Privacy Statement

SCHEDULE "B" TO
ST. JOHN'S RAVENSCOURT SCHOOL - PRIVACY POLICY

ONLINE PRIVACY POLICY


As a leading independent co-educational Kindergarten to Grade 12 university-preparatory day and boarding school, St. John's-Ravenscourt School ("SJR") is committed to protecting the confidentiality of personal information under its custody or control in accordance with relevant privacy laws.

This Online Privacy Policy sets out SJR's general privacy compliance obligations, including without limitation for its website and any other online services or communication tools offered by SJR through which personal information may be collected or obtained. This Online Privacy Policy is in addition to the general Privacy Policy adopted by SJR, as may be updated from time to time.

Application of this Privacy Policy
As a school located in Manitoba, Canada, SJR has undertaken to comply with the privacy obligations set out in the: (i) Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA"); (ii) The Personal Health Information Act (Manitoba) in connection with personal health information, if any, administered by our school nurse as a Trustee at law, and (iii) the General Data Protection Regulation (European Union) to the extent same is applicable to the school and as reasonably necessary.

This Online Privacy Policy applies to all third party personal information under the custody or control of SJR. For the purposes of this Online Privacy Policy, "personal information" means information about an identifiable individual, but does not include business contact information of an individual collected, used or disclosed solely for the purpose of communicating or facilitating communication with that individual in relation to their employment, business or profession. Personal health information of SJR students as administered by the SJR school nurse is subject to the Privacy Policy and must be administered in accordance with its terms; "personal health information" means recorded information about an identifiable individual relating to their health or health care.

Please note that given the nature of SJR and its operations, and taking into account PIPEDA requirements, this Online Privacy Policy does not apply to SJR employee personal information.

SJR Compliance – Privacy Officer
SJR has appointed a Privacy Officer to oversee the school's compliance with its Privacy Policy, this Online Privacy Policy and its privacy obligations at law. The SJR Privacy Officer may also, as he or she deems reasonably necessary, designate additional responsibilities for day-to-day collection and administration of personal information to other SJR employees, as appropriate.

Training
SJR trains its employees to ensure that they understand and implement its privacy practices including as set out in this SJR Online Privacy Policy. For each employee, SJR determines the appropriate level of access to personal information in the custody or under the control of SJR in order to perform his or her duties as a means of limiting use of personal information. SJR also requires that its agents, officers, board members and other authorized persons take reasonable steps to protect student and third party personal information in accordance with this SJR Online Privacy Policy.

Collection and Identifying Purposes
At SJR, we will do our utmost to specify the purposes for which personal information will be collected at or prior to the time of collection. Should it be necessary to use or disclose your personal information for additional purposes, we will contact you to obtain consent, unless otherwise required or permitted by relevant law.

Information Collected Through Online Use
When you use the SJR website, certain limited personal information may be collected automatically. The purpose of this collection is to gather information to tell us more information about how you use the SJR website and to allow us to improve our systems and gather analytical data. SJR gathers this information through the use of cookies, namely a small set of computer code generated by our website and which gets saved by your internet web browser; cookies allow our website to store information about you in terms of your preferences and website use. We gather certain usage data, which typically includes the internet protocol (IP) address or domain names of the computers utilized by you or associated with your use of the SJR website, as well as information concerning your usage such as the time of the request and time spent or details regarding your visit and activity relating to the site, the method used to submit the request to the server, the size of the file received in response, the country of origin of the request, the features of the browser and operating system you are using, and details about the path followed within our site with specific reference to the sequence of pages visited, and similar such information. Usage data is not combined by SJR with other data submitted or collected by us to identify personal information of particular users. The SJR website does not retain website login information through the use of cookies. While a user may adjust browser settings to limit the collection of user usage data or prohibit cookies, these types of setting changes may negatively affect your ability to use the SJR website, forms or other features.

SJR will also collect certain information about you if you contact us by completing an online form or by email, and the information we collect will include the contents of the information that you submit to us, including as it may relate to you, to a student or concerning other person(s) as addressed in the form or email submitted. This may include such information as, for example, your name, mailing address, postal code or ZIP code, country of residence/citizenship and your email address, and the name and details concerning any third party that is the subject of your communication to us.

