PRIVACY POLICY
Amboseli Institute of Hospitality and Technology (hereinafter “AIHT”) will process personal data relating to you in the course of interacting with you.
AIHT strives to comply with applicable data protection regulations, on the protection of privacy in relation to the processing of personal data.
This Privacy Notice (hereinafter “Notice”) explains how we collect and use personal data, who we share it with and the ways in which we protect your privacy while doing so.
This Notice applies to all personal data collected for and on behalf of AIHT. This includes data in analogue form (forms, documents, in writing) and through technological means, such as information systems and email.
AIHT reserves the right to make changes to this Notice from time to time and inform you of such changes in advance.
1. How we collect your personal data
We may collect your personal data in a variety of ways:
Personal data relating to our students can be obtained directly from our students or parents/ guardians, through, but not limited to, when completing the Admissions Form, Health or Consent forms, via information provided via the Parent Portal and via meetings with teachers and staff.
Personal data relating to our students or parents/ guardians can also be obtained via other information channels, such as previous schools, health professionals and social media channels.
Personal data relating to you or your children may also be obtained by actions of AIHT itself or its data processors, e.g. through evaluations and camera surveillance.
2. Why we use your personal data
AIHT is required to process personal data lawfully, fairly, and transparently. This means that they must have a valid legal basis for processing personal data and inform individuals of how the data will be used.
AIHT collects personal data, including special categories of personal data of students and parents to provide a safe and caring environment for teaching, learning and general educational purposes.
AIHT processes you or your parents/ guardian’s personal data for the following, but not limited to, the purposes that are compatible with the purposes described below:
2.1 to undertake and manage the admissions and enrolment
2.2 to provide a safe and secure learning environment
2.3 to support and enable the academic and personal objectives of students, including the monitoring and reporting of progress
2.4 to provide educational services
2.5 to provide support and care for emotional and psychological wellbeing (counselling)
to protect the health of the students and staff we serve
2.6 to provide a tailored learning environment and make evidence-based education decisions for the children we serve
2.7 to enable the students, we serve to continue or progress their education at other educational organizations
2.8 to support and develop our employees in the performance of their duties
2.9 for financial planning to help in the future planning and for resource investment purposes
2.10 to meet our statutory reporting requirements to the education and other authorities
2.11 to help investigate any concerns or complaints you may have
2.12 to build and maintain the AIHT community
2.13 to make you aware and inform you about our services, news, events and activities that are undertaken at or in association with the school
2.14 to communicate with you within the framework of your relationship with AIHT
2.15 to ensure the safety and security of students and staff, including camera surveillance
2.16 for forecasting and planning for education service provision
2.17 to respond to requests of our staff and (former) students regarding historic information pertaining to their time at the school
2.18 For marketing purposes e.g. including photos of students on our brochures and social media (separate parental consent will be asked once a student has enrolled at the school.)
3. On which basis does AIHT processes your personal data
We collect and use personal data to carry out the education services. We do so under the lawful basis that the processing is necessary for the performance of a contract in which you are entering or have entered into.
In some instance, we may have to process data for other purposes that are not necessary for the performance of the contract. In such cases, the processing may be based upon
3.1 our legitimate interests, such as providing a safe learning environment,
3.2 on the protection of you or your children’s vital interests,
3.3 on the compliance with our legal obligations and/or
3.4 on the consent you or your children may have provided to us.
4. The categories of personal data being processed
The categories of personal data that AIHT collects and processes include:
4.1 personal information (such as name, unique number and address)
4.2 special categories of data (such as health information, ethnicity)
4.3 educational and evaluation data (such as assessments, relevant medical information, special educational needs information, behavioral information and psychological reports and assessments)
4.4 attendance information (such as sessions attended, number of absences and absence reasons)
4.5 logging and audit in the use of IT systems and education technology apps, applications and cloud-based systems
4.6 communication and correspondence data (such as emails, letters and other types of correspondence)
4.7 photographs and videos
Special categories of data
The education services we provide require us to collect and process special categories of data, such as health information, for the purposes of safeguarding the protection of the students and the wellbeing of those within our care. We do not disclose or share special categories of data without explicit and unambiguous consent unless we have to do so where we are required to by law, or where we have good reason in protecting the vital interests of an individual, or where not doing so would place someone else at risk.
5. Storing personal data
We keep personal data for as long as necessary with regard to the purposes described in Section 2 of this Notice or for any other purposes that may be communicated to you.
6. Sharing and transfers of personal data
Your personal data will be shared internally within AIHT for the purposes of delivering the services required.
