SKV Privacy Notice:
SAMPOORNA KENDRA VIDYALAYA “SKV” of Dibrugarh processes personal data on its prospective, current and former students and their parents or legal representatives, as part of its everyday operations of providing educational services.SKV handles your personal data according to the General Data protection Regulation no. 679/2016 applicable in the European Union (“UDPR”) for these purposes, SKV acts as controller with regard to your personal data and the personal date of students, meaning SKV establishes the purposes and means of processing the personal date.
For the purpose of this privacy Notice, please note that the term “processing” shall represent any operation performed on personal date, whether or not by automated means such as collection, recording, storage, adaption, alteration, consultation, use disclosure by any means, erasure of destruction. SKV 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 the subject matter.
Please take a little of your time to read this privacy note to understand the data processing operations carried out by SKV.
The purposes for which SKV processes your personal data:
- Provision of educational services:- Starting with the admissions process, controlling students, administration of classes and timetable, teaching activities, administration of internal and public examinations, assistance regarding the application process to various educational institutions, issuance of academic records.
- Provision of educational ancillary services: Pastoral care career and personal counseling, library services, extracurricular activities, school trips, managing school’s publications, setting up the virtual learning environment and granting access to SKV’s intranet and internet as well as monitoring the use of SKV’s network.
- Ensuring campus security: Monitoring access on campus, performance of video surveillance
- 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/colleges, archiving, accessing the quality of our services, facilitating research activities.
- School related communications: Conveying various messages related to the students and SKV’s activities by any communication means.
- Organizing fundraising activities and other school events (e.g., Concerts, theatre productions, talent shows), including marketing communications related to the fundraising activities organized by SKV.
- Dispute resolution and litigations.
- The categories of personal data that SKV process, include, but are not limited to the following:
- Identification and contact information ( first and last name, citizenship, country of birth address, information included in ID’s/ passports, phone number, e-mail etc)
- Bank details are retained by the Admin office only for school payments.
- Health data medical history, allergies, immunization records, disorders, medical examination results and other medical data of the students.
- Data record to the educational background and regarding school performance of the students: academic, disciplinary or other educational related records, academic references, special needs, hobbies, results of educational diagnosis testing, test results, feedbacks, evaluations etc;.
- Behavioral data as well as data on performances/interests of students;
- Family information : household information , languages background , profession and workplace of parents etc.
- Authentication and physical access data: e-mail, passwords, badge no, location data, other online identifiers, vehical details etc;
- Photo & Videos
Generally the personal date held by SKV 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.
- The lawful basis for the processing operations we conduct with regard to the personal data:
SKV collects and further process personal data, based on one of following legal grounds, expressly laid down by the GDPR:
prior to any processing of the personal data for:
- The use of student’s photographs and videos in various school publications (including yearbook) on SKV’s website and social media pages:
- The use of your contact details for communications b/w school & family / student, and the CBSE Board.
- Other consents that may be granted for time to time for various processing activities.
Please note that there are some mandatory categories of personal data necessary to SKV in order to process enrolment applications 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. All the categories of data that are compulsory are, marked accordingly in the application form.
Please take into consideration, that all the mandatory categories of data are necessary for SKV 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 SKV to process your application.
- A legal obligation that requires SKV 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 SKV provides educational services, regards as a service of public interest, according to the local applicable provisions on education, many processing operations conducted by SKV 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 student’s performance etc.
SKV 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 students rights and liberties.
SKV may invoke the legitimate interest Legal ground in the following cases:
- monitoring use of the SKV’s virtual learning environment and network, including monitoring the use of e-mails account provided by SKV:
- Conducting fundraising activities, including marketing of such activities:
- Enforcement of legal claims, addressing complaints and third party controls:
- Management, control, reporting and performing statistics on school activity:
- Ensuring security:
- Maintaining close relationships with alumni & SKV’s Community;
- Collaboration with other schools and educational institutions;
- Performance of agreement 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 SKV processes health data based on the following legal grounds:
- The necessity of the school nurse 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 basic of National law:
- Processing is necessary to reasons of substantial public interest on the basis of 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 discloser of the personal data of students related to the allergies they suffer from.
- Disclosure of Personal Data
SKV discloses your personal data only to those members of SKV 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 nurse has access to the student medical records. Other employer of the school have access to specific health data based on the consent you have expressed.
With respect to the disclosure of the personal data to third parties outside SKV, 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 online tools, server hosting suppliers.
• Hostel wardens/school canteen in-charges in its capacity of independent provider of meal services on campus
• Other educational institutions or organizations, not limited to other schools
• Travel agencies, catering and transportation providers
• SKV’s photographer and video crew (web team & media club) courier services providers
• Utilities services providers.
• Public authorities and institutions national or foreign, judicial courts and foreign embassies or other terms of diplomatic missions
• Tax, legal and accounting consultants.
