PRIVACY NOTICE
Personal Data Collection Statement
We, Collège du Léman Sàrl (“we”, the “School”), Route de Sauverny 74, 1290 Versoix, are the controller of the personal data which we collect and process.
We respect your privacy, and we are committed to full transparency with regard to how we collect, use, and share your personal data.
This privacy notice is addressed to parents or guardians of prospective or current students, prospective students, current students, and alumni, leads, job applicants, as well as website or campus visitors. It informs you of how we process the personal data which we collect from you, which you provide to us, or which we may collect from other sources. This includes the various ways in which you interact with us, including in person, by email or telephone, through our website, or through our pages on social networks.
To exercise your rights in Switzerland or to raise any other question you may have about how we process your personal data, you can contact the Data Protection Referent at Collège du Léman Sàrl at dataprotection@cdl.ch.
Our parent company is Nord Anglia Education Limited, and the Group Data Protection Officer (DPO) is Jon Townsley. If you have any questions about your personal data, you can also contact the Group Data Protection Officer at the below address or by email at compliance@nordanglia.com. Nord Anglia Education Limited, Nova South, 160 Victoria Street, Westminster, London, SW1E 5LB, United Kingdom.
As a data controller, we are providing this privacy notice to:
· list the personal data we collect from you.
· explain why we process (e.g. collect, use, store, share) these data.
· specify the legal bases on which we process these data.
· identify with whom they are shared and where they are transferred.
· lay out the security measures we take with your personal data.
· describe your rights with regard to your personal data and how you can exercise them.
By providing your personal data to us (whether in person, in writing, by phone, or via our website or social media), you acknowledge the processing set out in this privacy notice. Further notices highlighting certain uses we wish to make of your personal data, together with the ability to opt in or out of selected uses, may also be provided to you when we collect personal data from you.
WHAT DATA DO WE COLLECT?
When you interact with us, for example, on our website, through our social media accounts, by email, when you visit our School, or at events, we may collect your personal data.
1. From all data subjects
When you get in touch with us, we collect your name, residential and email address, and telephone number, as well as communications metadata such as your IP address, time signature, and potentially geolocation details as contact information.
2. From parents or guardians of prospective or current students, prospective students, current students, and alumni, leads, as well as website or campus visitors.
If you file an application for enrollment at the School, we will collect demographic information, such as date of birth, age, gender, location, nationality, family information, such as household / family (e.g. parents, siblings), non-sensitive lifestyle information, as well as student application information, such as educational history, languages spoken, extracurricular interests, activities, and preferences, learning support and disciplinary records. We will also collect information pertaining to development of the student body, such as cookies from website visits, date, time, and attendance information for campus visits, social media account data, data collected in relation to virtual campus visits, interests and preferences (e.g. academic programs, camps, or extracurriculars).
From enrollment and through the course of a student’s tenure at the School, we will collect the following categories of information. We will collect personal identification information, such as photographic, facial or unique data, student life information, such as authentication and identification information (computer login, badges), behavioral and disciplinary records, registration for classes and extracurriculars, registration for the academic cursus, grades and assessments, dietary restrictions, room and roommate assignments, attendance, student movement on campus, computer login (including search history) and library records, university application, career advising, summer or other jobs, volunteering, registration for excursions and trips, sports, former school(s), as well as further information pertaining to development of the student body, such as interests and preferences (e.g. academic programs, camps, or extracurriculars).
With regard to a student’s time at the School, we also collect the following information which are sensitive or require additional protection. We collect sensitive information, such as health, medical records, disability access, dietary restrictions or allergies, special needs, psychological evaluation, genetic or biometric data, sexual orientation, and criminal records, as well as financial information, such as information related to payment of tuition, room, and board, information related to the administration of financial aid.
When you enter the premises of the School, we may collect identifying information such as your car license plates, photographic images or video recordings of you, or passport, national ID, or driver’s license information.
When you subscribe to any of our communication or marketing channels, we may collect information concerning your preferences or interests with regard to the nature of your subscription as well as the information which you wish to receive from us.
3. From job applicants
When you send an unsolicited job enquiry or respond to an employment offer, we may collect professional information such as employment history, schools attended, references, or certifications.
We collect this information directly from you. Furthermore, student information can be collected directly, when allowed, and/or indirectly from the student’s parents or guardians, when required (e.g. young children). Please note that the personal data of children are collected only with the parents’ or guardians’ consent. In certain instances, we may also collect personal information directly from previous schools attended about prospective students.
