WINSTON PREP – GENERAL PRIVACY NOTICE

WINSTON PREP – GENERAL PRIVACY NOTICE

Last Updated: 25 January 2019
  1. Introduction

    Purpose of this privacy notice

    This privacy notice describes how The Winston Preparatory School (“WPS”) collects and uses personal information. This privacy notice is not intended to override any other privacy notice we may provide you in specific circumstances.

    If you have any questions about this privacy notice or how we treat your personal information, please contact us using one of the following methods:
      Ms. Elizabeth Mendelsohn
      Email: emendelsohn@winstonprep.edu
      Address: The Winston Preparatory School
      50 Broad Street, Suite 402, New York, NY 10004
      Attention: Elizabeth Mendelsohn, Chief Operating Officer

    Changes to this privacy notice

    We may change this privacy notice from time to time. When the changes to the privacy policy affect you materially, we will update you by posting it on our website or drawing it to your attention directly using the last known contact details we retain for you.

  2. What personal information do we collect about you?

  3. In addition to the personal information you provide directly to us about yourself or your child, which may include financial and income tax data, we also collect the following personal information about you and your child:

    Students
    • Information provided to WPS by third party health providers, psychologists, social workers and others, with your permission.
    • Student records and personal data WPS receives directly from schools students previously attended.
    • Student personal information obtained through WPS’s admissions, placement and testing procedures.
    Employees, Contractors and Volunteers
    • Criminal and/or child abuse background check records of those having contact with students.
    • Information from recruitment agencies you applied to work with us through, from which we may receive information about you including your resume/curriculum vitae, current and past employment and other qualifications.
    • Information your named referees and former employer, from whom we collect information about your previous employment and suitability for the role you applied for with us.
    WPS Business Counterparty Representatives
    • Your name, professional title and contact details from the organization you represent.
    Website Visitors
    • When you navigate to our website, we may collect personal information about you and how you interact with our site. This includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform on the devices you use to access this website. We gather this information using cookies and other online tracking technologies.
  4. How do we use your personal information?

  5. We use your personal data for the following purposes:

    Students
    • As necessary for the performance of our contracted education services.
    • As necessary to comply with our legal obligations, including student safeguarding and diversity monitoring.
    • As necessary for our legitimate interests in protecting WPS against fraud, other unlawful acts or misconduct and safeguarding others by monitoring your activities on our IT systems.
    • As analytic data in a deidentified format, for the purpose of academic study and research purposes and as necessary to pursue our legitimate interest in enhancing the WPS education model.
    Current and Former Student Parents and Legal Guardians
    • As necessary for the performance of our contracted education services for your child.
    • As necessary to comply with our legal obligations, including student safeguarding and diversity monitoring.
    • To run competitions, raffles and other fundraising events or communications where you have provided your consent and/or otherwise chosen to participate.
    • As necessary to assess applications for financial aid submitted by parents or legal guardians.
    • To study as necessary for our legitimate interest in enhancing our education model.
    Employees, Contractors and Volunteers
    • As necessary to protect our legitimate interests in ensuring that you are suitable for your (proposed) role with us and to meet our legal obligations surrounding child and employee safeguarding.
    • As necessary to meet our legal obligations including diversity monitoring.
    • As necessary for our legitimate interests in protecting us against fraud, other unlawful acts or misconduct and safeguarding others by monitoring your activities on our IT systems.
    WPS Business Counterparty Representatives
    • As necessary to communicate with you in your capacity as a counterparty representative in order to manage and perform our business relationships and promote our legitimate interests in running and growing our business interests.
    Website Visitors
    • As necessary for our legitimate interests of running and safeguarding our business infrastructure, providing administration and IT services, ensuring network security, and preventing fraud.
    • As necessary for our legitimate interests to keep our website and other IT resources secure, functional, updated, and relevant.
  6. How do we share your personal information?

  7. As a general rule, we do not share your personal information with third parties other than to the extent it is necessary for our business operations and provision of our educational services. Accordingly, your personal information may be shared with our service providers including IT hosting companies, payroll providers, auction and promotional assistance companies, and legal and other business advisors, as necessary from time to time.

    We may also disclose your personal information to third parties such as law enforcement agencies if we believe disclosure is necessary to comply with our legal obligations or necessary and appropriate to meet our legitimate interests to prevent harm or loss, or in connection with an investigation of suspected or actual illegal activity, or where necessary to safeguard students’ or others’ vital interests, or when we are required to do so by applicable law.

  8. Transfers to Outside the European Economic Area

  9. Our IT systems are located and maintained in the United States of America. Accordingly, in the event we receive your personal information from outside the United States of America, we will transfer your personal information there for storage and processing in connection with our services. United States data protection laws may be less protective of personal data than those in the European Economic Area. Nevertheless, we take robust steps to safeguard your personal information. You can read more about this in the section below titled “How do we secure your personal information?”

  10. How long do we keep your personal information?

  11. We will only retain personal information for as long as necessary to fulfill the purposes for which we collected it, including meeting any legal, accounting, or reporting requirements to which WSP is subject which might require us to retain it for a longer period. With the exception of student school records that are retained for longer periods in compliance with our state law obligations, in most cases, this will mean that we keep personal information associated with you for 3 years.

    Please contact us using the contact details provided at the start of this policy should you wish to obtain more information about how long we retain specific items of data.

  12. Rights of Individuals in the European Economic Area

  13. In certain circumstances, individuals based in the European Economic Area may have rights in relation to the personal information we hold about them. Depending on the circumstances, these may include the right to:
    • request access to your personal information and obtain a copy of the information we hold about you;
    • correct your personal information that we hold where it is incomplete or inaccurate;
    • have your personal information erased where there is no good reason for us continuing to use or retain it;
    • request that your personal information is used only for restricted purposes;
    • object to your personal information being processed if the lawful basis for processing your personal information is either our or a third party’s legitimate interests;
    • require certain of your personal information to be transferred to you or a third party, and
    • lodge a complaint with the relevant data protection authority in your jurisdiction.

    If you believe you may be entitled to these rights and wish to exercise any of them, please contact us using one of the methods provided in Section 1.

  14. How do we secure your personal information?

  15. We use reasonable technical, administrative and physical security measures to protect your personal information. We of course cannot guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from unauthorized access or use (e.g., by hackers). We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties while or after you transmit your information to us.

  16. Third-party links

  17. This website may include links to third-party websites, plug-ins and applications with their own privacy notices. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we encourage you to read their privacy notices carefully.