We respect your right to privacy and aim to comply with the requirements of all relevant privacy and data protection laws, particularly the Data Privacy Act of 2012 (DPA). As in the case of the National Privacy Commission (NPC), we also seek to strike a balance between your personal privacy, and the free flow of information, especially when pursuing our legitimate interests and when necessary to carry out our responsibilities as an educational institution.
In this Policy, the terms, “data” and “information” are used interchangeably. When we speak of “personal data”, the term includes the concepts of personal information, sensitive personal information, and privileged information. The first two are typically used to distinctively identify you. For their exact definitions, you may refer to the text of the DPA. You should also note that while we give examples here to explain this Policy in simple and clear language, they do not make up an exhaustive list of all the data that we process.
Information We Collect, Acquire, or Generate
We collect, acquire, or generate your personal data in many forms. They may consist of written records, photographic and video images, digital material, and even biometric records. Examples include:
a. Information you provide us during your application for admission. When you apply with us for admission, we collect, among others: (1) directory information, like your name, email address, telephone number, and other contact details; (2) data about your personal circumstances, such as your family background, history, and other relevant circumstances, previous schools attended, academic performance, disciplinary record, and medical records; and (3) and any or all information obtained through interviews and/or during entrance assessments.
b. Information we collect or generate after enrolment and during the course of your stay with us. After you join the LALC, we may also collect additional information about you, including: (1) your academic or curricular undertakings, such as your regular daily activities, scholastic performance, attendance record, etc.; (2) co-curricular matters and extra- curricular activities, such as field trips and participation in and attendance to competitions, seminars programs and study tours. There will also be times when we will acquire other forms of data like pictures or videos of activities you participate in, via official documentation of such activities either by professionals we employ or by our own initiatives, or through recordings from closed-circuit security television cameras installed within school premises.
c. Unsolicited Information. There may be instances when personal information is sent to or received by us even without our prior request. In such cases, we will determine if we can legitimately keep such information. If it is not related to any of our legitimate interests, we will immediately dispose of the information in a way that will safeguard your privacy. Otherwise, it will be treated in the same manner as information you provide us.
It is assumed that all data entries you submitted to us upon your child’s admission is factual and correct. Additionally, we also take it on good faith that if you supply us with personal data of other individuals (e.g., person to contact in the event of an emergency), you have obtained the consent of such individuals before providing us with their personal data.
How We Use Your Information
To the extent permitted or required by law, we use your personal data to pursue our legitimate interests as an educational institution, including a variety of academic, administrative, research, historical, and statistical purposes. For example, we may use the information we collect for purposes such as:
a. Student Admission. Your child’s personal information, among others, his/her name, and gender, data and place of birth, citizenship, information about your family and other personal information, along with other documents you provide will be used to verify your child’s identity in the course of determining his/her eligibility to enrol in LALC.
b. Academic and Non-Academic Services. Your child’s personal information will be used by LALC in the course of fulfilling its obligation to provide him/her quality education. Your child’s personal information may also be processed in order to provide him/her with services (e.g. library services, dormitory, health service, counselling and guidance, transportation, etc), or to protect your child’s vitally important interests. Users of your child’s personal information will be limited only to the School’s duly authorized personnel, as part of their duties and responsibilities.
c. Clinic Services. Your child’s personal information will be used by the School to determine his/her physical fitness to enrol and be able to provide you with the proper care when he/she avails of the School’s health services or in case of an emergency. For instance, submission of medical certificates in order for your child’s absences to be excused, or when he/she needs to go on leave of absence, etc.
d. Information Dissemination. Contact information is processed by LALC in order to be able to communicate effectively with you and to enable us to contact your family members or other people you identify in case of an emergency. LALC, through the Center Director, or his/her respective administrators and teachers may use the information generated by the applicable registration system in order to contact you via email and/or SMS for class-related and other academic matters. We have also established social media channels via our official Facebook Group for picture documentation and announcements. Likewise, we have established official LALC Viber Communities for the same purpose.
e. Transportation Arrangements. Your child’s personal information will be utilized by our authorized transportation service provider to pick-up and transport him/her on the date, time, and location requested, and to appropriately charge transportation fees to your account.
f. Accounting Purposes. The School processes financial information related to your child’s studies, e.g. tuition payments, and payments for other fees. pursuant to its contractual or legal obligations as part of the School’s legitimate interests and our responsibility as a taxpayer.
g. Financial Audit. In preparing our financial reports, we will or may provide documents or files that may bear your child’s personal information to our external auditors, who are engaged to check for the consistency, accuracy, and validity of our financial records.
h. Accreditation/Certification Activities. Your child’s personal information may be collected to process accreditation or certification of the School’s programs or services.
i. Compliance activities. Your child’s personal information may be used to comply with contractual, organizational and regulatory requirements (e.g., submission of requirements to educational institutions and government agencies).
j. Other activities. We will use your child’s personal information for monitoring purposes, records management, School programs/activities, recognition of achievements/celebrations, other services that your child may avail, and other activities as deemed necessary to serve our business purpose, including sharing marketing and promotional materials regarding school-related functions, events, projects, and activities; soliciting your participation in research and non-commercial surveys sanctioned by the LALC; and soliciting your support, financial or otherwise, for LALC programs, projects, and events;
We consider the processing of your personal data for these purposes to be necessary for the performance of our contractual obligations to you, for our compliance with a legal obligation, to protect your vitally important interests, including your life and health, for the performance of tasks we carry out in the public interest (e.g., public order, public safety, etc.), or for the pursuit of the legitimate interests of the LALC or a third party. We understand that the DPA imposes stricter rules for the processing of sensitive personal information and privileged information, and we are fully committed to abiding by those rules.