We also use cookies and other tracking technologies (pixels, web beacons, and APIs) that collect certain types of information when you interact with our website or open our emails, such as IP addresses, location, browsing devices or preferences, operating system, source, length of visit, pages viewed, etc. For further information, please consult our cookie policy.
We may also collect personal data from third-party data aggregators (e.g. Google), promotional partners, public sources, and social networking platforms. This information may include personal data from your profile on a social network, which you authorize that network to share with us in accordance with their rules.
WHY DO WE PROCESS YOUR PERSONAL DATA?
First of all, we process your personal data in order to manage student life at the School, from application and enrollment through the course of a student’s tenure at the School (i.e. enrollment, inquiries about academic or extracurricular options, presence (roll call), assignment to classes/sections, assessment and performance, behavioral and disciplinary assessment, access to canteen and dietary restrictions management, learning support, organization and coordination of trips and tours, coordination of events, transportation coordination, extracurricular activity coordination, camps enrollment and coordination, boarding students management, medical appointments and consultations, pick-up and drop-off coordination, health and accident insurance). This also includes managing financial transactions (i.e. payment of tuition and other fees).
Second, we process your personal data for operational purposes. These include the provision of IT services, maintenance of IT infrastructure, management of building access and campus security, management of IT security, maintenance of buildings and facilities (e.g. cleaning services), management of catering and transportation, as well as management of visitors and guests.
Third, we process your personal data to carry out our marketing and communications activities. These activities are: the management of distribution of promotional material, management of leads/prospects, management of website and social media channels, newsletter distribution, alumni activities, and the organization of onsite/virtual visits for leads.
Fourth, we process your personal data to keep records of our activities to comply with financial and/or legal obligations or to aid in dispute resolutions.
Finally, if you are a job applicant we may process your personal data to respond to job enquiries, unsolicited or otherwise.
ON WHAT LEGAL GROUNDS DO WE PROCESS YOUR PERSONAL DATA?
Our processing of your personal data is lawful as long as there are legal grounds for doing so.
There are five main legal grounds on which we collect and process your data:
Processing necessary for the performance of a contract or prior to entering into a contract.
When you start a student relationship with us, say by making an enquiry about our School, filing an application for enrollment, enrolling at the School (whether you enroll directly or you are enrolled by a parent or guardian), etc. we process your contact information on a precontractual or contractual basis. The following kinds of information will also be processed at different stages of the enrollment process on the same contractual basis: personal identification information, demographic information, family information, student application information, student life information, information pertaining to development of the student body.
Further, financial information will be processed on the same contractual basis, from enrollment and through the course of a student’s tenure at the School.
Furthermore, sensitive information about students may also be processed on a contractual basis, from enrollment and through the course of a student’s tenure at the School. When sensitive information is sought from the School and additional consent is required, a further notice will be sent to the student or student’s parent or guardian to ensure that appropriate information on the collection is given and that explicit consent to the collection is obtained by the School.
Finally, if you respond to a job offer or send us an employment application, your professional information will also be processed.
Processing on the basis of your consent
If you choose to subscribe to our communications and marketing materials, such as our newsletter or mailing list, you may have the option to specify your preferences or interests or create a user profile. In this case, we will explicitly ask for your consent to process your personal data. Please note that you may exercise the option to unsubscribe or otherwise withdraw your consent at any time by contacting us at marketing@cdl.ch. For consent matters related to cookies, please see our cookie policy.
Processing necessary for the purposes of our legitimate interests or those of a third party
It is in the legitimate interest of the School, but also of the students, to have some of their personal information processed for operational and security purposes, such as maintaining a sound and safe IT infrastructure, IT security, and campus security. As such, we may process student personal identification information, visitor identifying information, as well as some authentication and identification information (e.g. computer login, badges).
Please note that in this case you have the right to object to the processing by contacting us at dataprotection@cdl.ch.
Processing necessary for compliance with a legal obligation
We as a business have legal obligations under both national and international law. In order to fulfil our obligations, we process your personal data for compliance purposes, record keeping, or fiscal, employment or security reasons.
Processing necessary to protect the vital interests of the data subject or of another natural person.
