Cornwall Hill College Digital Privacy Policy

30 June 2021 

We respect your privacy. Callouts like this are summaries of sections of our privacy policy. They contain the most important and relevant points for you. Please read the full privacy policy because it applies to you.

Introduction

Welcome to our privacy policy. We are Cornwall Hill College. We operate as a department of Cornwall Hill College (Registration number 1999/007241/08) and this is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (this is what is known as personal information).

The purpose of this policy is to describe the way that we handle your personal information.

Audience

This policy applies to you if you are:

  • A parent with a child enrolled in our school;
  • a visitor to our website; or
  • a prospective or current customer who has requested the services that we provide, or the opportunity we offer.

Examples of customers (both current and prospective) include (but are not limited to):

  • The parents or guardians of children who are enrolled at Cornwall Hill College.
  • The children of such parents and guardians.

This policy applies to you if you visit our website or make use of our services.

Personal information

Personal information includes:

  • certain information that we collect automatically when you visit our website;
  • certain information collected on registration (see below);
  • certain information collected while you make use of the services that we offer; and
  • optional information that you provide to us voluntarily (see below);

but excludes:

  • information that has been made anonymous so that it does not identify a specific person;
  • permanently de-identified information that does not relate or cannot be traced back to you specifically;
  • non-personal statistical information collected and compiled by us; and
  • information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, or discussion board. (Because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).

Personal information includes information we collect (i) automatically when you visit our website, (ii) on registration, (iii) while you make use of our services, and (iv) from you voluntarily. It excludes (i) anonymous, (ii) de-identified, (iii) non-personal statistical, and (iv) public information.

Common examples

Common examples of the types of personal information which we may collect in the online application  process include your:

  • identifying information – such as your name, date of birth, or identification number of any kind;
  • contact information – such as your phone number or email address;
  • address information – such as your physical or postal address; or
  • demographic information – such as your gender or marital status.

Sensitive personal information

We may also collect sensitive personal information including your:

  • financial information – such as your bank account details;
  • sensitive demographic information – such as your race or ethnicity;
  • medical information – such as information about your physical or mental health;
  • a criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings;
  • employment information – including who your current employer is;

Acceptance

Acceptance required

You must accept all the terms of this policy when you request our services. If you do not agree with anything in this policy, then you may not request our services.

You may not request our services if you do not accept this policy.

Legal capacity

You may not request our services if you are younger than 18 years old or do not have the legal capacity to conclude legally binding contracts. You may, however, access our services even if you are younger than 18 years old.

Deemed acceptance

By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

Your obligations

You may only provide to us your own personal information, the personal information of your child, or the information of another data subject where you have their permission to do so.

Changes

We may change the terms of this policy at any time by updating this document. If you are on our database we will notify you of any changes by sending you an email, highlighting the changes that we have made. If you do not agree with the changes, then you must stop using the website and our services. If you or your child continues to use the website or our services following notification of a change to the terms, the changed terms will apply to you and your child, and you will be deemed to have accepted those updated terms.

Collection

On registration

Once you make an application to the school on our website, you will no longer be anonymous to us. You will provide us with certain personal information when you make an application via our website.

The personal information you provide relates to your child and to the parents or legal guardians of your child, as and where applicable. The personal information will include:

  • given names and surname;
  • email address;
  • telephone/cell phone number;
  • postal address and street address;
  • gender;
  • marital status;
  • relationship to the child;
  • identity number;
  • birth date;
  • country and place of birth;
  • nationality;
  • home language;
  • information about the previous schooling;
  • occupation and employer;
  • financial statements;
  • a photograph of your child;

You will also be asked to upload copies of certain documents that contain personal information, as listed above. Examples of such documents include identity documents, school reports, bank statements, and salary slips.

We will use this personal information to process your application, assess your capacity to afford our fees, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.

We collect certain information when you register via our website.

From browser

We automatically receive and record internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites that you have visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

We collect certain information from your web browser, including your Internet usage information when you visit our website.

Cookies

We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files can serve a number of useful purposes for you, including:

  • tailoring our website’s functionality to you personally by letting us remember your preferences;
  • improving how our website performs;
  • allowing third parties to provide services to our website; and

Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. 

When you first access our website you will be presented with a cookie consent banner that allows you to change the cookie settings for your use of our website. As the default, the only cookies that are enabled are those that are essential for our website to function properly. They do so anonymously. All other cookies are disabled by default. You will be asked to consent to our use of cookies. 

As cookies are files that are kept on your device, you can also delete them manually. However, no longer accepting cookies or deleting them may prevent you from accessing certain aspects of our website where cookies are necessary. Many websites use cookies and you can find out more about them at www.allaboutcookies.org.

We collect certain information from cookies that we may send to your computer to try and give you a personalised experience.

