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Data Protection policy

 

This policy is drafted in accordance with the new Act on Federal Data Protection (“nFADP”), September 1, 2023 which implements the European General Data Protection Regulation (EU) 2016/679 of April 27, 2016 regarding the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).    

 

Surval complies with these terms. Personal data will be kept strictly confidential and will not be sold or passed on to third parties except under the conditions below.

 

Surval is committed to keeping personal information accurate, up-to-date, safe, and secure and will not keep personal information longer than necessary. This privacy notice explains how we use personal information, whom we share it with, and how we protect privacy. This notice applies to all personal data collected for and on behalf of the school. 

 

What categories of personal data do we collect?

 

We mainly collect the following personal data:

 

  • Contact details for students and their families (student name, parents' names, mobile numbers, personal emails, postal address)

  • Contact details of staff (name, job title, work and mobile telephone numbers, work and personal email and postal address);

  • Professional details (e.g., job and career history, educational background, and professional memberships);

  •  Car details (for staff using our parking);

  • Financial information (e.g., taxes, payroll, pensions, assets, bank details, insolvency records);

  •  Images and video recordings including CCTV footage;

  • Past, present, and future students’ academic, admissions, and certificates;

  •  References received about students and staff.

 

Other types of sensitive data that we might collect (according to school purposes)  include:

 

  • Personal identification documents;

  •  Biometric information;

  •  Special educational needs;

  • Information about health status or provision of health care linked to a specific individual;

  • Behavioural information; 

  • Criminal records.



 

How do we collect data

 

  • In person and over the phone;

  • Through our webpage forms and enrolment forms; 

  • Through cookies on our webpage;

  • From emails, job applications, invoices, letters, consent forms;

  • Through online tools such as WhatsApp and Wechat; 

  • Through CCTV cameras located at our school;

  • Through referees.

 

How do we use personal data?

Surval collects personal information of current and prospective students, parents, former students, school agents, employees, candidates, suppliers, and at times, third parties. We use the information provided for purposes that are necessary and required to undertake the performance of the contract into which the individual, family, or company is entering or has entered into and do so as we are required to do by law.

 

We use the information provided in the following ways:
 

  •  to undertake and manage the school admissions and enrolment;

  •  to provide a safe learning environment;

  •  to comply with child protection requirements;

  • to support and enable the academic, pastoral, and personal objectives of children including the monitoring and reporting of progress;

  •  to provide support and care for emotional and psychological well-being (pastoral and counselling);

  •  to protect the health of students and staff;

  •  to enable students to go on school trips or participate in outside events; 

  • to inform the development and implementation of recruitment and retention policies;

  •  to support and develop our employees in the performance of their duties;

  •  to help investigate any concerns or complaints:

  •  to comply with legislative or administrative requirements;

  •  to maintain communication with agents and alumnae;

  •  to recruit new staff;

  •  to administer payroll, pension, and HR records.

 

Who has Access to Personal Data and with whom does the School share it

Occasionally, the school will need to share personal information relating to its community with third parties, such as professional advisers (lawyers and accountants) or relevant authorities (police, commune or canton) in order to comply with authority requests or in our duty as employer and school with a responsibility to our students and staff.  For the most part, personal data collected by the School will remain within the School and will be processed by a limited number of dedicated staff with respect for confidentiality.

Strict rules of access apply for:

 

  • Student medical records are held and accessed only by appropriate medical staff or otherwise with parental and/or student consent;

  • Pastoral and safeguarding files;

  • Staff files.

 

How do we protect the security of data

The school will take reasonable steps to ensure that members of staff will only have access to the personal data of students and their families where necessary. 

 

Surval uses a list of strategies to safeguard data:

  • Regular backups and IT audits; 

  • Regular software updates;

  • Password protection;

  • Antivirus software;

  • Multi-Factor authentication;

  • Firewall protection;

  • Confidential information about students and families is stored on secure servers such as iSams and CPOMS which are managed in accordance with their data protection policy;

  • HR and salary software are stored on secure servers certified by Swissdec.

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Conservation of data

The School will retain personal data securely and only in line with how long it is necessary to keep it for a legitimate and lawful reason. Typically, Swiss Law recommends keeping ordinary staff and student personnel files for up to 10  years following departure from the School. Incident reports and safeguarding files will need to be kept much longer in accordance with specific legal requirements.  Please refer to the school’s archive policy for further details.

Once the personal information is no longer required or permitted to be retained for legal or business purposes, it will be destroyed or made anonymous.

 

Rights

In accordance with the Federal Act on Data Protection (FADP), any person may request information from the school as to whether their personal data is being processed and may, if necessary, have the data corrected or destroyed. This right to information allows everyone to maintain control over the data collected about them. It is key to enabling those affected to assert their rights under the law and ensures transparency regarding what use is made of the data. Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, should put their request in writing to the School’s Principal.

 

Minors

Surval Montreux will not collect and process data from students under legal age. Parent consent or a valid authorisation of a legal representative will always be required.

 

Cookies

Cookies are stored on the individual’s computer when our website is used by you. Cookies are small text data files that are stored on the individual's hard disc and associated with the browser through which certain information flows to the entity that places the cookie (in this case Surval). Their purpose is to make the Internet offering more user-friendly and effective overall.
The personal data provided by the individual on our website will be used by Surval Montreux only to give you the desired information material or services. 



 

Social Networks

The school’s website contains links to other websites or social networks such as Instagram, Facebook, YouTube, and LinkedIn. Surval Montreux is not responsible for the privacy practices or the content of such sites. Individuals should be aware that the processing of their personal information is carried out by those sites and governed by their respective privacy policies. If individuals do not want these sites to collect and process information, please review their corresponding privacy policies and/or disconnect from them before using our Services.

 

Privacy Notice updates

The School may need to update this privacy notice periodically, so we recommend that individuals review this information from time to time.  

 

This version was updated in September 2023.

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