Colegio Europeo de Madrid's Privacy & Cookie Policies
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Colegio Europeo de Madrid PRIVACY NOTICE FOR PUPILS
INTRODUCTION
What is this notice? As a school, Jorge Calvo DPO@cognita.com (hereinafter, the "School"), acting as data controller, is required by data protection law to look after and protect information that we hold about you. This privacy notice sets out the details regarding the School's uses of the personal data we collect from you, or that you give to us. What is personal information? Personal information is any information which is about you and is capable of identifying you. Examples of this would be your name, where you live and your age.
CONTACT US IF YOU HAVE FURTHER QUESTIONS.
Please make sure you read this privacy notice carefully and If you have any questions about it then please speak to your teacher who will make sure that your question or query is handled by the right person.
The School has a Data Protection Co-ordinator who can explain in more detail how your information is handled and looked after by the School. The School's Data Protection Co-ordinator is Jorge Calvo.
We have a Data Protection Officer whose contact details are as follows: Group Legal Director (DPO@cognita.com).
WHAT PERSONAL INFORMATION MIGHT THE SCHOOL HOLD ABOUT YOU?
Your full name
Your date of birth and grade
Your home address and home telephone number
Your School email address
Your personal email address
Your mobile number
Your photograph
Your medical records (including allergies and special education needs and/or accidents) (see "Sensitive Personal Data")
Your parents' or guardians' details
Your academic records and test results
INFORMATION WE RECEIVE FROM OTHER PEOPLE OR COMPANIES
We shall collect personal information from your parents or guardians. Likewise, we might work closely with other institutions such as your previous school, School nurses or doctors, School photographers, the local council, social services, education authorities and the School's lawyers. We might receive information about you from them. We may also collect information about where you are when using our bus services and how you use our School-issued devices. We may also use CCTV footage to ensure the School is safe.
HOW THE SCHOOL USES YOUR INFORMATION
The School shall do the following things with your information (these are called "purposes of processing"):Subject to our legitimate interest in promoting the objects and interests of our School and ensuring the most efficient management of our School, and for those purposes.
We will also use your image collected through CCTV systems as per our legitimate interest in safeguarding the security of the School.
Under the basis of our legitimate interest in the adequate management and administration of the contract we as a School hold with your parents/guardians, we will also use the information your parents or guardians give us as is necessary to carry out our obligations arising from the contract between the School and your parents/guardians and to provide you and them with the information and services that your parents/guardians request from us (to manage any queries or disputes you may have with us or that we have with you, look after you, teach you). Subject to this same legitimate interest, we shall use your personal information for the purpose of correctly identifying you as a School pupil, as part of a manual ID system.
Also, we are required by law to take a register, keep a personal file about you, keep a record of your behaviour and provide a written report on your progress which will include personal information about you.
SENSITIVE PERSONAL DATA
When we hold details about your medical condition or health, this type of information is called "sensitive personal data" which means the School must adopt higher standards of care to make sure this kind of data is safe and doesn't fall into the wrong hands. It also means that we may need to ask for yours and your parent/guardian's explicit consent to collect and process that data when we ask for it. We will need to hold sensitive personal data about you to protect your vital interests. In order to achieve this, the School may also use software applications and other technology.
INFORMATION WE GIVE TO OTHER PEOPLE OR COMPANIES
We will share information with your parents or guardians to carry out our obligations arising from the contract between the School and your parents.
In order to pursue the abovementioned purposes of processing, the School will rely on software applications and other technology to handle your information. These include virtual learning environments (including the setting of tasks and homework), revision tools, parents evening booking systems, text and email messaging communications, assessments of your progress and co-ordination of School trips. The companies we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your information is kept secure. Some of our key systems include ESS (SIMS), iSams, Evolve, BatonRoute, Medical Tracker, CPoms, NetSuite, Microsoft Dynamics, Forsta and Lightspeed. For further information on the kind of technology we use, please speak to your teacher who will liaise with the School's Data Protection Co-ordinator.
