Privacy Notice

Privacy Notice

Saltus Grammar School (“SGS”, the “school”, “us” and “we”), is committed to protecting your information and uses your personal information carefully in line with privacy and data protection laws, including the Personal Information Protection Act 2016 (as amended) (“PIPA”). 

This privacy notice provides information about how we, and to the extent applicable the Saltus Association on our behalf, uses personal information in connection with our school community.  Members of our “school community” include our current, past and prospective students, their parents, carers or guardians (referred to in this notice as the “parents”); donors, friends and supporters; and other individuals connected to or visiting the school (including students enrolled in our vacation courses). We have a separate privacy notice for our staff community.  

This privacy notice is intended to provide clear and easily accessible information about our privacy practices and policies. We are responsible for any personal information that is used by us in Bermuda.

This privacy notice does not form part of your contract (if any) with SGS and does not confer any contractual right on you, or place any contractual obligation on us. We may update or otherwise amend this notice at any time.

Definitions
  • “Personal information” means any information about an identified or identifiable natural person.
  • “Use” or “using”, in relation to personal information, means carrying out any operation on personal information, including collecting, obtaining, recording, holding, storing, organizing, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating or otherwise making available, combining, blocking, erasing or destroying it.
  • “Sensitive personal information” means any personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, gender, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information.
How we collect your personal information 
We collect most of the personal information we use directly from the individual concerned (or in the case of students, from their parents).  This may include information provided in initial school enrolment applications as well as throughout your relationship with the school. We may also collect information from the student directly, from the school’s teachers and from other parents at the school.  

In some cases, we collect personal information from third parties (e.g. referees, previous schools, or professionals or authorities working with the individual) or from publicly available resources.  Information may also be collected through our systems, e.g. IT and email systems and CCTV footage.

Your personal information that we use
We use personal information about our school community. The personal information we use takes different forms – it may be factual information, expressions of opinion, images or other recorded information which identifies or relates to a natural person.  Examples of personal information that we may use include:
  • Parent information (e.g. name, contact details (phone, home and email address) occupation and contact details at work, if applicable, next of kin information)
  • Financial information (e.g. parents’ bank details to corroborate payments received by the school, and including information regarding financial standing, bursary and scholarship information)
  • Student information (e.g. name, date of birth, family members (including siblings, if relevant to their application), references given or received by the school and relevant information provided by previous educational establishments and/or other professionals or organizations working with students)
  • Students’ past, present and prospective academic, disciplinary, admissions and attendance records (including e.g. admissions assessments, examination scripts and marks, university applications and references, detention and other disciplinary information, attendance at courses, meetings or events, parent teacher conference reports)
  • Where applicable, health and welfare information (including e.g. nominated emergency contact information, any relevant medical information (including any special needs), doctor/other medical professionals’ information, information provided to and produced by the school’s counsellors in their provision of counselling and support services to students)
  • Correspondence and other student administration information (e.g. correspondence (physical and electronic) with and concerning students and parents, past and present, travel requests and other leave permission requests, academic probation letters, withdrawal information)
  • Images/photographs/audio/video recordings (e.g. images and videos of students, staff and parents (and occasionally other individuals) engaging in school activities, and images captured by the school's CCTV
  • Donor information (e.g. name, contact details, bank details to corroborate payments received by the school, donation pledges, conditions and deeds (if applicable), relationship to the school and year of graduation (if applicable)
  • Legal information (e.g. custodial information, court orders)
As a school, we may need to use some sensitive personal information and criminal record information about some individuals (particularly students).  Some of the information above is sensitive personal information that we may use, for example information about a student’s physical or mental health, marital and family status. We use Sensitive Personal information in accordance with all applicable laws, in particular PIPA.

How we use your personal information
It is important to us that we use your or your child(ren)’s personal information in a lawful and fair manner. 

Personal information held by us is used by appropriate members of staff for the purposes for which the personal information was provided.