Third-party cookies

Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.

Optional details

You may also provide additional information to us on a voluntary basis (optional information). This includes content that you decide to upload to or download from our website or when you respond to surveys or order certain additional services.

We collect certain optional information, that you provide when you upload or download content to or from our website, or when you respond to surveys or register and subscribe to certain additional services.

Purpose for collection

We may use or process any services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:

  • services purposes – such as processing for and providing our educational services to all pupils;
  • marketing purposes – such as pursuing lawful related marketing activities;
  • business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
  • legal purposes – such as handling claims, complying with regulations, or pursuing good governance.

We may use your usage information for the purposes described above and to:

  • remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
  • monitor website usage metrics such as total number of visitors and pages accessed; and
  • track your entries, submissions, and status concerning any activities in connection with your usage of the website.

We may use any of your personal information that you provide to us for the purposes that you indicated when you agreed to provide it to us.

Consent to collect

We will obtain your consent to collect personal information:

  • in accordance with applicable law;
  • when you provide us with any registration information or optional information.

We will get your consent to collect your personal information in accordance with applicable law when you provide us with it.

Use

Our obligations

We may use your personal information to fulfil our obligations to you.

Messages and updates

We may send administrative messages and email updates to you about the website. We may wish to provide you with information about new services in which we think you may be interested. This means that in some cases, we may also send you primarily promotional messages. We will not send you promotional messages unless you have chosen to opt into them. But, we may send you one message asking you to opt into promotional messages without your having opted into promotional messages.

We may use your information to send you administrative messages and email updates regarding the website, and for marketing purposes where lawful.

Disclosure

Sharing

We may share your personal information with:

  • other divisions of the organisation, to which we belong (e.g. Cornwall Hill College), so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications;
  • an affiliate, in which case we will seek to require the affiliates to honour this privacy policy;
  • our services providers under contract who help provide certain services or help with parts of our business operations, including fraud prevention, bill collection, marketing, and technology services. (Our contracts dictate that these services providers use your information only in connection with the services they supply or services they perform for us, and not for their own benefit);
  • credit bureaus to report account information, as permitted by law; and
  • other third parties who provide us with relevant services where appropriate.

We may share your personal information with third parties for the purposes of fulfilling our obligations to you among other purposes.

Regulators

We may disclose your personal information as required by law or governmental audits.

Law enforcement

We may disclose personal information if required:

  • by a subpoena or court order;
  • to comply with any law;
  • to protect the safety of any individual or the general public; and
  • to prevent violation of our customer relationship terms.

We may disclose personal information to third parties if required for legal reasons.

No selling

We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.

Marketing purposes

Sometimes we will wish to use certain personal information of your child for marketing purposes, for example, to celebrate the Online School’s, or your child’s, achievements and successes. In such a case we will always first secure your consent before using any such personal information for marketing purposes.

Employees

We may need to disclose personal information to our employees that require personal information to do their jobs. These include our responsible management, educators, human resources, accounting, audit, compliance, information technology, or other personnel. In certain situations, volunteer workers, not in our employ but vetted by us, will be entrusted with personal information as required in the performance of specific duties, and subject to their agreeing to our policies on data protection.

Change of ownership

If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.

Security

We take the security of personal information very seriously and will always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. Wherever practical, we allow access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.

Our website is hosted on a secure server and uses security measures to prevent interference by intruders.

Accurate and up to date

We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information held in our database. You are able to update any personal information that we hold on you by emailing us or phoning us. Please note that in order to better protect you and safeguard your personal information, we will take steps to verify your identity before making any corrections to your personal information.

Please keep your personal information accurate and up to date by emailing us or by phoning us.

Retention

We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:

  • retention of the record is required or authorised by law; or
  • you have consented to the retention of the record.

During the period of retention, we will continue to abide by our non disclosure obligations and will not share or sell your personal information.

We may retain your personal information in physical or electronic records at our discretion.

We will only retain your personal information for as long as is necessary.

Transfer to another country

We may transmit or transfer personal information from South Africa to a foreign country and process it in that country. Personal information may be stored on servers located outside of South Africa in a foreign country whose laws protecting personal information may not be as stringent as the laws in South Africa. Personal information may be transferred to the parents or guardians of learners when they access the Learning Management System (Moodle), or by email. You consent to us processing your personal information, or the personal information of your child, in a foreign country, or transferring it to a foreign country whose laws regarding processing of personal information may be less stringent than those in South Africa.

We may transfer your personal information, or the personal information of your child, from South Africa to a foreign country.

Updating or removing

You may choose to correct or update the personal information you have submitted to us by contacting us by phone or by sending an email to popia@cornwallhill.org.

You may choose to update or remove the personal information you have submitted to us.

Limitation

We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.

Enquiries

If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us at popia@cornwallhill.org.

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