Brent International Schools Privacy Statement
(Baguio/Manila/Subic)
Effective Date: Oct 22, 2019
INTRODUCTION
Brent International Schools (Baguio/Manila/Subic) hereinafter referred to as “Brent School” , offers a number of services to provide timely information to students and parents via traditional and online services. Brent School values the privacy of its students, parents and employees and is committed to protect the personal data that they have shared with the school. In this regard, it is the policy of Brent to uphold data privacy rights, and ensure that all data collected from students, their parents or guardians, employees and other third parties, are processed pursuant to the general principles of transparency, legitimate purpose and proportionality as espoused by Republic Act No. 10173 , otherwise known as the “Data Privacy Act of 2012”, its Implementing Rules and Regulations, and other relevant policies and issuances of the National Privacy Commission.
DEFINITION OF TERMS
Personal Data : All types of Personal Information;
Data Subject : An individual whose Personal Data is collected and processed;
Personal Information : Any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual;
Sensitive Personal Information : Personal information including, but not limited to, an individual’s race, ethnic origin, marital status, age, color, religious philosophy, political affiliation, health, education, financial information and other government identification numbers;
Process, Processed or Processing : Any operation or any set of operations performed upon Personal Data including, but not limited to, the collection, recording, organization, storage, updating, modification, retrieval, consultation, use, consolidation, blocking, erasure, or
destruction of data.
RIGHTS OF DATA SUBJECT
Brent School is committed to protect the privacy rights of individuals on personal information pursuant to the provisions of the Data Privacy Act of 2012, its Implementing Rules and Regulations and other relevant issuances.
The data subject shall have the right, where personal information is processed by electronic means and in a structured and commonly used format, to obtain from the personal information controller a copy of data undergoing processing in an electronic or structured format, which is commonly used and allows for further use by the data subject. The National Privacy Commission may specify the electronic format referred to above, as well as the technical standards, modalities and procedures for their transfer. The lawful heirs and assigns of the data subject may invoke the rights of the data subject for which he or she is an assignee.
Personal information that are excluded from the scope of the Data Privacy Act include those which are (1) processed or used only for the needs of scientific and statistical research and on the basis of which no activities are carried out or no decisions are taken regarding the data subject; (2) those which are gathered or processed for the purpose of investigations in relation to any criminal, administrative or tax liabilities of a data subject.
All employees, students and administration officers are enjoined to comply with and to share in the responsibility to secure and protect personal information collected and processed by Brent in pursuit of legitimate purposes.
WHAT PERSONAL DATA WE COLLECT
Brent School collects the Personal Data of its students and family members, faculty and staff, including, but not limited to, personal information, health and other sensitive personal information, basic contact details, assessment/ examination results, attendance, behavior, ethnicity, special education needs, relevant medical information, government required document information, photographs, video footage and/or digital material.
HOW WE COLLECT PERSONAL DATA
Brent School collects data in the following manner:
- Through personal interaction with students and their family, employees and job applicants.
- From paper and electronic documents including but not limited to enrollment forms, emails, invoices, letters to the school, consent forms (e.g. field trips, medical form), job applications, the school websites (www.brent.edu.ph, www.brentbaguio.edu.ph, www.brentsubic.edu.ph) and school sanctioned social media sites (e.g. Facebook, Twitter, Instagram).
- Through school-based software applications (e.g. BASIS, Google Classroom, Destiny)
- Student Services forms and documents.
- CCTV camera footage located on school premises.
HOW DOES BRENT USE PERSONAL DATA
To the maximum extent allowed by law, Brent School may use personal data of its students, faculty and employees to pursue its objectives. In particular, the personal data collected by Brent School shall be used, among others, to:
- Support the education of the students, including to monitor and report on their progress;
- Provide appropriate personal and social care to students;
- Assess its performance as a school, together with any other uses normally associated with this provision in an independent school environment; and
- For employment purposes such as but not limited to, determining eligibility for employment, administering compensation, professional development, performance evaluation, compliance for government related requirements, insurance claims, compiling directories, and other purposes reasonably required by the school.
