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Personal Data Protection Policy

The International French School (Singapore) firmly undertakes to respect a set of rules of good conduct and of regulations in order to guarantee respect for the confidentiality of all personal data:

Data Eng

Purpose of this policy

The purpose of this document is to inform of the International French School (Singapore) policies on data collection, usage, disclosure, processing and protection, which are subject to the Singapore Personal Data Protection Act 2012 (“PDPA”).

Data Collected

The International French School (Singapore) is collecting the following data

The personal data is entered through forms and through the interactivity established between the user and Parents’ Portal. The International French School (Singapore) also use cookies and/or logs to collect information about Parents’ Portal usage.

Forms and interactivity

Personal data is collected through forms, namely:

  • Application registration form
  • School registration, re-enrolment, deregistration forms
  • Other personalised forms

Log files and cookies

The International French School (Singapore) collects certain information through log files and cookies. This mainly concerns the following information: IP address at registration, pages visited in Parents’ Portal and requests, connection time and day. The use of such files allows the International French School (Singapore) to improve and personalise the service and to establish anonymous statistics.

Purpose of personal data collection

The International French School (Singapore) is collecting personal data for the following purposes (list below not exhaustive).

The collection, use and/or disclosure of the name, date of birth, identification documents, home address, contact details (such as email address and telephone or mobile phone number), medical records and academic history and background of the Student, for the purposes of:

  • Compliance with regulations issued and/or administered by governmental departments and statutory boards such as (without limitation) the Ministry of Education, Immigration & Checkpoints Authority and Agence pour l’Enseignement Français à l’Etranger (“AEFE”);
  • Registering and enrolling the Student with the School, and any subsequent withdrawal from, or cancellation of, the Course (or any part thereof);
  • Preparing and scheduling the Course, and the classes and lessons that form part of the Course;
  • Publishing the results of the Student for any tests, examinations, assessments, reviews and/or papers within the School;
  • The general administration and operation of the School with respect to project management, work-related and teacher-related communication and the preparation and issuing of School reports;
  • Establishing, maintaining, updating and disclosing the educational background of the Student;
  • Communicating with the Legal Guardian(s) via teacher’s emails and through the University Guidance Department, as well as for crisis communication;
  • Planning, organising and implementation of School trips and extra-curricular activities and events, and the registration of the Student for those school trips and extra-curricular activities and events;
  • Ascertaining, monitoring and attending to the medical needs of the Student;
  • Registration of the Student for Transit Link;
  • Obtaining and maintaining viable insurance policy and coverage;
  • Including the Student in IFS’ Alumni services;
  • Evaluation, by requesting schools, with respect to admission suitability;
  • Carrying out the random drug testing policy implemented by IFS (“Drug Policy”);
  • Transferring such personal data to the relevant departments of the French government, as may be required in order to facilitate the creation and allocation of an Identifiant National Elève (“INE”) for the Student; and
  • Such other purposes as may be directly in relation to, or in connection with, the purposes set out in this paragraph.

The collection, use and/or disclosure of pictures and videos containing imagery of the Student and/or the Legal Guardian(s) for the purposes of:

  • Use with School projects, in the School yearbooks, in class pictures and in posters and printed material for display within IFS’ premises;
  • The marketing and promotion of IFS through the inclusion of such personal data:
    • on IFS’ social media platforms, such as IFS’ Facebook, Instagram, Twitter and LinkedIn accounts;
    • On IFS’ website and the website of the AEFE;
    • In printed advertising in magazines, newspapers, brochures, leaflets, posters and printed material;
    • In any form of advertisement (whether digital or printed); and
    • In any online journal or informational website (such as a weblog) relating to IFS and/or any of the classes offered by IFS; and
  • Such other purposes as may be directly in relation to, or in connection with, the purposes set out in this paragraph.
  • IFS undertakes that the collection, use and/or disclosure of pictures and videos containing imagery of the Student and/or the Legal Guardian(s) will not bear invasion of the privacy, dignity, and reputation of the individuals.

The collection, use and/or disclosure of the name, date of birth, identification documents, home address, contact details (such as email address and telephone or mobile phone number) and bank account details of the Legal Guardian(s) for the purposes of:

  • The communication, by teachers, School administration and management and University guidance, with the Legal Guardian(s);
  • Contacting and communicating with the Legal Guardian(s) in the case of an emergency affecting the Student;
  • Contacting and obtaining information on the Student in relation to the planning, organising and implementation of School trips and extra-curricular activities and events, and the registration of the Student for those school trips and extra-curricular activities and events;
  • Providing invitation to, and seeking assistance with, the fund-raising events organised and held by IFS;
  • Issuing invoices for the fees payable by the Legal Guardian(s) in respect of the enrollment of the Student, processing the payment of such fees and maintaining a payment history of all fees paid by the Legal Guardian(s);
  • Transferring such personal data to the relevant departments of the French government, as may be required in order to facilitate the creation and allocation of an Identifiant National Elève (“INE”) for the Student; and
  • Such other purposes as may be directly in relation to, or in connection with, the purposes set out in paragraph 4(C)(i) to (vi) above.