We use or may use your personal information where it is necessary in the context of performing our contract with you (and/or to prepare to enter into a contract with you); to respond to an emergency that threatens the life, health or security of an individual or the public; to carry out a task in the public interest (to provide our education services to our students) and/or, where it is necessary in order for us to comply with a provision of law that authorizes or requires such use. 

We may ask for your consent to certain processing which is not otherwise justified under one of the above bases. We shall provide clear, prominent, easily understandable, accessible mechanisms for you to give consent in relation to the use of your personal information, unless it can be implied from your conduct that you consent to the use of your personal information (excluding sensitive personal information) for the intended purposes that we have notified you of. 

Where you provide to us personal information of a third party, e.g. a student, next of kin and other emergency contacts, you must be authorized to share such personal information with us and you must obtain the individual’s consent where applicable and inform them of SGS’ privacy notice. 

Where consent is given, it may be withdrawn at any time, but this will not impact on any other lawful basis for processing relied on by the school. In some cases such withdrawal or refusal may mean that we’re unable to continue your engagement with the school if we do not have the personal information we believe necessary for the effective and efficient administration and management of our relationship with you and the applicable student. 

We generally use personal information to support the school’s operation.  The following is a non-exhaustive list of how we use personal information: 
  • To support student learning
  • For the purposes of student selection and admission to the school (and to confirm the identity of prospective students and their parents)
  • To monitor and report on student progress
  • To provide education services, including musical education, physical training or spiritual development, career services, and co-curricular activities to students, and monitoring students’ progress and educational needs
  • To assess the overall effectiveness of the school’s operation
  • To maintain relationships with alumni, staff and the school community, including direct marketing or fundraising activities
  • To undertake donor due diligence, and to confirm the identity of prospective donors and their background and relevant interests – the school may analyze publicly available information about potential donors to make appropriate requests
  • To keep the school community updated about the school’s activities including fundraising and alumni and parent events of interest
  • To monitor students’ email communications and internet use to ensure compliance with school policy
  • Where appropriate, to promote the school through the school’s media sources (including the use of photographs or images)
  • To enable relevant authorities to monitor the school’s performance and to intervene or assist with incidents as appropriate
  • To give and receive information and references about past, current and prospective students, including relating to outstanding fees or payment history, to/from any educational institution that the student attended or where it is proposed they attend; and to provide references to potential employers of past students
  • To enable students to take part in national or other assessments, and to publish the results of public examinations or other achievements of students
  • To safeguard students’ welfare and provide appropriate pastoral care
  • To make use of photographic and video images of students and staff in school publications, on the school website and (where appropriate) on the school’s social media channels in accordance with the school’s policy on taking, storing and using images of children
  • To ensure security such as using CCTV cameras
  • To carry out or cooperate with any school or external complaints, disciplinary or investigation processes
  • To support the school’s administrative requirements including obtaining appropriate professional advice and insurance for the school
The following is a non-exhaustive list of how we use sensitive personal information: 
  • To safeguard student and staff welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual’s medical condition or other relevant information where it is in the individual’s interests to do so: e.g. for medical advice, for social protection, safeguarding, cooperation with police or social services, for insurance purposes or to caterers or organizers of school trips who need to be made aware of dietary or medical needs
  • To provide educational services in the context of any special educational needs of a student
  • To run any school systems that operate on biometric data, such as for security and other forms of student identification (lockers, school shop purchases, etc.)
  • As part of any school or external complaints, disciplinary or investigation processes that involve such sensitive personal information, e.g. if there are learning, health or safeguarding elements
  • For legal and regulatory purposes (e.g. child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care
We retain personal information only for a legitimate and lawful reason and only for so long as necessary for the purpose of its use, including in accordance with any statutory or regulatory requirements and our record retention policies. A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes. If you have any specific queries about or record retention periods, please contact our Privacy Officer.

