General Privacy Notice
The General Privacy Notice for Aiglon College, as adopted by the School Council in June 2018, is available on this page. The School's Data Protection Coordination Group (DPCG) can be contacted here.
Who We Are
This privacy notice relates to the following corporate entities:
- Aiglon College Association
- Aiglon College Services SA
All of the above entities have registered offices at Aiglon College, Avenue Centrale 61, 1885 Chesières-Villars, Switzerland and for the purposes of this policy will hereafter be referred to as ‘the School’.
Under legislation including the EU General Data Protection Regulation and other relevant Swiss legislation relating to the holding and processing of data, the School is identified as the ‘Data Controller’.
What this notice is for
This privacy notice is intended to provide information about how the School will process personal data about individuals including its staff, its prospective, current and past students, their parents, governors, trustees and other clients of the School.
This information is provided in accordance with the rights of individuals under data protection law to understand how their data is used. Staff, parents, students, governors and other clients are all encouraged to read this Privacy Notice and understand the School’s obligations to its entire community.
This privacy notice applies alongside any other information the School may provide about a particular use of personal data, for example when collecting data via an online or paper form. This privacy notice also applies in addition to the School's other relevant terms and conditions and policies, including:
- any contract between the School and its staff, the parents of students and other connected parties;
- the School's policy on taking, storing and using images of children;
- the School’s security camera policy;
- the School’s retention of data policy;
- the School's safeguarding, health and safety policies, including as to how concerns or complaints are recorded; and
- the School's IT policies, including its Acceptable Use and E-safety policies.
Anyone who works for, or acts on behalf of, the School (including staff, volunteers, governors and service providers) should be aware of and comply with this privacy notice.
Responsibility for Data Protection
The School has a Data Protection Coordination Group (DPCG) who deal with requests and enquiries concerning the School’s uses of personal data and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law. They can be contacted from this email address: [email protected]
Why the School Needs to Process Personal Data
In order to carry out its ordinary duties, and as part of its daily operation, the School may process a wide range of personal data about individuals (including current, past and prospective staff, students or parents).
Some of this activity the School will need to carry out in order to fulfil its legal rights, duties or obligations including those under a contract with its staff, or parents of its students. Other uses of personal data will be made in accordance with the School’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
The School expects that the following uses may fall within that category of its (or its community’s) legitimate interests:
- For the purposes of student admission (and to confirm the identity of prospective students and their parents);
- To provide education services, including musical education, physical training or spiritual development, career services, and extra-curricular activities to students, and monitoring students' progress and educational needs, taking place within term time and in the holidays, including those run by the School’s Enterprise Department;
- Maintaining relationships with alumni and the school community, including direct marketing or fundraising activity;
- For the purposes of donor due diligence, and to confirm the identity of prospective donors and their background;
- For the purposes of due diligence on scholarship and financial aid applications;
- For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as diversity or gender pay gap analysis and taxation records);
- To enable relevant authorities to monitor the School's performance and to intervene or assist with incidents as appropriate;
- To give and receive information and references about past, current and prospective students, including relating to outstanding fees or payment history, to/from any educational institution that the student attended or where it is proposed they attend; and to provide references to potential employers of past students;
- To enable students to take part in national or other assessments, and to publish the results of public examinations or other achievements of students of the School;
- To safeguard students' welfare and provide appropriate pastoral care;
- To monitor (as appropriate) use of the School's IT and communications systems in accordance with the School's IT acceptable use policy;
- To make use of photographic images of students in School publications, on the School website and (where appropriate) on the School's social media channels in accordance with the School's policy on taking, storing and using images of children;
- For security purposes, in accordance with the school’s security camera policy;
- To market and provide the services contracted with other clients of the School, including (but not limited to) the School’s summer school programmes; and
- Where otherwise reasonably necessary for the School's purposes, including to obtain appropriate professional advice and insurance for the School.
In addition, the School may need to process special category personal data (concerning health, ethnicity, religion, or sexual orientation) or criminal records information (such as when carrying out DBS or other police authority checks) in accordance with rights or duties imposed on it by law, including as regards safeguarding and employment, or from time to time by explicit consent where required. These reasons may include:
- To safeguard students' welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual's medical condition where it is in the individual's interests to do so;
- To provide educational services in the context of any special educational needs of a student, the sharing of assessment data with staff responsible for delivering education to the student;
- In connection with employment of its staff, for example DBS or police authority checks, welfare or pension plans;
- For legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care.
Types of Personal data processed by the School
This will include by way of example:
- names, addresses, telephone numbers, e-mail addresses and other contact details;
- car details (about those who use our car parking facilities);
- bank details and other financial information e.g. about parents who pay fees to the School;
- past, present and prospective students' academic, disciplinary, admissions and attendance records (including information about any special needs), and examination scripts and marks;
- where appropriate, information about individuals' health, and contact details for their next of kin;
- references given or received by the School about students, and information provided by previous educational establishments and/or other professionals or organisations working with students and other clients; and
- images of students (and occasionally other individuals) engaging in School activities, and images captured by the school's security camera system (in accordance with the School's policy on taking, storing and using images of children);
How the School Collects Data
Generally, the School receives personal data from the individual directly (including, in the case of students, from their parents). This may be via a form, or simply in the ordinary course of interaction or communication (such as email or written assessments). In some cases personal data may be supplied by third parties (for example another school, or other professionals or authorities working with that individual); or collected from publicly available resources.