 

Management and Care of Pictures (for Student, Staff and Parents of enrolled Students):

  1. Minimum 2 persons per photo for social media posts, IFS collateral and video content.
  2. If one person is required alone for an image, parent or person (for staff) consent for image usage is required.
  3. Photos must not be associated with alcohol, tobacco, extreme politics, drugs, or any other controversial topics.
  4. Photos must be socially appropriate: no rude gestures, culturally sensitive gestures, appropriately clothed, etc.
  5. Pictures can only be disseminated via official IFS and AEFE media channels, publications and collateral.
  6. From grade/level 6eme no display/publication of students in swimming suites outside of the pool.
  7. Social media guideline: No tagging on images on any IFS social media platform. The school will not authorize any inappropriate comment on social media.
  8. Image lifespan: no more than three years from the date a student leaves the school ‘For website, advertising, publications and IFS collateral. If the student become of legal age in this 3 years period, the school will require the student permission to continue to use his/her image.
  9. IFS does not sell or resell images to third parties.
  10. IFS will always protect identity and integrity for all imagery used on all IFS shared media including social media, video and collateral. 

Consent

Parental Consent 

For the purpose of school students in grades up to and including “Terminale”, parental consent is sufficient. 

The International French School (Singapore) will collect and use personal data in accordance with the Personal Data Protection Act (2012). Consent to the School using such data as set out above can be given in the Student Contract, Legal Authorisation Form and Parents’ Portal.

Management and Care of Personal Data

Protection of Personal Data

The International French School (Singapore) undertakes to:

  • Implement appropriate security measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular when the processing of data involves the transmission or storage on or within a network. The International French School (Singapore) uses the following technical measures:
    • Access to platform via a secure connection (HTTPS) on a DMZ network,
    • Only authorized personnel are able to access the data,
    • Network monitoring, intrusion detection and virus defence software,
    • Encrypted computer backups that can only be restored on the original platform,
    • Connection to Parents’ Portal is protected by a login/password combination,
    • The server hosting the platform is protected by a hardware firewall and a software firewall.
  • Notify data subjects about any accidental or unauthorised access of their data that may lead to damage or harm.

Right of Access, Correction and restriction

Parents have a right to see the personal data (subject to the exemptions listed below) and to request for data to be corrected if it is incorrect. Parents will be provided access to data held about their children whilst they are students at the School within the limitations of this policy.

Thanks to Parents’ Portal, parents have unlimited access to their data. Correction or withdrawal is possible at any time if needed.

The Legal Authorisation Form is submitted to parents on a yearly basis via the Parents’ Portal. It is always possible to change the answers provided to this form.

Exemptions to Right of Access

The International French School (Singapore) retains the right to refuse access to:

  • Opinion data kept for evaluative purposes
  • Examination papers or the results of examinations
  • Confidential references written to support a student’s application to other educational institutions or courses
  • Data or material that would provide personal data about other individuals in contravention of this policy or of the law.

Right to restriction of processing

Under certain circumstances, Parents may obtain from the International French School (Singapore) restriction of processing of the Data. To exercise this right, please contact the International French School (Singapore) Data Protection Officer: [email protected]

Portability

Thanks to Parents’ Portal, Parents can receive the personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

To exercise this right, please log into Parents’ Portal, go to « Account settings » and click on « download my personal data ». The system creates an encrypted compressed file protected with a password.

Data Retention & Removal

The International French School (Singapore) shall take reasonable effort to destroy or anonymise documents containing Personal Data as soon as it is reasonable to assume that:

  • The purpose for which the data was collected is no longer being served by retention of the Data; and
  • Retention is no longer necessary for legal or business purposes.

Right to be forgotten

Parents have the right to obtain erasure of the personal data under certain circumstances. To exercise this right, please contact the International French School (Singapore) Data Protection Officer: [email protected]

Sharing Data with Third Parties

Personal Data may be disclosed by the International French School (Singapore) to its third-party service providers or agents in Singapore (such as travel agents, insurance companies and data hosting companies) for one or more of the Purposes. Personal Data may also be disclosed to some schools outside of Singapore or to the French Ministry of Education, the AEFE or any other institution under its responsibility which may be located outside of Singapore, for one or more of the Purposes.

The International French School (Singapore) will only share data for the purposes of eliciting a necessary service from these third party organisations and not for commercial gain.

The International French School (Singapore) signs contracts to ensure that the organisation is using the data purely for the intended purpose of providing the required service and that it is taking appropriate precautions to safeguard the data. In some instances, for example for online services, explicitly signed contracts do not exist.

In these instances, the School will ensure that the terms & conditions of the service include clauses that:

  • The International French School (Singapore) remains the owner of the data,
  • The service provider is not entitled to use any data held on its service for any purpose other than to provide the required service,
  • The service provider is taking reasonable precautions to ensure the security of the data,
  • Once the School terminates its agreement with the service provider, that any and all data held will be deleted and not used for any other purpose,
  • The service provider is compliant with PDPA.