Please note further that we will not subject your personal data to any automated decision-making process without your prior consent.
How We Share, Disclose, or Transfer Your Information
To the extent permitted or required by law, we may also share, disclose, or transfer your personal data to other persons or organizations in order to uphold your interests and/or pursue our legitimate interests as an educational institution. For example, we may share, disclose, or transfer your personal data for purposes such as:
a. Sharing through email or by any other means available by any of our authorized personnel across all campuses of the Little Archers Learning Center, if deemed necessary for our business purpose, as listed below:
- Archers Arrow Learning Center, Inc. (Little Archers – Multi)
- Animo Kids Learning Center, Inc. (Little Archers – MOA)
- Archers Animo Learning Center, Inc. (Little Archers – Makati)
b. Securing insurance coverage for our pupils, and other disclosures as necessary for financial or insurance organisations.
c. Compliance with requests for information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable laws or regulations. This may include disclosures outside the country, if necessary. As part of our commitment to protect your personal information, we will review and use your information to determine whether disclosure is required or permitted.
The School ensures that personal information shared through email or by any other means available are protected with our IT or manual systems and controls in place to mitigate the risk of data breaches. We ensure you that all our employees across are well-informed of the Data Privacy Act and their responsibilities, particularly in sharing your personal information.
In addition to those enumerated above, we may use, share or disclose your data in the following ways:
1. sharing of your personal data with your parents, guardians, or next of kin, as required by law, or on a need-to-know basis, as determined by the LALC, in order to promote your best interests, or to protect your health, safety, and security, or that of others;
3. sharing of some information to donors, funders, or benefactors for purposes of scholarship, grants, and other forms of assistance;
4. publication of scholars’ graduation brochure for distribution to donors, funders, or benefactors;
5. distribution of the list of graduates and awardees in preparation for and during commencement exercises;
6. complying with court orders, subpoenas and/or other legal obligations;
7. conducting internal research or surveys for purposes of institutional development;
8. publishing academic, co-curricular, and extra-curricular achievements and success, including honors lists and names of awardees in school bulletin boards, website, social media sites, and publications;
9. sharing your academic accomplishments or honors and co-curricular or extra-curricular
achievements with schools you graduated from or were previously enrolled in, upon their request;
10. use of photos, videos, and other information in order to promote the school, including its activities and events, through marketing or advertising materials, such as brochures, website posts, newspaper advertisements, physical and electronic bulletin boards, and other media;
11. live-streaming of LALC events;
12. publication of communications with journalistic content, such as news information in
LALC publications, and social media sites;
How We Store and Retain Your Information
Your personal data is stored and transmitted securely in a variety of paper and electronic formats, including databases that are shared between the LALC’s different units or offices. Access to your personal data is limited to LALC personnel who have a legitimate interest in them for the purpose of carrying out their contractual duties. All of your child’s personal information collected and documented in various official LALC Forms/Templates will be filed by the designated custodians in a locked storage container for the security and protection of your child’s personal information. On the other hand, personal information in electronic forms will be retained in our computer systems which we have employed with information security controls.
Unless otherwise provided by law or by appropriate LALC policies, we will retain your relevant personal data indefinitely for historical and statistical purposes. Where a retention period is provided by law and/or a LALC policy, all affected records will be securely disposed of after such period.
After the retention period, the School is no longer responsible to keep and provide you with your child’s personal information/ documents. As authorized, our designated custodian will purge your child’s personal information through shredding of paper files and/or deletion of electronic les in our computer system, or in any other manner which would prevent further processing of your child’s personal information.
Your Rights with Respect to Your Personal Data
The School acknowledges your child’s rights as data subjects. Thus, you and even your child himself/herself, are entitled to perform any of the following:
a. Request a copy of your child’s information or access to his/her information. The School will provide your request in a commonly portable format (e.g., printed copy of any soft copy files you have requested, photocopy of the document you are requesting) for a span of two (2) months from date that the prescribed processing fee is paid.
However, the School is not generally required to undertake endless and disproportionate searches for information in order to respond to a request and the School may refuse to your request if:
– The relevant personal information is not in the School’s possession or control
– The request is identical or very similar to the one you have recently requested
– The request is obviously unfounded or frivolous, and
– Harm would arise or likely arise from disclosure, for example, if disclosure would be likely to prejudice a criminal investigation or prejudice someone’s commercial interests.
In case your request is declined, we will provide you a formal noti cation indicating the grounds for declining your request.
B. Request for the correction/rectification or deletion of your child’s information, provided that the information is/are not necessary for compliance with a regulatory obligation and it is not necessary to establish, exercise or defend legal claims.
C. Object/Restrict processing of your child’s information, provided that personal information requested for restriction is not necessary for compliance with a regulatory obligation and it is not necessary to establish, exercise or defend legal claims. This right may be exercised upon discovery and substantial proof that personal information was obtained or processed unlawfully. This includes objecting and restricting the use of your child’s picture or image in LALC marketing and promotion efforts.
D. File a complaint with the National Privacy Commission (NPC) if any of the DPA provisions regarding security of your child’s personal information, including your child’s rights as data subjects, are violated.
For further knowledge and reference about your child’s rights as data subjects and how he/she can exercise them, you may visit NPC’s of cial website at https://privacy.gov.ph/.
In the event your child’s personal information is breached, we are prepared to follow any laws and regulations which would require us to notify you of such breach including the quality of information affected.
As our business partner, you are expected to comply with security related and privacy clauses that need to be executed as part of our standard terms of business and/or contract(s).
Where do you go for more information?
If you have questions about how we use your information, you may contact our Program Director, Teacher Noni Odulio, at 88232390 or at firstname.lastname@example.org.
/ 13 June 2019