Likewise, we may share your personal information with: local authorities, education authorities (for example, the Independent Schools Inspectorate), the Department for Education, educational visit providers, SEN co-ordinators, social services or the police where we have reason to believe there are concerns with your safety, and/or with Cognita Regional Office (School Community Partners) in Spain, a member of the Cognita group of companies (your School belongs to the Cognita group),.Kindly note that, "group of companies" shall be understood as the definition of Group of Companies set forth in article 42 of the Spanish Code of Commerce. For further information about which companies are part of Cognita group, you can visit the website www.cognita.com as they are listed therein.
We may also share your personal information with exam boards in order to successfully administer exams.
If you are British, or national of any other country out of the Schengen area, we may have to provide information about you to the Spanish Immigration authorities.
We may also need to share your information with our head office in Spain and in the UK, professional advisors and suppliers.
WHERE WE NEED YOUR CONSENT
We will seek yours or your parent/guardian's permission if we decide to post any photographs of you on any of our marketing materials (including our prospectus or website). If you are under the age of 14, we need your parent's permission. If you are over the age of 14, then we reserve the right to seek consent exclusively from you (and not your parent's consent). Where you or your parent/guardian have given permission, you or your parent/guardian, as appropriate, can withdraw this permission at any time.
TRANSMISION OF PERSONAL INFORMATION OUTSIDE THE COUNTRY
Sometimes your information will need to be transferred to, and stored at, a destination outside the EEA. We try to limit this where possible but it may be necessary where, for example, one of our suppliers has a data storage centre outside Europe. We will take all steps reasonably and legally necessary to ensure that your information is treated securely, in accordance with this privacy notice and in compliance with data protection laws. For further information on the transfers of data to third-countries carried out by the School, please speak to your teacher who will liaise with the School's Data Protection Co-ordinator.
YOUR RIGHTS
Under data protection law, you have the following the rights:
Request access to your personal information (commonly known as a "subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
Object to processing of your personal information.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another organisation (e.g. another school) (portability right).
Withdraw the consent given at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Request a copy of or access to the safeguards under which your data is transferred outside of the EEA (if it is transferred outside the EEA).
Right to complain to the competent authority (AEPD) about any complaints or queries you may have, although please contact us first.
If you wish to exercise your data protection rights, please contact the Data Protection Coordinator
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We will not keep any personal information about you for any longer than is necessary for the purposes for which the personal data are used.
As a general rule, we keep your pupil record file for 6 years after you leave the School. This storage period may be exceeded if it is necessary to comply with legal obligations or to establish, exercise, or defend legal claims. Once the aforementioned relevant period has elapsed, the file will be duly blocked and later on destroyed, in compliance with applicable legal obligations.
We follow a data retention policy which determines how long we keep specific types of personal information for. For further information, please speak to your teacher who will liaise with the School's Data Protection Co-ordinator where necessary.
CHANGES TO THIS PRIVACY Notice
We might decide to make changes to this privacy notice and we will let you know about those changes when they are made.
Colegio Europeo de Madrid PRIVACY NOTICE FOR PARENTS
1 INTRODUCTION
1.1 We are committed to protecting and respecting yours and your child’s privacy. In this privacy notice, references to “we”, “us” or “our” is a reference to Jorge Calvo, acting as data controller, and the school which your child is attending, may be attending or has attended.
1.2 This privacy notice sets out the details regarding our uses, as data controller, of the personal data we collect from you as a parent or guardian (hereinafter indistinctively referred as "parents") or your child, or that provided to us and handled by us. We also have a privacy policy for our pupils, whose most updated version is available on our website.
1.3 Please read the following carefully to understand our views and practices regarding your and your child's personal data and how we will treat it.
1.4 For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and the Ley Orgánica 3/2018, de Protección de Datos Personales y Garantía de los Derechos Digitales, we are the data controller and our address is DPO@cognita.com.