HOW TO ACCESS AND CORRECT PERSONAL DATA
A student information sheet is sent to parents for verification and correction at the start of each school year. If Personal Information needs to be accessed by the owner for review, verification or correction at a different time, you may send a request through the following contact information which may be subject to further verification:
For Students and Parents
Baguio : registrar@brentbaguio.edu.ph
Manila : registrar@brent.edu.ph, upperschool@brent.edu.ph, middleschool@brent.edu.ph, loweschool@brent.edu.ph
Subic : registrar@brentsubic.edu.ph
For Employees
Baguio : humanresources@brentbaguio.edu.ph
Manila : humanresources@brent.edu.ph
Subic : biss.info@brentsubic.edu.ph
Requests for access to and / or correction of personal data may be subject to further verification by Brent School to ensure the authenticity of the same.
THIRD PARTIES, DISCLOSURE
Brent School will maintain the confidentiality and secrecy of all personal information that the school holds. Personal data, however may/will be disclosed by the school to its third party service providers, whether local or foreign, pursuant to a lawful purpose, such as, but not limited to: (1) the provision of transport, medical, catering, travel, and online services; (2) fundraising, marketing, or promotional activities; and (3) provision of character references, educational history, and alumni services.
Personal information may likewise be disclosed to government agencies to satisfy reportorial requirements in line with their constitutionally or legislatively-mandated functions pursuant to existing education or labor laws applicable to Brent students or employees, or to a lawful order of a court or tribunal.
DATA SECURITY AND STORAGE
To ensure that the rights of the data subjects are protected, (1) data subjects are notified and collection of their information is done with their consent, which consent is included in the forms filled-out during application for admission, enrollment, availment of student services such as scholarships, access of school website, on the job trainings, application for employment, etc.; (2) only authorized personnel are allowed to access and process the personal information collected; and (3) only personal information which is reasonably or directly related to the School’s primary or secondary functions or activities shall be collected.
The security of your data is important to Brent School, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While Brent School strives to use acceptable security measures as a means to protect your Personal Data, the school cannot guarantee its absolute security.
Brent School has implemented various data protection measures to guard against unauthorized access and unnecessary retention of personal data in its system. For example, Only authorized personnel have access to student or employee records, security appliances and devices such as CCTVs. Storage facilities where hard copies of the personal information are contained are also in a secured area. Secure Socket Layer (SSL) protocol is also used, which is an industry standard security technology for establishing an encrypted link between a web server and a browser. This link ensures that all data passed between the web server and browsers remain private and integral. In addition, to better protect Personal Data, some areas of Brent’s system are only accessible when you supply individually identifiable and verifiable information using a username and password.
Your password protects your user account, so Brent School encourages you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Brent School services.
RETENTION OF PERSONAL DATA
Brent School, in keeping with good practice of maintaining detailed and complete records, may choose to keep your personal data as long as necessary to the extent required by law, for the fulfillment of its legitimate purposes, for archival of records or general reference. In some cases, it may be used for legal purposes, such as for the establishment, exercise or defense of legal claims. When retention is no longer necessary for purposes of which it was collected, reasonable steps will be taken to de-identify or delete the personal data in a secure manner.
NOTICE OF CHANGES TO THIS PRIVACY POLICY
Brent School may update its Privacy Policy from time to time. It will notify you of any changes by posting the new Privacy Policy on its website and update the effective date t the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on Brent School’s website.
TRACKING COOKIES DATA
Brent School uses cookies and similar tracking technologies to track the activity on its Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze the school’s Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the school’s Service.
LINKS TO OTHER SITES
Brent School’s online services may contain links to other sites that are not operated by it. If you click on a third party link, you will be directed to that third party’s site. Brent School strongly advises you to review the Privacy Policy of every site you visit. The school has no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
CONTACT BRENT
If you have any questions about this Privacy Policy, please contact the respective Data Protection Officers:
Baguio
Kurt Salvador
kurt.salvador@brentbaguio.edu.ph
Manila
Roehl Castaneda
rcastaneda@brent.edu.ph
Subic
Alvin Enguillo
aenguillo@brent.edu.ph