Who has access to your personal information
Personal information will only be used and disclosed as permitted by applicable law. 

For the most part, personal information collected by the school will remain within SGS, and will be accessed and used by relevant staff only in accordance with our access protocols (e.g. on a ‘need to know’ basis). 

In the course of school business, we share personal information (including sensitive personal information, where appropriate) with third parties, including: 
  • To examination boards
  • To the BC Ministry of Education
  • To school doctors or other healthcare providers
  • To the school’s professional advisors (e.g. Conyers, The Bank of Butterfield, HSBC, Clarien, KPMG)
  • To relevant authorities (e.g. the Department of Education, the Department of Child and Family Services and the Department of Immigration). This could relate to, for example, our complying with our statutory obligations in relation to the care of our students, in light of imminent or pending legal proceedings or a statutory audit of the school
  • To potential or current employers of our alumni
  • Ticketing and events management vendors (e.g. PTIX).  This may relate, for example, to websites used for fundraising purposes
  • The Saltus Association and other SGS affiliated organizations
  • To other contractors or service providers
Some systems used by SGS are provided by third parties, e.g. hosted databases, online vendors, school website or cloud storage providers (i.e. Blackbaud (CORE and Raiser’s Edge), Renweb, Google Workspace, Microsoft 365, and the BC Ministry of Education (BC’s EDX). Personal information may also be shared with certain interconnecting systems. Data contained in such systems may be accessible by providers of those systems, their associated companies and sub-contractors.  This is always subject to contractual assurances that all personal information will be kept securely, used only in accordance with our specific directions and that such third parties represent that they are compliant with PIPA. 

We do not transfer personal information to any overseas third party unless we are satisfied that the personal information will be afforded an equivalent level of protection by the overseas third party. 
Collaboration with the Saltus Association 
The Saltus Association is a volunteer-led association that works in partnership with SGS to support school community events and fundraising activities, and this privacy notice applies to both SGS and the [Saltus Association] and should be read together with any specific notices provided for particular events or initiatives. We may also provide certain personal information to the Saltus Association, either for its own use or for use on instruction from SGS, in connection with its initiatives including managing school events, volunteering, fundraising initiatives and other related communications. Further information about the Saltus Association is available on our website.

Medical information 
The school may need to process certain medical information to comply with its statutory duties and to keep pupils and others safe, but the school will ensure only authorized staff can access information on a need-to-know basis. This may include wider dissemination if needed for school trips or for catering purposes. Express consent will be sought where appropriate and necessary. However, a certain amount of any special needs requirements will need to be provided to staff more widely in the context of providing the necessary care and education that the student requires. 

Safeguarding information 
Students and parents are reminded that the school is under duties imposed by law and statutory guidance to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as the police.

Monitoring 
Any usage of school systems, telephones, email and internet facilities may be subject to monitoring in compliance with law and best practice. For example, we may monitor students’ usage: to prevent, detect or investigate suspected wrongdoing or abuse of school policies; to comply with legal obligations; or to locate and retrieve lost messages or files. 

Email and internet usage are potentially subject to interception and to disclosure to third parties in the course of litigation or an investigation. We have a legitimate basis on which to access and protect school data stored or processed on a device, including the content of any communications sent or received from the device. 

The school uses CCTV, internally and externally in common areas, and you may be recorded when at or around the school’s premises. We use the CCTV footage for security purposes, and to prevent, detect or investigate suspected misconduct, illegal conduct, wrongdoing or other misuse by the staff and/or student community. 

Keeping in touch and supporting the school 
The school will use the contact details of members of the school community to keep them updated about SGS’s activities, or alumni and parent events of interest, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, SGS may also contact staff, parents and/or alumni by post and email in order to promote and raise funds for SGS and, where appropriate, other worthy causes. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, SGS is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
Security safeguards that we use
We will take reasonable steps and adopt appropriate safeguards against risk (including physical and IT based security measures and controls) proportional to the potential harm, sensitivity and context of the personal information which comply with applicable laws to protect our school community’s personal information against loss, unauthorized access, destruction, use, modification, disclosure or other misuse. Access to personal information is also restricted to authorized employees and agents who require access for a permitted purpose to perform their employment functions, and whom have been advised as to its proper handling.