2 INFORMATION WE COLLECT ABOUT YOU AND YOUR CHILD
Information you give us
2.1 You may give us personal data about you or your child, in a number of ways; these include:
2.1.1 using, visiting or interacting with our website (such as filling out forms or registering on our website);
2.1.2 visiting our school;
2.1.3 corresponding with us by phone, e-mail or post; and
2.1.4 sending information directly to us, for example when paying our fees, giving us medical records or information about your child's health, completing school admission forms, signing our parent contract or providing information as requested by us and/or which is necessary from time to time.
2.2 The information you give us may include the following information about you and your child:
2.2.1 full name of all the parents and the child/children;
2.2.2 date of birth and year group of the child/children;
2.2.3 parents' and children's contact details (including home address, e-mail address, and mobile, home and/or work phone number);
2.2.4 parent login information (i.e. username and password) for the website;
2.2.5 IP address, when using our website and providing your prior consent for the use of cookies and/or similar technologies;
2.2.6 parents' financial and credit card information;
2.2.7 photograph of the child/children;
2.2.8 passport and/or ID details, nationality and other information relating to immigration status of the parents and the child/children;
2.2.9 education and health records (including special education needs, medical or physical conditions and/or accidents) of the child/children;
2.2.10 previous educational records and achievements of the child/children;
2.2.11 (where appropriate) family circumstances (including your relation to the child and your marital status);
Information we receive from other sources
2.3 We may be working closely with third parties (including, for example, your child's previous or new school(s), medical practitioners, photographers, local authorities, education authorities, examination boards, payment and delivery services, debt collectors, lawyers and credit reference agencies) and may receive information about you from them.
2.4 We may also use a third party to collect:
2.4.1 location data to track, for example, your child on our bus services; and
2.4.2 information relating to monitoring, for example, your child's usage of our school-issued devices.
2.5 We may also use CCTV footage to ensure the school is safe. We may receive information about you if you use any of the other websites we operate or the other services we provide.
3 CONTACT US
3.1 Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at DPO@Cognita.com or Plaza Doctor Letamendi 1-2, 4th Floor, 08007, Barcelona, Spain.
3.2 We have also appointed within each school a Data Protection Co-ordinator. Please contact the school for further details about the Data Protection Co-ordinator overseeing data protection matters at your child's school.
4 USES MADE OF THE INFORMATION
Information you give to us
4.1 We will use the information you give to us to pursue the following purposes of processing:
4.1.1 Subject to our legitimate interest in promoting the objects and interest of our schools, and ensuring the most efficient management of the schools, and for those purposes;
4.1.2 to store this information on the school's chosen management information system under the basis of the correct performance of the contract we hold with you as the pupil's parent/guardian;
4.1.3 to use your child's personal information as part of a ID system on the school management information system under the basis of the correct performance of the contract we hold with you as the pupil's parent/guardian;
4.1.4 to contract with other companies and organisations under our legitimate interest in preventing fraud and protecting the school from fraudulent actions, and reducing credit risk, and for those purposes;
4.1.5 where your child is attending one of our schools, to provide you with information about other similar services (for example, after school activities or open days) we offer as part of the education and overall development of your child at the school, under the basis of the correct performance of the contract we hold with you as the pupil's parent/guardian (you will be able to opt-out this at any time);
4.1.6 once your child has left the school, to keep you up to date with key school news and upcoming events, subject to your consent (you will be able to opt-out this at any time); and
4.1.7 to send out surveys to you by email as part of our Voice of the Parent campaign which is our school improvement tool, as per our legitimate interest in gaining fundamental knowledge on the school's performance and assessing the level of parents/guardians satisfaction (you will be able to opt-out this at any time).
4.2 We will also use the information you give to us as is necessary to carry out our obligations arising from the contract (or potential contract) between you and us and to provide you with the information and services that you request from us. We will provide education services, which could include the use of technological remote means, to your child and will use personal data where necessary to deliver these services. We will also use your personal information to invoice you for our services pursuant to the contract between you and us. We will also require a certain amount of personal information about you and your child at the pre-contract enquiry and application stage, please see our admissions protocol regarding which information we collect at this stage.