5) Retention and Disposal of Personal Data
SKV holds your personal data for as long as you are enrolled and afterwards for a standard period as specified in our SKV record management plan for which SKV can justify a need in storing such personal data.
SKV keeps the student file and the data related to the student interaction with SKV 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 regards to their school career within SKV, which usually appear after the students have completed XII. The school will follow all local legal requirements for the reflection and disposal of student data.
6) Your rights related to the processing of personal data by SKV
The SKV 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 mention below:
The rights of access, which entails your possibility to obtain the confirmation from SKV whether your personal data is being processed by SKV 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 purpose 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 SKV and requesting confirmation by Email:_______________________ please consider that these 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 SKV rectification of any inaccurate personal data that SKV 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 the cases where the law provides for the possibility of erasure of personal data amount to situation where the processing in unlawful or where the processing is based on your consent and you have withdrawn consent.
• The right to restriction of processing signifying your light to obtain restriction of processing your personal data from SKV part. Please bear in mind that this right can be exercised only in specific situation 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 the performance of the contract you have concluded with SKV.
• The right to object to the processing of your personal data by SKV, on grounds relating to your particular situations. The right to object applies to the situations where SKV relies on consent on 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 SKV 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.
SKV Greater various profiles through automated means had on the personal data that pertain to students. Generally, such profiles. via Various applications used in the on-line education environment Such as the MAP Testing tool.
SKV creates and uses such profiles to evaluate the performance of its students, to identify gaps in their development of to access specific traits that characterize students personality, preferences and behavior of professional inclinations.
8) Video Surveillance
SKV has implemented a video surveillance system in 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.
All the areas covered by a video camera are signalized in campus through banners, informing you with regard to the video. Surveillance conducted by the SKV
9) Contact point
In the situation where you may wish to exercise any of the rights Listed under point 7 of this privacy Notice or to obtain additional information or clarifications on the subject of processing your personal date please contact SKV, via its appointed contact person. Data protection team-responsible for ensuring that SKV complies with all the requirements of the GDPR.
CONTACT DETAILS OF SKV’S DATA PROTECTION TEAM:
WHISTLE BLOWING AT SKV:
SKV offers a whistle blowing channel for anyone to anonymously report malpractice unlawful, unethical behavior within the workplace or any other abuse witnessed.
You can read the full PROCESS OF WHISTLE BLOWING HERE SEND
The present privacy notice shall apply along with other policies/procedures adopted at the level of SKV. For more important please contact our data protection officer Email: _______________
WHISTLEBLOWING AT SKV
What does it mean?
SKV encourages staff and any other party to report to SKV findings of any misconduct. The whistleblowing channel is designed to allow easy opportunity to inform and enable SKV to intervene in harmful occurrences that are happening or about to happen and to protect members of the SKV community. The reports should the made sincerely and with integrity.
“Whistle blowing” means disclosing of information which contains data on breach. of the laws, violation of human rights, execution of public authorizations contrary to the purpose it has been entrusted for jeopardy of life, public health, security, environment, as well as for the purpose of preventing of damage of large proportions. The information may contain data of the whistle blower. The employer and authorities in charge contain are obliged to act upon anonymous notices in regard to the information, within their authorization
“Information on breaches means, information including reasonable suspicious, about actual or potential breaches, which occurred or are very likely to occur in the organization in which the reporting person works or has worked or in another organization with which the reporting person is or was in contact through his or her work, and about attempts to conceal such breaches”
- The announcements go to the data protection officer (DPO) at email id: ______________________
- The DPO must make an initial assessment of the announcement and either accept or reject it. The DPO may reject the report in cases where it is obvious that the report contains false information or is done with malicious intent.
- All accepted reports are discussed in the next strategic team meeting taking into account the following principles:
- members the team are bound to anonymity by law,
- when possible, the case will be handled anonymously even within the team
- A person whom the suspicious concerns or who has an interest in the matter will not participate in investigating a report.
- Strategic Team meeting will decide next steps in handling the case.
- The whistle-blowers has given their own contact information, He/she will given be informed that the announcement is being handled by school strategic leadership. If the next steps in handling the announcement are known within 7 days, the whistle-blower can also be informed about those on a general level.
- Latest, within 3 months from the announcement, the whistle-blower will be informed about action taken by SKV to address the concern (if they have provided their own contact information)
- The announcement and action taken will be carefully documented into SKV file.
Protection of the whistleblower:
The whistleblower is lawfully protected against any retaliation. Retaliation means any direct or indirect act or omission which occurs in a work-related content, which is prompted by internal or external reporting or by public disclosure, and which causes or may cause unjustified detriment to the reporting person.
Reporting person shall qualify for protection provided that they had reasonable ground to believe that the information on breaches reported was true at the time of reporting, and that such information fell within the scope of the directive.
Whistleblowing announcement channel:
The whistleblowing channel below is open an accessible to anyone. If chosen, the information can send the form fully anonymously. The form is coded in such a way that the informant cannot be identified. If the informant wishes to receive feedback on the