PRIVACY POLICY

DATA CONTROLLER:
INTERNATIONAL SCHOOL OF MILAN (“The School”) 
Via I Maggio, 20 - 20021 Baranzate (MI)
Email address: dataprivacy@ismilan.it
 
DATA PROCESSOR:

INTERNATIONAL SCHOOL OF EUROPE S.P.A
Via Manfredo Camperio, 14 - 20123 Milano

International School of Milan is part of Inspired Education Holdings Ltd., (“Inspired Education Group”), which is a company registered in United Kingdom with number 09268120 and registered address at Sixth Floor, 3 Burlington Gardens, London, W1S 3EP. Inspired operates numerous affiliated schools globally via its regional offices in Europe, Africa, Middle East, Asia-Pacific and Latin America.

1. INTRODUCTION

This policy is drafted in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data (GDPR) and the Italian implementation by Legislative Decree n. 101 dated 10 August 2018.
Our Data Protection Officer can be contacted by email at the address dataprivacy@ismilan.it if you have any queries regarding the processing of your personal data.

2. TYPES OF PERSONAL DATA WE PROCESS

We process personal data from our students and their families and / or competent persons and from our employees, candidates, suppliers, contractors, prospective customers and third parties interested in finding out more about International School of Milan within the systems controlled by the school as Data Controller.
The personal data processed are mainly the following:
•    Names, addresses, telephone numbers, e-mail addresses and other contact details;
•    Nationality, location and language
•    Family details and siblings;
•    Safeguarding information (such as court orders and professional involvement)
•    Education and employment data;
•    Images, audio and video recordings, including CCTV footage (video images);
•    Financial information;
•    Educational centres previously attended.
Other types of data we may collect and process, according to the school purposes, are related to health condition, criminal records and other sensitive information related to an individual, such as:
•    Information about health status or provision of health care linked to a specific individual;
•    Behavioural information;
•    Special educational needs
•    Criminal records linked to a specific individual
•    Biometric information;
•    Ethnicity;
•    Religion or ideology;
•    Sexual preferences. 
 

3. HOW WE COLLECT AND PROCESS PERSONAL DATA

International School of Milan collects information in several ways, including:
•    Personally and over the phone;
•    Through our website, including information received through our website cookies; 
•    From email and hand delivery paper documentation; 
•    Through online tools such as apps, educational platforms and other software used by the School;
•    Through any CCTV cameras located at our premises or sites;
•    Through third parties, such as legal representatives, professionals or other authorities;

4. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

International School of Milan processes personal data to carry out the School’s educational activity lawfully and legitimately. The School collects and keeps students' and parents’ information when necessary to:
•    Attend enquiries correctly; 
•    Ensure that the student meets the school’s admission criteria;
•    Provide educational services including the support of pupil learning, monitor and report on pupil progress;
•    Make provision to the students of welfare and pastoral care services;
•    Ensure to the students medical and nurse attention, catering service and bus service, among other necessary services;
•    Meet the educational, social, physical and emotional requirements of the student;
•    Manage the International School of Milan Summer Camp; 
•    To enable parents/guardians to be contacted in the case of emergency or in the case of school closure, or to inform parents of their child’s educational progress or about school events, etc.
•    With the aim to celebrate school’s achievements and to keep a record of the history of the school, International School of Milan may take photographs and recorded images of students to be shared in, e.g., yearbooks, school website, etc, always based on informed consent from parents or students of legal age;
•    To send commercial communications if previously requested and authorised by the data subject. You will be able to unsubscribe from the receipt of such commercial communications by clicking in the “unsubscribe” section found in all these kinds of e-mails sent by the School.
In the case of a CV received through our website, in the section “Work With Us”, we will process the information provided under the Legislative Decree 101/2018 and art. 13 GDPR, with the purpose to include the candidacy in the selection process or to consider it for future positions. The information will be kept for the time necessary to comply with the purpose, or when the candidate withdraws her / his consent. In these cases, the data will be safely removed from our files. 
The personal data may only be communicated to third parties when necessary for a safer recruitment and to comply with the purposes of such application as well as to other INTERNATIONAL SCHOOL OF EUROPE S.P.A schools with the prior written consent of the interested party with the same legitimate purposes mentioned herein.

5. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

As a School, we may be lawfully required to share personal information with relevant authorities or third parties as permitted on statutory grounds, to comply with legal obligations or based on a specific consent given by the individual concerned.
We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party. For example, we will enter into data processing agreements with relevant parties (providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data).
The parties to whom we may disclose your personal data as above referred may be located in countries outside Italy, including countries which may offer a lower level of data protection. In such cases, we will implement appropriate measures to ensure adequate protection of your personal data in accordance with applicable data protection legislation.
Your personal data shall be neither rented nor sold to third parties.

6. CONSERVATION OF DATA

Personal information will only be retained for the period required to fulfil the purpose for which it was collected unless for a longer time for public interest archiving, scientific or historical research, or statistical purposes. Once the personal information is no longer required or permitted to be retained for legal or business purposes, or you have withdrawn your consent,  it will be destroyed or made anonymous.

7. YOUR RIGHTS

Under the data protection regulations, you have rights regarding the processing of your personal data. These rights are, however, subject to certain exemptions and limitations.
You have the right to:
•    Be informed, at the time when personal data is collected, about the data processing.
•    Access the information we process and how we process it as well as to obtain a copy of the personal data considering the legal limitations and exceptions;
•    Ask for the erasure of the personal data we hold about you without undue delay considering the legal limitations and exceptions;
•    Obtain the rectification of your personal data providing a supplementary statement;
•    Obtain restriction of processing of your personal data when it is inaccurate, illegal, unnecessary or not verified, considering the legal limitations and exceptions;
•    Obtain data portability of your personal information in a structured, commonly used, and machine-readable format. This allows the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided;
•    Object to processing for direct marketing purposes;
•    Withdraw consent at any time and freely to the processing of your personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You can send a written request, along with a copy of your ID card, to the Data Protection Officer’s email address dataprivacy@ismilan.it.

8. CONSENT

You will have the right and possibility to withdraw your consent for any specific purpose granted at any given time without prejudice of the legality of processing according to the consent given before withdrawal.

9. MINORS

International School of Milan will not collect and process, under any concept, data from individuals under 14 years old. Consent from parents or legal representatives will be always required. 

10. STORING AND SECURING INFORMATION

International School of Milan shall use the appropriate technical and organisational measures to ensure the security, confidentiality, integrity, and privacy of the personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the files.

11. COMMON USE WITH SOCIAL NETWORKS

This website contains links to parent’s portal and other educational platforms in addition to social networks like Instagram, YouTube, and Facebook. Our School is not responsible for the privacy practices or the content of such sites. You should be aware that the processing of your personal information is carried out by those sites and governed by their respective privacy policies. 
If you do not want these sites to collect and process your information, please review their corresponding privacy policies and / or disconnect from it before using our Services.

12. COOKIES USED IN OUR WEBSITE 

We use cookies to provide you with a better experience in the use of our website, as well as to store information about our visitors. This information is related to your session ID and are a way of monitoring single user access. 
The Web server is allowed to remember some data concerning the user, such as his preferences for visiting the pages of this server, name and password, products that are more interesting, etc.
The Cookies that we use in our website and that require informed consent by the user are the functional cookies and the targeting cookies. Consent is not required for required cookies, which are those of a technical nature necessary for the operation of the website or the provision of services expressly requested by the user.
You can find more information about our Cookies policy at: https://www.internationalschoolofmilan.it/en/cookies-policy. 

13. COMPLAINTS

If you are not satisfied with our response, you would like to discuss anything regarding this privacy notice, or you believe we are processing your personal data disregarding the data protection regulations in force, please contact our Data Protection Officer at:  dataprivacy@ismilan.it or you can address your request for mediation to the Italian data protection authority, Garante per la Protezione dei Dati Personali, addressed at Piazza Venezia 11, IT-00187, Roma, with email: rpd@gpdp.it. or visiting the website: https://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-tuoi-dati-personali, although it is recommended that previous steps are taken to resolve the matter with the school before involving the authority.

14. PRIVACY NOTICE UPDATES

International School of Milan may need to update this privacy notice periodically, so we recommend that you review this information from time to time.  

This version was last updated in January 2023