4.3 In addition, we may be required by corresponding applicable law to do the following :
4.3.1 keep an admissions and attendance register;
4.3.2 keep pupil files (including, where relevant, special education needs and child protection files);
4.3.3 keep a record of behaviour sanctions; and
4.3.4 provide an annual written report on pupil progress and attainment.
4.4 Inevitably, there will be an overlap between what we do that is necessary to (a) perform our contract with you, (b) carry out our legal obligations and (c) pursue a legitimate interest although we have tried our best to distinguish these as set out above. If you have any questions about these please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).
Information we collect about you from our website
4.5 We will use this information for the following purposes of processing:
4.5.1 in order to take steps prior to entering into a contract, we will use your personal information to inform you about available places in the future;
4.5.2 under our legitimate interest in the proper management and optimisation of the performance of our website, we will use your personal information to administer our website and for internal operations, including troubleshooting, and as part of our efforts to keep our website safe and secure.
4.5.3 for the correct provision of services requested, we will use your personal information to allow you and your child to participate in interactive features of our service, for example virtual learning environments; and
4.5.4 subject to obtaining your prior consent, we will use your personal information through the use of cookies and/or similar technologies on the website, for data analysis, testing, research, statistical and survey purposes;
4.5.5 subject to obtaining your prior consent, we will use your personal information through the use of cookies and/or similar technologies on the website, to improve our website to ensure that content is presented in the most effective manner, and your online experience is as effective and appropriate as possible, for you and for your computer;
You may learn more about the use of cookies and/or similar technologies on our website through the cookie policy, whose most updated version is available at all times at the following link: cookie policy
Information we receive from other sources
4.6 We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for one of the purposes set out above (depending on the types of information we receive). For example, we may receive a court order relating to you which impacts on our use of your and your child's information to protect the welfare of the child.
4.7 Also, social services or health practitioners may provide us with information (particularly sensitive personal data) about your child which may need to be added to the school's child protection or special educational needs file. This kind of processing of sensitive personal data may be necessary to protect the vital interests of your child or another person taking into account the mental and physical capacity of your child.
4.8 In order to achieve the purposes described in paragraph 4.7, our schools may do the following:
4.8.1 keep a list of your child's allergies or medical requirements within the classroom, dining area and/or staffroom and during educational visits in case of emergency. It is necessary for the school to have a list readily available to our staff so that we are able to look after your child promptly in the event of a medical emergency; and
4.8.2 rely on software applications and other technology to process medical information (such as allergies, accidents and injuries) about your children. For further information on the kind of technology we use, particularly in the context of processing sensitive personal data about your child, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).
When we disclose information
4.9 We may share your and your child's personal information with:
4.9.1 Cognita Regional Office [School community Partners/SCP] in Spain;
4.9.2 a member of the Cognita group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in article 42 of the Spanish Code of Commerce. For further information about which companies are part of Cognita group, you can visit the website www.cognita.com as they are listed therein;
4.9.3 local authorities, education authorities (for example, National Association of British Schools in Spain (NABSS)), COBIS, Ministry of Education (or local equivalents) SEN co-ordinators, social services or the police where we have reason to believe there are safeguarding concerns in respect of your child;
4.9.4 exam boards (for example, Cambridge Assessment and Pearson) in order to successfully administer exams;
4.9.5 where your child is not an EU citizen, we may have to provide information about you or your child to the Spanish immigration authorities;
4.9.6 professional advisors, debt collector, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
4.9.7 credit reference agencies for the purpose of assessing your credit score where this is a condition for us entering into a contract with you.
4.10 We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use the terms of the parents' contract (between us and you) and other agreements. We may also rely on a legitimate interest to share your information with a third party, for example exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4.11 Our schools also rely on software applications and other technology to process personal data about you and your children. These include the school's management information system, virtual learning environments (including the setting of tasks and homework), revision tools, parents evening booking systems, text and email messaging communications, assessments of pupils' progress, school transport tracking systems, our group-wide billing system and co-ordination of school trips. The third parties we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your and your child's personal data is kept secure. Some of our key systems include ESS (SIMS), iSams, Evolve, BatonRoute, Medical Tracker, CPoms, NetSuite, Microsoft Dynamics, Forsta and Lightspeed. For further information on the kind of technology we use, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).