In collecting personal information, SJR will only make mandatory the provision of personal information it actually requires in order to deliver a service. SJR will, where possible, specify mandatory information as part of its collection practices, and while it may collect optional information in forms and through other means, services will not be denied if optional information is not provided. User usage data, to the extent that this is deemed to be personal information at law, shall be deemed mandatory information as it is automatically collected.

Users Responsible for Information Shared with SJR
As a user, you are responsible for all information including any personal information that you share with SJR, including through its website, online forms or otherwise. You undertake to ensure that all personal information that you provide to SJR is accurate and correct and that you have legal authority and capacity to submit any such personal information to SJR. If you are submitting a request form to SJR to apply for services on behalf of a student or proposed student, you confirm that you have the legal authority as a parent or legal guardian to make such submission to us on behalf of that minor child.

Safeguards and Data Processing
SJR has adopted privacy safeguard measures to in order to prevent unauthorized access, disclosure, use, modification or destruction of personal information under its control. You acknowledge, however, that notwithstanding any reasonable safeguard measures that we may take, the provision of information through online means may carry an inherent risk.

SJR is located in Manitoba, Canada, and has a diverse student population which may include at any time students both from within and from outside of Canada. You acknowledge and agree that SJR may, in its discretion, use information managers or other third party service providers located in Canada or in other countries to host, process or otherwise administer personal information under SJR's control from time to time. SJR shall only transfer personal information to a third party, including an information manager, for storage, processing or other permitted transactions where it has in place contractual or other means to require that third party to provide a comparable level of protection for the transferred personal information sufficient to meet the obligations of SJR under this Online Privacy Policy. Without limiting the foregoing, where SJR uses such third party information managers or service providers, including where they are outside of Canada, SJR shall bind such information managers or service providers to comply with the terms of PIPEDA and the GDPR in terms of the safeguarding of personal information. In addition to the foregoing, SJR also reserves the right to transmit personal information for storage, administration and/or processing by third parties either within or outside of Canada, in its discretion, including to jurisdictions outside your country of residence. You acknowledge that any personal information which is managed by such third party information managers and/or service providers may also be subject to the laws of the other jurisdictions or foreign country where the information manager or service provider is located or where it stores such data.  

You are entitled to find out where your personal information is being maintained or processed, which information can be obtained upon request from SJR's privacy officer at privacyofficer@sjr.mb.ca
In addition, SJR personal information may also be accessible to certain types of service providers who require such information to complete services required by SJR, such as website administrators, sales, marketing, legal, system and administration service providers. All such persons shall be under obligations of confidentiality and the use of appropriate safeguards consistent with SJR's obligations under its Privacy Policy and this Online Privacy Policy.

Purposes of Processing of Personal Information
SJR may process personal information where: (a) consent has already been granted for those specific purposes; (b) that personal information is necessary for the performance of an agreement to which the user is a party; (c) processing is necessary for compliance with a legal obligation and/or right to which SJR is subject or which it has at law, (d) or such use is permitted by relevant law without a need for specific or additional consent.

Analytics
SJR reserves the right to collect analytics concerning the use of its website and its services to analyze web traffic concerning the SJR website and to engage such third parties to collect and carry out those analytics on its behalf.

Limiting Use, Disclosure, Retention
SJR shall use personal information for purposes for which the information was collected, unless additional consent has been obtained or unless permitted by relevant law. It is anticipated that personal information may be collected for or on behalf of SJR and used and/or disclosed for the following purposes

     (a)  to establish and maintain responsible educational relations with students and their families;
     (b)  to provide support and services to its students and families;
     (c)  in order to meet student/family needs and requests;
     (d)  to develop, enhance, market or provide educational services;
     (e)  to manage and develop the School's business and operations;
      (f)  to meet legal and regulatory requirements;
     (g)   in order to contact students and their families in the course of undertaking educational activities;
     (h)  in order to contact suppliers and other third party service providers;
      (i)  in order to process payments and invoices related to the services; and
      (j)  in order to process expenses.

SJR may also use or disclose personal information as required in order to comply with The Education Administration Act, wherein certain information must be provided to the Minister of Education, Government of Manitoba, for various purposes including: to determine enrolment, assign Manitoba education numbers, and other purposes under that Act.