For the purposes described in Section 2 of this Notice, AIHT may need to share your personal data externally with certain recipients, as well as with third parties processing your data on behalf of The AIHT School. This means that the personal data, including special categories of data, may be transferred outside of Kenya, including the UK and the EU (and any additional territories where a student’s transferring is located for example).
More specifically, this includes the following categories of recipients:
Schools that the students attend after leaving AIHT; Other international schools or programs;
Family nurses, doctors or social service organizations (amongst others where sharing is in the vital interests, or where not sharing could have a negative impact on the individual);
Providers of information systems that are necessary for AIHT to deliver the admissions, administration, teaching and learning, spiritual development, mental health and well-being assessments and child protection services;
Providers of IT hosting and maintenance services;
Government organizations, police, health and social care (where we are required to do so by law, or where we have obtained your consent to do so).
Personal data may also be transferred to other data processors. For such transfers of personal data, AIHT has implemented suitable safeguards.
7. Technical and organizational measures
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Such measures include, where appropriate, access controls, strong passwords, pseudonymizing, anonymizing and encrypting personal data and ensuring that our employees are well trained on how to handle personal data.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties on a need-to-know basis. They will only process your personal data on our instructions and they are subject` to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Cookies
When you view our website, some information may be stored on your computer. This information will be in the form of a “cookie” or similar file and will allow the website to tailor the experience to your interests and preferences. With most Internet browsers, cookies can be blocked or erased after visiting a website. Some aspects of this website may not function properly if your browser is set to block cookies.
9. Camera surveillance
We collect information in the form of camera footage via our CCTV-systems to ensure the safety and security of students, parents and staff. We retain these CCTV images for 20 days after which they are deleted, unless we need to retain the images for further investigation or law enforcement purposes.
10. Photographs and videos
Photographs and videos of your children may be taken by staff and students throughout the year to record and share everyday life at AIHT. The student may be identifiable in these photographs or videos. Identifiable photographs of your student may be used for:
10.1 educational and informational purposes (such as keeping records of lessons, field trips, sports, events, staff training), as we have a legitimate interest to do so;
10.2 the identification of your child for health-related purposes, such as allergies, as it is in the vital interest of the student to do so; and
10.3 marketing and publication purposes, if and to the extent we have obtained you and/or your child’s consent where required under applicable data protection legislation to do so.
If such photographs and videos reveal any sensitive personal data of you or your child, we will only process and use such photographs and videos if and to the extent we have obtained you and/or your child’s consent where required under applicable data protection legislation to do so.
AIHT holds copyright to such photographs and videos and infringement of the same may result in legal action being taken by AIHT.
11. Your rights
Parents and students may exercise a number of rights with regard to the processing of their personal data.
The first point of contact in connection with the processing of personal data and the exercise of the rights described below is the AIHT Privacy contact (info@amboseliinstitute.ac.ke). AIHT shall respond to such requests and may or may not act upon them, in principle within a period of one month, all in accordance with applicable data protection legislation.
The rights which you may have under applicable data protection legislation are:
Right to object – the right to object on grounds relating to your particular situation to the processing of personal data based on the legitimate interests of School, and the right to object to the processing for direct marketing purposes.
Right to information and access – to request access to and copy of the personal records. This Notice serves to inform you thereon, but please email if you have any questions.
Right to rectification – to correct inaccurate personal data or to complete incomplete personal data.
Right to erasure – to request the deletion or removal of personal data in specific circumstances, for example if your personal data is no longer necessary for the purposes pursued by the school or if there no longer is a legal ground for the data processing.
Right to restriction of the processing – to limit the processing, e.g. where you have told us the data is inaccurate and we are in the process of checking this. In such circumstances we will continue to store your data but will not process it further until we have checked and confirmed whether the data is inaccurate.
Right to data portability – to receive your personal data in a structured, commonly used format and to transmit it or have it transmitted to another international school.
Right not to be subject to automated individual decision-making – the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Where the processing of your personal data is based upon consent, you and/or your child have the right to withdraw consent at any time. Such withdrawal of consent shall not affect the lawfulness of the processing based on consent before the withdrawal.
There may be instances where you may not want us to process or share your personal information. In these cases, we may not be able to fulfil the service you need, or do so in a limited way, or be able to comply with a statutory obligation. In those instances, we will not be able to comply with your request and we will tell you if this is the case.
For any questions or concerns relating to this Notice or the processing of your personal data by or on behalf of AIHT, as well as for the exercise of any of the rights described in this Notice, please contact the AIHT on info@amboseliinstitute.ac.ke