Where we need to get your consent
4.12 We will not market services to you (other than in accordance with paragraph 4.1.5, 4.1.6 and 4.1.7 above) without your consent and you have the right to ask us not to use your contact details for marketing.
4.13 We will seek your express permission to post any photographs of your child on any of our marketing materials (including our prospectus, advertisements or website). Consent is based on the age and degree of maturity of the child:
4.13.1 where a pupil is under the age of 14 or does not have a sufficient degree of maturity, we require consent from all legal guardians to use images of the pupil on marketing materials, social media and/or within the school; and
4.13.2 where a pupil is over the age of 14 and has a sufficient degree of maturity, we reserve the right to seek consent exclusively from the pupil to use images of the pupil on marketing materials, social media and/or within the school.
Where you have given consent to the above, you can withdraw this consent at any time by contacting the Data Protection Coordinator (see paragraph 3).
5 SENSITIVE PERSONAL DATA
5.1 When we hold details about you or your child's medical condition or health, this type of information is called "sensitive personal data" which means the school must adopt higher standards of care to make sure this kind of data is safe and doesn't fall into the wrong hands. It also means that we may need to ask for your explicit consent to collect and process that data when we ask for it. We will need to hold sensitive personal data about you or your child to protect your or your child's vital interests. In particular, these shall include the processing of sensitive personal data (i) for equal opportunities monitoring, (ii) for dietary requirements, (iii) for facilitating religious customs and practices e.g. prayer, dress and holidays / festivals, and/or (iv) for identification purposes. Every time we collect sensitive data from you about you or your child, we will inform you and, where necessary, collect your explicit consent to the processing of that data. In order to achieve this, the school may also use software applications and other technology.
6 TRANSMISSION OF PERSONAL INFORMATION OUTSIDE THE EEA
6.1 The data that we process about you and your child may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). We try to limit this where possible but it may be necessary where, for example, one of our suppliers, has a data centre outside the EEA. We will take all steps reasonably and legally necessary to ensure that yours and your child's data is treated securely, in accordance with this privacy notice and in compliance with data protection laws; and that the appropriate legal safeguards are in place prior to the transfer, for example ensuring that any contracts between us and the recipient of the information have EU-approved standard data protection clauses, or the country we are transferring the data to is deemed by the EU Commission a country with adequate protection. For further information on the transfers of data to third-countries carried out by us, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).
7 YOUR RIGHTS
7.1 Under the GDPR, you and your child have the following rights:
7.1.1 Right to correction. You have the right to have inaccurate personal data about you or your child rectified.
7.1.2 Right to erasure. You have the right to request that we delete yours and your child's personal data where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 7.1.5 for more details); (d) the personal data has been unlawfully processed; and (e) we are required to erase the personal data in order to comply with the law.
7.1.3 Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 7.1.5 for more details).
7.1.4 Right to data portability. In certain circumstances, you have the right to receive personal data from us in a structured, commonly used and machine-readable format and the right to transmit it to a third party organisation.
7.1.5 Right to object. You have the right to raise an objection to any of our processings based on our legitimate interests, including profiling and to decisions which are based solely on automated processing. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.
7.1.6 Right to object to marketing. If you do not want us to process your personal data for direct marketing and particularly you do not want to receive commercial communications trough electronic means, please send us an email to the following e-mail address: DPO@cognita.com and we will ensure that you will not receive any direct marketing communications.
7.1.7 Right to complain to the competent authority. Whilst we would always prefer it if you approached us first about any complaints or queries you may have, you always have the right to lodge a complaint with the AEPD.
7.1.8 Right to request access. You have the right to access personal data we hold about you. We encourage you to contact the school's Data Protection Co-ordinator and request our standard SAR form for you to complete in order to help us process your request.
