Privacy and Personal Information Policy
1. Purpose and Objectives
1.1 Yeremyan Academy (YA) is bound by Personal Data Protection Law of the Republic of Armenia (2015). This policy outlines how YC uses and manages personal information provided to, or collected by YC.
2.1 This Policy relates to the collection, storage, use and disclosure of personal information by YA, and applies to all staff, students – past and present, parents, guardians, agents, teachers, employers, and industry partners.
Throughout this policy the following definitions apply:
‘Personal information’ information or an opinion about an identified or reasonably identifiable individual, whether true or not and whether recorded in a material form or not;
‘Sensitive information’ information or an opinion about the ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices or criminal record that is also personal information, or health information, genetic information, biometric information or biometric templates of an individual.
4.1 Collection of Personal Information
4.1.1 YA may collect personal information, including sensitive information, about:
· students and parents and/or guardians;
· potential students;
· former students, graduates and alumni;
· staff members, volunteers and contractors;
· potential employers and industry partners;
· agents, school professionals and other people who come in contact with YA.
4.1.2 YA endeavors to collect personal information that is up-to-date, relevant and complete in a reasonably un-intrusive manner.
4.1.3 YA will generally collect personal information by way of forms filled out by parents or students, in face to face meetings, during interviews, via telephone calls and email enquiries.
4.1.4 In some circumstances, YA may obtain personal information about an individual from a source other than the individual, for example, from a report provided by a medical professional, an agent, another school or, industry newsletter and journals.
4.2 Use of Personal Information
4.2.1 YA will use personal information it collects for the primary purpose of
· communicating with potential students, students and graduates, and potential employers and industry partners;
· maintaining student records as per legislative requirements;
· fulfilling legislative and regulatory requirements with respect to data collection and provision to government and regulatory bodies;
· responding to queries or requests for information;
· providing education and related services.
4.2.2 YA may also use personal information it collects for such other purposes that are related and are reasonably expected, or for which consent has been obtained at the time of collection.
4.3 Students and parents
4.3.1 The purposes for which YA uses personal information of students and parents include:
· to keep students informed about matters related to them and their studies, through correspondence, newsletters and magazines;
· day to day administration of the school;
· looking after a student’s educational, social and medical wellbeing;
· marketing for the school;
· satisfying our various legal obligations, particularly in the case of student welfare.
4.3.2 YA may not be able to enroll or continue the enrolment of a student if necessary personal information about the student and/or parent or guardian is not provided as per the relevant YA forms.
4.4 Job applicants, staff members and contractors
4.4.1 In relation to personal information of job applicants, staff and contractors, YA’s primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor, to maintain adequate personnel and professional development records and to comply with statutory requirements.
4.4.2 The purposes for which YA uses personal information of job applicants, staff members and contractors include:
· administering the individual's employment or contract;
· satisfying insurance requirements;
· marketing for the school;
· satisfying the school’s legal obligations.
4.5 Agents, Teachers, Employers, Potential Employers and Industry Partners
4.5.1 YA maintains records of employers who accept students as part of the cooperative education process, and vocational education professionals who partner with YA, to provide to students quality advice and material to support career choice. Printed material of interest to prospective students and other promotional material is distributed to education professionals and to industry partners to ensure that YA continues to offer a quality learning environment engaged with industry.
4.5.2 YA publications, such as newsletters and magazines, may incorporate personal information such as images. YA will obtain an individual's consent before using their image in a publication.
4.6 Disclosure of Personal Information
4.6.1 With consent, YA may disclose personal information, including sensitive information, held about an individual:
· to government departments;
· to medical practitioners;
· for the purposes of publication in newspaper, newsletters and magazines;
· to potential employers and industry partners;
· to parents and guardians;
· to anyone else an individual authorizes the school to disclose information to.
4.6.2 YA may also disclose personal information to certain contractors or subcontractors that provide administrative, promotional or other services to YA.
4.6.3 Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.
5.1 Management and Security of Personal Information
YA staff are required to observe the confidentiality of personal information provided by students, parents and guardians, as well as the privacy of individuals. YA has in place steps to protect the personal information YA holds from misuse, loss, unauthorized access, modification or disclosure by use of various methods including locked storage of paper records and password protected.
5.2 Computer Usage
Computer facilities are provided on YA sites for student use. While YA’s interest is to prevent illicit, illegal and excessive usage, students should be aware that YA and/or its delivery partners may monitor computer usage including the sites visited and the items downloaded.
5.3 Updating Information
YA endeavours to ensure that the personal information it holds is accurate, complete and up-to-date; YA may be required by legislation to seek updates regularly from students in respect to the accuracy of the personal information regarding them. Students will be advised during Orientation of the processes for updating personal information.
Access to Personal Information
5.3.1 An individual may request access to any personal information which YA holds about him or her and advise YA of any perceived inaccuracy. Such requests and enquiries can be directed to firstname.lastname@example.org YA may require verification of identity prior to providing access to personal information. In some circumstances access may be denied. Such circumstances include where YA considers that the release of the information would have an unreasonable impact on the privacy of others, or where otherwise permitted by law.
5.3.2 YA will take reasonable steps to ensure that the personal information that is collected, used and/or disclosed is accurate, up-to-date and complete. If YA is satisfied that any personal information held is inaccurate, out-of-date, incomplete, irrelevant or misleading, YA will amend its records accordingly. If an individual believes that a breach of his or her privacy has occurred, YA encourages that individual to contact YA at email@example.com to discuss any concerns. All complaints will be considered and dealt with by our Manager. Our Manager may escalate the complaint internally within YA 's organisation if the matter is serious or if necessary to resolve it.
5.4 Access by Third Parties to Personal Information of Others
Students may authorise their parents or guardians or other parties to have access to their personal information. Where a request for access to personal information is made by a third party, YA will seek consent from the relevant student, unless disclosure of personal information is required or permitted by law.
Generally, YA will refer any requests for consent and notices in relation to the personal information of a student to the student alone. In such cases, information will not be released without specific approval from that student.
5.5.1 Collection and Use of Information
5.5.2 In order for an individual to obtain information about YA, to register on a mailing list, or to proceed with an paper application for an YA course, certain personal information (and credit card information where necessary) may be requested.
YA strives to take reasonable technical measures to prevent loss or unintended use or disclosure of information held by YA.