained in a manner which is no less stringent the protection measure required by POPIA.
Use of the School website will only be allowed where the Data Subject is over the age of 18 years, or alternatively where a person under the age of 18 years access the website they may only do so with the prior consent of a Competent Person.
How we collect your Personal Information
The School will only collect Personal Information from a Data Subject (you) in one of 3 ways, namely:
- Directly from you, as the Data Subject, with your prior consent;
- The School may require certain Personal Information from you in order to access parts of the School site, alternatively to enable the School to provide services to you or to conclude an enrolment agreement.
- Through automative or passive interactions with you;
Collection from browser
We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (“IP address”), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (“usage information”).
Cookies
When you access our website, we may send one or more Cookies (small text files containing a string of alphanumeric characters) to your computer to collect certain usage information. We use session Cookies (which disappear after you close your browser) and persistent Cookies (which remain after you close your browser and which can be removed manually) which may be used by your browser on subsequent visits to our website.
We use information gathered by Cookies to improve the website. Please note that some of our business departments (e.g. marketers) use the Cookies or widgets on our website.
Refusing a Cookie may, in some cases, preclude you from using, or negatively impact your use of the School website.
The School uses Google Analytics and Cookies to target our marketing.
Google Analytics is a web analysis service that analyses how users interact with the site. On behalf of the School and based on your consent, Google will use this information to assess your use of the website, to compile reports on website activity and to provide the website operator with other services related to website and internet use.
We use the IP anonymization tool offered by Google Analytics in order to ensure anonymous collection of IP addresses (so-called IP masking).The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
How can you control Cookies?
To prevent your data from being used by Google Analytics, download and install the Google Analytics Opt-out Browser Add-on and click on the blue button.
For more information on terms of use and data protection, please visit the Analytics Help page; Safeguarding your data.
In addition, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing Cookies. Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website. If you use different devices to access our website, you will need to ensure that each browser of each device is set to your Cookie preference.
To find information about how to manage Cookies in the most commonly used browsers, visit the following addresses below:
- Chrome: Google Chrome Cookie Support
- Firefox: Mozilla Firefox Cookie Support
- Safari: Apple Safari Cookie Support
- Microsoft: Microsoft Cookie Support
If you are in need of further assistance, please email io@iesmail.com.
Third Parties.
Processing Personal Information to any Third Party will be done in accordance with the Data Subjects consent, alternatively for a recognised purpose as listed in section 6 of POPIA. Where the School receives Personal Information about you from various third parties and/or public sources, such information will be treated with the utmost care and in confidence.
Who do we share your Personal Information with?
In general, the School will only share your Personal Information with a Third Party, where the School has obtained your permission or for any purpose as set out in this privacy policy.
The above notwithstanding, the School may share your Personal Information under the following circumstances:
- To Third Party service providers and suppliers who have agreed to be bound by this privacy policy or on terms which offer the same level of protection to a Data Subjects Personal Information to that contained in POPIA.
- To employees and/or contractor staff to the extent that they have an operational need for such Personal Information.
- In order to enforce or apply any agreement between the School and You.
- To government agencies, exchanges and other regulatory or self-regulated bodies if required by law or pursuant to an ongoing legal investigation.
Cross Boarder Transfer
Personal Information collected by the School, may be collected in, or transferred to a destination outside of the Republic of South Africa. Such destination may not have comparable Personal Information legislation which provides the same level of protection to that required by POPIA. The School will ensure that there exists a binding agreement in place with such overseas Third Party ensuring the protection of your Personal Information to a level which is the same which is required by POPIA, or which other Personal Information Protection legislation that may replace POPIA from time-to-time.
How does the School protect your Personal Information
The School is committed to ensuring that the Personal Information processed by the School is secure. To achieve this, as well as to prevent unauthorised access or disclosure, we have put in place reasonable physical, electronic and managerial procedures in place to safeguard and secure the Personal Information for which the School is responsible for. The aforementioned measures are designed to ensure the security of your Personal Information by taking reasonable measures to prevent the unlawful destruction, unlawful access as well as loss of Personal Information. Where the School reasonably suspects that Personal Information may have been compromised, the School will notify you in writing.
The above notwithstanding, while the School will take the above measures to protect your Personal Information and ensure its accuracy and correctness, it will always be an obligation on you to notify the School of any change to your Personal Information. Please contact the School at io@iesmail.com should you:
- Require to access your Personal Information which is stored on the Schools database;
- Wish to contact us and inform the School of a change to your Personal Information or that or your minor child;
- Should you want your Personal Information to be removed from our database.
How long will the School store your Personal Information
The School will store your Personal Information for as long as we have a lawful need for such Personal Information, as required by law. The School may store your Personal Information for longer than needed, only where this is pursuant to a lawful requirement imposed on the School.
The Personal Information that you provide to the School will be stored electronically on the schools servers as well as in hardcopy format, provided that this hardcopy information will at all times be protected with reasonable organisation and technical safeguards in place to protect such Personal Information.
Where you have opted to receive direct marketing or news letters from the School, the School will then retain your Personal Information until such time chose to unsubscribe from this service.
The School will only be able to keep and process your Personal Information if and for so long as:
- The School is required or permitted by law or agreement with you;
- The School has a reasonable need for such Personal Information based on lawful purposes related to the functions and/or activities of the School;
- We have a reasonable need to retain such Personal information for evidentiary purposes; and
- Where you agree to the School storing your Personal Information for a specified further period.
Access to Information
As mentioned above, the School is committed to acting in accordance with your right to privacy as well as your right of Access to Information, as enshrined in the Constitution of the Republic of South Africa. In light of the above, you have the right to request from the School whether the School holds any Personal Information as well as which third parties we share your Personal Information with. Such request can be made through the Schools PAIA manual which can be found on the School’s website.
Once the School has given the information requested above, you have the right to ask the School to:
- Correct or delate any Personal Information pertaining to you, which is in the Schools possession or under its control;
- Destroy or delete a record of Personal Information held by the School;
- opt out from receiving any further direct marketing from the School.
Changes to this Policy
Any change to this Privacy Policy will be made available on the Schools website, and will deem to apply from the date of publication.
Complaints
You may submit complaints about the processing of Personal Information by emailing io@iesmail.com.
In the event of you not being satisfied with the way in which your compliant was handled you may contact the Information Regulator by completing the prescribed form 5 and emailing to POPIAComplaints@inforegulator.org.za. For more information in this regard you can visit the Regulator’s website at https://inforegulator.org.za.
Our Contact Details
- IES Group Information Officer
- Email: io@iesmail.com
- Website: Houtbayinternational.co.za
