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.
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.
SJR Compliance – Privacy Officer
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
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.
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 firstname.lastname@example.org
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.
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.
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.
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.
-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 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.
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:
Deputy Head, Finance and Operations
St. John's-Ravenscourt School
Direct Line - 204-477-2415
Fax Number - (204) 477-2466
Email Address: email@example.com