Your rights in relation to your personal information
You have various rights under PIPA to access and understand the personal information we hold about you, and in some cases ask for it to be erased or amended or for us to stop using it, subject to certain exemptions and limitations.

You may submit reasonable written requests to the Privacy Officer to: 
  • Access your personal information that is in our custody or control as well as the purposes for which the personal information has been and is being used and the names and persons or types of persons and the circumstances in which the personal information has been and is being disclosed
  • Correct an error or omission in any of your personal information which is under our control
  • Cease, or not to begin, using your personal information where the use of that personal information is (i) for the purposes of advertising, marketing or public relations and/or (ii) causing, or is likely to cause, substantial damage or substantial distress to the individual or to another individual
  • Erase or destroy your personal information where it is no longer relevant for the purposes of its use
Any request must be in writing and provide sufficient detail to enable us to identify the personal information to which the request relates. We encourage requests to be specific and targeted.

We will acknowledge receipt of a request in writing, including the date of the request and inform you if there is any additional information required to complete the request. We will respond to any such written requests as soon as is reasonably practicable and in accordance with applicable law. 

SGS may charge a fee for providing access to personal information. Please note that in some circumstances we may not be required to fully comply with your request, for example, if disclosure could reasonably be expected to threaten the life or security of an individual, if the personal information would reveal personal information about another individual. We may also refuse to provide access in certain situations, including for example where the personal information is protected by legal privilege. SGS will inform you in writing if we should choose to refuse to take action on a request, including the reasons for refusal and the right to contact the Privacy Commissioner to make a complaint. 

Further information about student information
Individual rights under PIPA belong to the individual to whom the information relates, however we will often rely on parental consent to use personal information relating to students (if consent is required) unless, given the nature of the use in question and the student’s age and understanding, it is more appropriate to rely on the student’s consent.

Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents’ rights at law or under their contact, and all the circumstances.

In general, we will assume that the student’s consent is not required for ordinary disclosure of their personal information to their parents, unless, in the school’s opinion, there is a good reason to do otherwise.

Where a student seeks to raise concerns confidentially with a member of staff and expressly withholds their consent to their personal information being disclosed to their parents, we will consider their request in all of the circumstances, including, for example, their age, maturity, any obligations of confidentiality or other legal or regulatory obligation and will endeavour to act in what the school considers will be in the student’s best interest in light thereof.  

Students can make subject access requests for their own personal information, provided that they have sufficient maturity to understand the request they are making. A person with parental responsibility will generally be entitled to make a subject access request on behalf of students, but the information in question is always considered to be the child’s at law. A student of any age may ask a parent or other representative to make a personal information access request on their behalf. Moreover (if of sufficient maturity) their consent or authority may need to be sought by the parent making such a request. We may need to verify your identity and relationship to the student before complying with any request. 

Contacting us & our Privacy Officer 
SGS is located at 108 St. John’s Road, Pembroke, Bermuda, HM 09

If you have any questions about this privacy notice or to request more details about your rights and how we handle your personal information, please contact our Privacy Officer at privacy@saltus.bm:

Change of details
We try to ensure that all personal information held in relation to an individual is as up to date and accurate as possible. Please notify privacy@saltus.bm of any significant changes to important information, such as contact details, held about you or your child.

Privacy notice updates
This privacy notice is subject to change in accordance with changes to applicable laws or our internal policies and procedures. Any substantial changes that affect how we use your personal information will be notified on our website and to you directly, as far as practicable.
Any changes to this privacy notice will be effective upon publication of the revised privacy notice.
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