7.1.9 Right to withdraw the consent given at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
If you wish to exercise your data protection rights, please contact the School's Data Protection Officer, which is Group Legal Director, at the following email address: DPO@cognita.com
8 HOW LONG WE KEEP PERSONAL INFORMATION
8.1 We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data are processed.
8.2 As a general rule, we keep your child's education records during the life of the contractual relationship with us and for 6 years afterwards, with access restricted. This storage period may be exceeded if it is necessary to comply with legal obligations or to establish, exercise, or defend legal claims. Once the aforementioned relevant period has elapsed, the file will be duly blocked and later on destroyed, in compliance with applicable legal obligations..
8.3 We follow a personal data retention policy which determines how long we keep specific types of personal information for. For further information about the criteria we use to determine what periods we keep specific information, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 3).
9 USE OF OUR WEBSITE
9.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict risk-based procedures and security features to try to prevent unauthorised access.
10 CHANGES TO OUR PRIVACY NOTICE
10.1 Any changes we make to this privacy notice in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Colegio Europeo de Madrid COOKIE POLICY
1 WHAT IS A COOKIE?
1.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer's hard drive. To find out more about cookies, visit www.aboutcookies.org.
2 ABOUT OUR USE OF COOKIES
2.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
2.2 When you visit our website, we may automatically collect the following information:
2.2.1 technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
2.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our number.
3 COOKIES WE USE AND WHY
3.1 Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
3.2 Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
3.3 Google Advertising cookies.Google Analytics' Display Advertiser features are enabled for the Google Analytics property this website is tagged with. This means that Google Analytics will drop additional cookies on your browser and collect data using Google's advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation. For more information about Google's Advertising Cookies and how you can control advertising cookies visit Google Advertising Privacy FAQ and Google's advertising cookies.
3.4 Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
3.5 Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising around the web more relevant to you. We may also share this information with third parties for this purpose.
3.6 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
4 WE HAVE NO CONTROL OVER THIRD PARTY COOKIES
4.1 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
4.2 Our website may also contain links to and from the websites of our partner networks, advertisers, suppliers and affiliates. If you follow a link to any of these websites, please note that these websites have their own cookie notices and privacy notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal data to these websites.
5 HOW DO I CHANGE MY COOKIE SETTINGS?
5.1 Generally, browsers allow some control of most cookies through the browser settings. To find information relating to the browser you are using, please visit the browser developer's website, below are links to some of the most common browsers:
6 WHAT HAPPENS IF YOU BLOCK COOKIES?
6.1 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site and your user experience may be seriously downgraded whilst browsing the site.
7 EXPIRY OF COOKIES
7.1 When we send a cookie, we instruct your browser to keep that cookie for a certain period of time, for example, we may instruct your browser to keep the cookie for the period you are on the website; this is known as a “session cookie”. You can override the cookie expiration periods set by us, or any other website, by changing your cookie settings. If you do not change your settings, then, all cookies set by us will expire after 6 months. Default expiration settings will vary for third-party cookies; you can find out more about these by following the links in section 3.5.
8 CONTACT US
8.1 If you have any questions regarding this Cookie Notice please contact servicedesk@cognita.co.uk.
Colegio Europeo de Madrid GENERAL PRIVACY NOTICE
1 INTRODUCTION
1.1 We are committed to protecting and respecting your privacy. Cognita is a group of independent schools. In this privacy notice, references to "we", "us", "our", or "Cognita" is a reference to Colegio Europeo de Madrid, acting as data controller.
1.2 This privacy notice deals with any personal data we process which is not covered in our parent and pupil privacy notices or our employee notice. It sets out the sets out the details regarding our uses, as data controller, of the personal data we collect from you. For example, this notice applies to you if you are a, potential recruit, next of kin, supplier, or potential supplier, alumni, or prospective pupil or parent of a prospective pupil.
1.3 For prospective parents and pupils, please also see our Parent/Guardian and Pupil Privacy Notices. For candidates, please also see our Privacy Notice for Employees, Contractors, Candidates and Interns These are also available on our website here.