Who has Access to Personal Data and Who the School Shares it with
Occasionally, the school will need to share personal information relating to its community with third parties, such as professional advisers (lawyers and accountants) or relevant authorities (police, commune or canton). For the most part, personal data collected by the School will remain within the School, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of:
- medical records held and accessed only by appropriate medical staff or otherwise in accordance with express consent; and
- pastoral, wellbeing or safeguarding files.
A certain amount of any student’s relevant information will need to be provided to staff more widely in the context of providing the necessary care and education that the student requires. Staff, students, parents and other clients are reminded that the School is under duties imposed by Swiss law and to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This may include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities or police and the School’s insurers.
Finally, in accordance with data protection law, some of the School’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the school’s specific directions.
How Long Will Data be Kept
The School will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep ordinary staff and student personnel files is up to 10 years following departure from the School. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements. If you have any specific queries about how this policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the DPCG at the School’s registered address above. The School may have lawful and necessary reasons to hold on to some data.
Keeping in Touch and Supporting the School
The School will use the contact details of parents, alumni and other members of the School Community (such as former employees and volunteers) to keep them updated about the activities of the School, or alumni and parent events of interest, including by sending updates and newsletters, by email and by post. They will only do this having due regard to the contact preferences set up when the student joined the school and any subsequent updates. Unless the relevant individual objects, the School may also:
- Share personal data about parents and/or alumni, as appropriate, with organisations set up to help establish and maintain relationships with the school community;
- Contact parents and/or alumni by post and email in order to promote and raise funds for the school and, where appropriate, other worthy causes;
- Collect information from publicly available sources about parents' and former students' occupation and activities, in order to maximise the School's fundraising potential.
- Should you wish to limit or object to any such use, or would like further information about them, please contact the Data Protection Lead in writing at the School’s registered address above. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the School may need nonetheless to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
Individuals have various rights under data protection law to access and understand personal data about them held by the School, and in some cases ask for it to be erased or amended or for the School to stop processing it, but subject to certain exemptions and limitations. Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, should put their request in writing to the DPCG at the School’s registered address above.
The School will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits, which is one month in the case of requests for access to information. The School will be better able to respond quickly to smaller, targeted requests for information. If the request is manifestly excessive or similar to previous requests, the School may ask you to reconsider or charge a proportionate fee, but only where data protection law allows it.
You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal professional privilege. The School is also not required to disclose any student examination scripts, nor any confidential reference given by the School for the purposes of the education, training or employment of any individual.
Students can make subject access requests for their own personal data, provided that, in the reasonable opinion of the school, they have sufficient maturity to understand the request they are making (see section Whose Rights below). A student of any age may ask a parent or other representative to make a subject access request on his/her behalf, and moreover (if of sufficient age) their consent or authority may need to be sought by the parent. Students aged 13 are generally assumed to have this level of maturity, although this will depend on both the child and the personal data requested, including any relevant circumstances at home. Children younger than 13 may be sufficiently mature to have a say in this decision. All subject access requests from students will therefore be considered on a case by case basis.
Where the School is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). The School may have another lawful reason to process the personal data in question even without consent.
That reason will usually have been asserted under this Privacy Notice or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services).
The rights under data protection law belong to the individual to whom the data relates. The School will often rely on parental consent to process personal data relating to students (if consent is required) unless, given the nature of the processing in question, and the student's age and understanding, it is more appropriate to rely on the student's consent.
Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents’ rights at law or under their contract, and all the circumstances.
In general, the School will assume that students’ consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the student's activities, progress and behaviour, and in the interests of the student's welfare, unless, in the School's opinion, there is a good reason to do otherwise.
Where a student seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, the School may be under an obligation to maintain confidentiality unless, in the School's opinion, there is a good reason to do otherwise; for example where the School believes disclosure will be in the best interests of the student or other students, or if required by law.
Students are required to respect the personal data and privacy of others, and to comply with the School's relevant policies, e.g. ICT acceptable use policy, E safety policy and the school rules. Staff are under professional duties to do the same covered under the relevant staff policy.
Data Accuracy and Security
The School will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the DPCG of any changes to information held about them.
An individual has the right to request that any inaccurate or out-of-date information about them is erased or corrected. The School will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to School systems. All staff and governors will be made aware of this policy and their duties under data protection law.
Queries and Complaints
Any comments or queries on this policy should be directed to the DPCG at the School’s registered address as noted at the start of this document. If you have any questions about this privacy notice or how the School processes personal data, or if you wish to exercise any of your rights under applicable law please contact the DPCG.