SJR shall retain files containing personal information as required by law. The retention period shall take into account limitation periods and taxation audit periods in addition to privacy requirements. Personal information that is no longer required by SJR shall then be retained and destroyed in accordance with SJR's Records Management Policy. When destroyed, personal information shall be shredded and/or disposed of in a manner that safeguards the confidentiality of the information.

Accuracy
SJR shall take steps to ensure that personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Individual Access
Subject to the terms of the Privacy Policy, individuals shall have a right to access their own personal information under the custody and/or control of SJR, unless otherwise specified under relevant law. Individuals may also require that their personal information be provided in a commonly used electronic form, subject to availability.

SJR reserves the right to require that requests for access to personal information be made in writing.
Prior to the release of personal information, SJR may require that you confirm your identity, including through the provision of government issued photo identification.

If a request for access cannot be granted, SJR will reply in writing and advise of the reasons that an access request is being denied.

User Rights
-Withdrawal of Consent – Individuals may withdraw their consent concerning use of their personal information at any time, subject to contractual restrictions. Any such withdrawal: (i) will not affect any past processing or administration of personal information made while the consent was valid, and (ii) may affect the ability of the individual to qualify to receive certain services where personal information is required, which shall be specified to the subject individual in writing.

-Right to Object for Direct Marketing –
An individual has a right to object to any use or processing of his/her personal information which is for direct marketing purposes. Should any individual object to any use for this purpose, SJR shall make no further use of that personal information for this purpose. SJR shall also advise individuals of their right to object as part of the initial collection of consent after the coming into force of this Online Privacy Policy and as part of consents thereafter.

-Right to Erasure -
Individuals may also require that their data be erased when personal information is no longer required for the purpose for which it was collected or processed, and subject to any records Managementpolicy established by SJR. SJR shall comply with such requests subject to applicable laws and any such policies in place from time to time.

Breach of Security Safeguards
Should there be a breach of security safeguards, SJR shall immediately investigate the breach and take commercially reasonable steps to mitigate any loss, risk or harm which results or is likely to result from such breach.

Where a breach has occurred, and an individual may encounter a real risk of significant harm as a result, then SJR shall forthwith notify the affected person and the Office of the Privacy Commissioner of Canada to report the breach, in the manner contemplated in the SJR Privacy Policy.
SJR shall maintain a record of all security safeguards in accordance with the terms of its Privacy Policy.

Challenging Compliance
Should an individual have a question, or have any issue with the manner in which SJR, its employees, agents or representatives are collecting, using, storing, disclosing or destroying personal information, or any other matter under this Policy, he or she may contact the Privacy Officer at the address previously set out below.

If there are any matters that have not been expressly addressed in this Policy, or (i) if an individual requires clarification as to how to implement or interpret this Policy, (ii) if an individual would like to request access to his or her personal information or to amend such information, (iii) if an individual would like to withdraw their consent concerning the use of their personal information at any time, or (iv) an individual would like to file a complaint under this Policy, such concerns should be brought to the attention of the Privacy Officer immediately.

The Privacy Officer can be contacted as follows:

Privacy Officer
Deputy Head, Finance and Operations
St. John's-Ravenscourt School
Direct Line - 204-477-2415
Fax Number - (204) 477-2466
Email Address: privacyofficer@sjr.mb.ca

St. John's-Ravenscourt

400 South Drive
Winnipeg, MB, Canada
R3T 3K5 - VIEW MAP
Founded in 1820, St. John’s-Ravenscourt School is a university-preparatory day and boarding school for boys and girls. As one of Canada’s leading Kindergarten to Grade 12 independent schools, SJR has a reputation for excellence and a consistent tradition of national and international achievements, including 18 Rhodes scholars and winning 14 out of the last 30 World Championships at the World Individual Debating and Public Speaking Championships –a feat unmatched by any other school in the world.
Founded in 1820, St. John’s-Ravenscourt School is a university-preparatory day and boarding school for boys and girls. As one of Canada’s leading Kindergarten to Grade 12 independent schools, SJR has a reputation for excellence and a consistent tradition of national and international achievements, including 18 Rhodes scholars and winning 14 out of the last 30 World Championships at the World Individual Debating and Public Speaking Championships –a feat unmatched by any other school in the world.