1.4 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.5 For the purposes of the General Data Protection Regulation 2016/679 ("GDPR") and the Ley Orgánica 3/2018, de Protección de Datos Personales y Garantía de los Derechos Digitales, we are the data controller and our address is DPO@cognita.com.
2 INFORMATION WE COLLECT ABOUT YOU
Information you give us
2.1 You may give us personal data about you, in a number of ways; these include:
2.1.1 using, visiting or interacting with our website (such as filling out forms or registering on our website);
2.1.2 visiting our offices or schools;
2.1.3 during an interview or meeting;
2.1.4 corresponding with us by phone, e-mail or post; and
2.1.5 sending information directly to us, or providing information as requested by us and/or which is necessary from time to time (for example providing your job application form, CV or business card).
2.2 The information you give us may include the following information about you:
2.2.1 full name;
2.2.2 photograph (for which, where appropriate, we will obtain your specific consent to use, when this is collected);
2.2.3 employment history;
2.2.4 contact details (including home address, e-mail address, and mobile, home and/or work phone number);
2.2.5 financial information (for example payee details);
2.2.6 passport and/or ID details, nationality and other information relating to immigration status;
2.2.7 previous educational/professional records and achievements;
2.2.8 information received via safeguarding forms when visiting a site;
2.2.9 references (as an applicant or potential supplier);
2.2.10 information about your disability status, to ensure your health and safety at our sites and to assess your fitness to work and to provide appropriate adjustments;
Information we receive from other sources
2.3 We may be working closely with third parties (including, for example, recruitment agents, previous employers, medical practitioners, education authorities, government bodies, regulators, suppliers, payment and delivery services) and may receive information about you from them.
2.4 We may also use CCTV footage to ensure our sites are safe. We may receive information about you if you use any of the other websites we operate or the other services we provide, please see our Cookie Notices for further information.
3 CONTACT US
3.1 Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at DPO@Cognita.com or Data Protection Officer, 4th Floor, Plaza Doctor Letamendi, 1-2, 08007, Barcelona, Spain.
4 USES MADE OF THE INFORMATION
Information you give to us
4.1 We will use the information you give to us to pursue the following purposes of processing (as applicable to our relationship with you):
4.1.1 Subject to our legitimate interest in promoting the objects and interest of our schools, and ensuring the most efficient management of the schools, and for these purposes;
4.1.2 to ensure that the schools' legal obligations are adhered to, as necessary for compliance with a legal obligation applicable to us;
4.1.3 to store this information on our management information system/s under the basis of the correct performance of the (potential) relationship we may hold with you;
4.1.4 to enforce our terms of use with you or any other contract we may have with you under the basis of the correct performance of the relationship we hold with you;
4.1.5 for the purposes of recruitment, as necessary for the performance of the relevant contract or in order to take steps prior to entering into said contract;
4.1.6 to enable us to receive your services under the basis of the correct performance of the contractual relationship we hold with you; and
4.1.7 where you have attended one of our schools, to keep you up to date with key school news and upcoming events, subject to the obtention of your prior consent.
4.2 In addition, we may be required by law to do the following, which shall involve the processing of your personal information (and is not an exhaustive list):
4.2.1 keep an accounting record of payment; and
4.2.2 keep a record to evidence fair recruitment processes.
4.3 Inevitably, there will be an overlap between what we do that is necessary to (a) perform our contract with you, (b) carry out our legal obligations and (c) pursue a legitimate interest although we have tried our best to distinguish these as set out above. If you have any questions about these please contact our Data Protection Officer (see paragraph 3).
Information we receive from other sources
4.4 We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for one of the purposes set out above (depending on the types of information we receive). For example, we may receive a reference from a previous employer relating to you, which may impact a recruitment decision.