On an exceptional basis and in very specific circumstances (e.g. accident), we may process a student’s sensitive information in order to protect their vital interests or those of another natural person. This remains an exception.
WITH WHOM DO WE SHARE YOUR PERSONAL DATA AND WHERE ARE THEY TRANSFERRED?
We do not sell your personal data to third parties.
As the Collège du Léman is part of Nord Anglia Education and utilizes the resources of the Group, we may share your personal data within Nord Anglia Group, with Nord Anglia Education Limited in the United Kingdom, as well as with other Nord Anglia Education Schools (see regions here). Please note that all transfers within Nord Anglia Education are regulated by an Intra-Group Transfer Agreement.
In order to provide education services and extra-curricular activities, we may also share your personal information with third party providers and suppliers. These include providers of extra-curricular activities (e.g. camps, expeditions and trips, after-school programs), but also providers of operational services and campus life services, such as catering, transportation services, and program partners.
We may also share your personal data in relation to our education services with other schools, universities or other educational institutions, as well as potential employers.
Finally, we may share your personal data with other providers and suppliers, such as our IT contractors, our marketing and mailing agencies (e.g. advertising agency, development agency, CRM management services, and newsletter publishing and distribution services), our fiduciary, medical and/or health service providers and coordinators, insurance providers, or with federal and/or cantonal authorities, when required.
Apart from within Nord Anglia Group, we endeavor to work with providers located in Switzerland. That being said, we may transfer certain personal data abroad. However, such transfers are limited as much as possible to The European Economic Area (EEA) and the United Kingdom.
Transfers of your personal data to the United States and/or Canada
Some of our software and system providers are also located in the United States and/or Canada or have entities in these territories besides their offices and/or entities in the European Union.
It is therefore important to note that your personal data may be transferred to these territories.
These territories both benefit from partial adequacy decisions from the European Commission, while Canada also benefits from such a decision from the Swiss FDPIC. As of writing this notice, discussions between authorities in Switzerland and the United States are ongoing as to a similar adequacy decision for this territory.
Several of our providers in these territories have implemented various additional safeguards when transferring personal data to the United States and/or Canada, such as DPAs including the EU Standard Contractual Clauses. We also endeavor to review our providers’ compliance with the GDPR and FADP on a regular basis.
If you would like to have more information on the specific safeguards applied by our providers when transferring your personal data to the United States and/or Canada, you can contact us at dataprotection@cdl.ch.
That being said, if you don’t want your personal data to be transferred to these territories, please do not correspond with us or provide us with your personal data.
We may also use plugins on our website linking to social media platforms. The third-party platform's use of information collected from you (or as authorized by you) is governed by its own privacy notice and your settings on the service. If you do not wish a third-party social network site to attribute data collected via our website to your account on that social network, you must log out of the relevant social network site before visiting our website.
WHAT SECURITY MEASURES ARE IN PLACE FOR YOUR PERSONAL DATA?
We take appropriate technical and organizational measures to secure your personal data and to prevent the loss, misuse, or alteration of your personal data.
When the personal data that we process is no longer required for the purpose for which it was collected, or to meet legal obligations, they will be deleted or destroyed securely.
Our website includes links to third party websites. We have no control over and cannot be held liable for the privacy policies and practices of these third parties. You are fully responsible for finding out about the privacy policies and practices of these third parties.
WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
You can exercise your rights at any time by contacting us at dataprotection@cdl.ch.
You have the following rights in relation to your personal data:
· you have the right to be informed about how your personal data are processed and access to your personal data at any time
· you have the right to rectify your personal data or to have your personal data erased under certain conditions
· you have the right to restrict the processing of your personal data under certain conditions and, when based on legitimate interest, you have the right to object to the processing
· when based on consent, you have the right to withdraw your consent at any time
· you have the right to data portability, that is, to receive the personal data in a structured, commonly used format. and to transmit those data to another controller without hindrance from us.
If you are not satisfied with how we process your data, you have the right to make a complaint to a supervisory authority.
You can also limit the use of tracking technologies, such as cookies, by configuring your browser to warn you before accepting them, or you can simply configure it to refuse them.
If you feel that we are not respecting your rights or our obligations, you can lodge a complaint directly with your data supervisory authority at any time.
We reserve the right to make any changes and corrections to this privacy notice. Please refer to this page from time to time to review these and any new information.
Collège du Léman Sàrl, June 2024