When we disclose information
4.5 In order to pursue one of the purposes of processing set out in 4.1, 4.2, 4.3, and/or 4.4 above, we may share your personal information with:
4.5.1 Cognita Regional Office in Spain;
4.5.2 a member of the Cognita group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in article 42 of the Spanish Code of Commerce. For further information about which companies are part of Cognita group, you can visit the website www.cognita.com as they are listed therein;
4.5.3 local authorities, education authorities (for example, National Association of British Schools in Spain (NABSS)), COBIS, Ministry of Education (or local equivalents), SEN co-ordinators, social services or the police where we have reason to believe there are safeguarding concerns in respect of a child;
4.5.4 professional advisors, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
4.6 We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce our contract (between us and you) and other agreements.
4.7 We also rely on software applications and other technology to process personal data about you. These include the school's management information system and our HR and finance systems. The third parties we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your information is kept secure. Some of our key systems include ESS (SIMS), iSams, Evolve, BatonRoute, Medical Tracker, CPoms, NetSuite, Microsoft Dynamics, Forsta and Lightspeed. For further information on the kind of technology we use, please contact our Data Protection Officer (see paragraph 3).
Where we need to get your consent
4.8 We will not market services to you (other than in accordance with paragraph 4.1.7 above) without your consent and you have the right to ask us not to use your contact details for marketing. Please contact DPO@Cognita.com if you no longer wish to be contacted by us.
5 TRANSMISSION OF PERSONAL INFORMATION OUTSIDE THE EEA
5.1 The data that we process about you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). We try to limit this where possible but it may be necessary where, for example, one of our suppliers has a data centre outside the EEA. We will take all steps reasonably and legally necessary to ensure that your data is treated securely, in accordance with this privacy notice and in compliance with data protection laws; and that the appropriate legal safeguards are in place prior to the transfer, for example ensuring that any contracts between us and the recipient of the information have EU-approved standard data protection clauses, or the country we are transferring the data to is deemed by the EU Commission as a country with adequate protection. For further information on the transfers of data to third-countries carried out by us, please contact our Data Protection Officer (see paragraph 3).
6 YOUR RIGHTS
6.1 Under the GDPR, you have the following rights:
6.1.1 Right to correction. You have the right to have inaccurate personal data about you rectified.
6.1.2 The right to be forgotten / right of erasure. You have the right to request that we delete your personal data where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 6.1.5 for more details); (d) the personal data has been unlawfully processed; and (e) we are required to erase the personal data in order to comply with the law.
6.1.3 Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 6.1.5 for more details).
6.1.4 Right to request transfer. In certain circumstances, you have the right to receive personal data from us in a structured, commonly used and machine-readable format and the right to transmit it to a third-party organisation.
6.1.5 Right to object. You have the right to raise an objection to any of our processings based on our legitimate interests. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.
6.1.6 Right to object to marketing. If you do not want us to process your personal data for direct marketing and particularly you do not want to receive commercial communications trough electronic means, please send us an email to the following e-mail address: DPO@cognita.com and we will ensure that you will not receive any direct marketing communications.
6.1.7 Right to complain to the AEPD. Whilst we would always prefer it if you approached us first about any complaints or queries you may have, you always have the right to lodge a complaint with the AEPD.
6.1.8 Right to request access. You have the right to access personal data we hold about you. Please contact our Data Protection Officer if you wish to do so at DPO@Cognita.com.
6.1.9 Right to withdraw the consent given at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
If you wish to exercise your data protection rights, please contact the School's Data Protection Officer, which is Group Legal Director, at the following email address: DPO@cognita.com
7 HOW LONG WE KEEP PERSONAL INFORMATION
7.1 We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data are processed. This storage period may be exceeded if it is necessary to comply with legal obligations or to establish, exercise, or defend legal claims. Once the aforementioned relevant period has elapsed, the file will be duly blocked and later on destroyed, in compliance with applicable legal obligations.
7.2 We follow a personal data retention policy which determines how long we keep specific types of personal information for. For further information about the criteria we use to determine what periods we keep specific information, please contact our Data Protection Officer (see paragraph 3).
8 USE OF OUR WEBSITE
8.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
9 CHANGES TO OUR PRIVACY NOTICE
9.1 Any changes we make to this privacy notice in the future will be posted on our website and, where possible and appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
These notices were last updated October 2024.
