BACKGROUND

Silverline Private School is a fully inclusive private school which is approved and fully licensed by the Cyprus Ministry of Education and Culture for the provision of education from Kindergarten to Secondary school age. We are an international school delivering the English National Curriculum to Kindergarten, Primary and Secondary students. Education in our Secondary School culminates in students taking IGCSE, A/S & A level qualifications through the Pearson Edexcel examination board, for which we are a centre. Furthermore, a formal School Leaving Certificate (Apolytirion) is issued to each child, on graduation at the end of Year 13. Welcoming children from a wide variety of backgrounds and as an examination centre for Pearson Edexcel, we take our responsibilities, as data controllers, extremely seriously and are committed to using, storing and sharing the personal data we hold in accordance with the law.

Our Privacy Policy complies with the General Data Protection Regulation (GDPR) 2016/679, and it provides in-depth information about the way in which personal data is processed by the school. It is important that you read it carefully and contact our  the Data Protection Officer with any questions with regard to your personal data or its use by email on dpo@silverlineschool.com, by telephone on +357 25 716 361 or by post at DPO, Silverline Private School, 4A Griva Digheni, 4651, Limassol, Cyprus.


TYPES OF PERSONAL DATA PROCESSED BY SILVERLINE PRIVATE SCHOOL

We process personal data about prospective, current and former pupils and their parents or guardians, members of staff, suppliers and contractors, friends and supporters of the school and other individuals connected to or visiting the school, including summer school students.

The school process different types of data, including:

  • names, addresses, telephone numbers, e-mail addresses and other contact details
  • family details
  • admissions, academic, disciplinary and other education related records
  • information about special educational needs
  • references, transcripts and grades
  • education and employment information
  • photographs, audio and video recordings
  • financial information
  • details of courses, meetings or functions/events attended

Special category personal data, for example information relating to health or ethnicity, is processed by the school, in accordance with applicable law or by explicit consent.


COLLECTING, HANDLING AND SHARING PERSONAL DATA

The majority of the personal data we process is collected directly from the individual concerned or, in the case of pupils, from their parents or guardians. In some cases, we collect data from third parties (for example, referees, previous schools or professionals or authorities working with the individual) or from publicly available sources.

Any personal data held by Silverline Private School is processed by appropriate members of staff for the purposes for which it was provided. We take sufficient measures to ensure that the personal data is stored in a secure place. The school does not transfer personal data beyond the European Union unless we are satisfied that it be given the same amount of protection.

In the course of the academic year, we share personal data (including special category personal data, where appropriate) with third parties such as examination boards, and relevant authorities (e.g. Ministry of Education and Culture, Welfare Office, Statistics Office, Immigration Department, Tax Department, Department of Social Insurance). Some of our systems are provided by third parties, e.g. hosted databases, school website, cloud storage providers. This is always on the understanding and subject to contractual assurances that personal data will be kept securely and only in accordance with the school’s instructions. We maintain personal data about Silverline Private School alumni. We do not share or sell personal data to other organisations.


REASONS FOR WHICH PERSONAL DATA IS USED BY SILVERLINE PRIVATE SCHOOL

Personal data is processed by us to support the operation of Silverline Private School, as a school registered by the Cyprus Ministry of Education and Culture, and in particular for:

  • the selection and admissions process
  • the provision of education to pupils
  • administration of the school curriculum and timetable
  • monitoring student progress and educational needs
  • reporting progress and needs both internally and to parents or guardians
  • administration of pupils sitting both internal and external examinations
  • reporting on and publishing examination results
  • the provision of references for pupils, even after they have left the school
  • the provision of educational support
  • provision of career counselling
  • provision of library services
  • administration of sports teams and school trips
  • the provision of the Silverline IT and communications system and monitoring of the same, in accordance with our IT Policy
  • the provision of educational coursesto pupils during school holidays
  • the safeguarding of students’ welfare and provision of pastoral care, welfare and healthcare servicesby school staff
  • the research into and development of effective teaching and learning methods and best practices
  • compliance with legislation and regulations,including the preparation of information for inspections, submission of information to the Cyprus Ministry of Education and Culture and other government departments
  • the compilation of student records
  • the administration of invoices, tuition fees and accounts
  • the management of security and safety provisions, including the use of CCTV in accordance with our CCTV Policy and monitoring of the school’s IT and communications systems in accordance with our IT Policy
  • management planning and forecasting
  • research and statistical analysis
  • the administration and implementation of the Silverline policies for parents, students and staff
  • the maintenance of archives
  • staff administration,including the recruitment of staff and/or engagement of sub-contractors
  • administration of payroll, pensions and sick leave
  • review and appraisal of staff performance
  • disciplinary procedures
  • the maintenance of appropriate human resources records for current and former staff
  • the provision of references
  • the promotion of the schoolthrough its own website, the prospectus and other publications and communications, including our social media channels
  • maintaining contact with Silverline Alumni and the wider school communityby communicating with the body of current and former students and/or their parents or guardians
  • organising events

The processing of personal data set out above is carried out to fulfil our legal obligations, including those in our student/parent contract and staff employment contracts.


FUND-RAISING

We raise funds from individuals, companies and foundations who want to support our events. Although we do not use third-party profiling companies, we may look at publicly available data about potential donors in order to make appropriate requests.

We keep in touch with Silverline Alumni, current or former parents or other members of the school community.


PERSONAL DATA RETENTION

We retain personal data only for a legitimate and lawful reason and only for so long as necessary or required by law and the Cyprus Ministry of Education and Culture and the Cyprus Military. If you wish that your personal data be considered for deletion, please contact the Data Protection Officer.


YOUR RIGHTS

You have rights under GDPR to access and understand the personal data we hold about you.  Subject to certain limitations, you may ask for it to be altered or even removed.

You reserve the right to withdraw consent which has been previously given or otherwise object to receiving generic or fundraising emails or letters. However, please note that the school may have another lawful reason for processing the personal data in question, even without your consent. That reason will usually have been made clear under this Privacy Policy or may exist under a separate contract or agreement with the individual (e.g. an employment or parent contract, or as a result of a purchase of goods or services).

If you would like to access or amend your personal data or object to how your personal data is being used, please make your request in writing to the Data Protection Officer.

We will respond to any such written requests as soon as possible and in any event within statutory time-limits, which is one month in the case of requests for access to information. We will be better able to respond quickly to smaller, targeted requests for information. If the request excessive or similar to previous requests, we may ask you to reconsider or charge a proportionate fee, but only where it is allowed by GDPR.

Please note that some data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal privilege. We are also not required to disclose any student examination scripts (although examiners' feedback may be disclosed), nor any confidential reference given by the school for the purposes of the education, training or employment of any individual.


STUDENT DATA

Under Data Protection legislation, the rights of personal data belong to the individual to whom the data relates although the school often relies on the consent of the parent or guardian, where consent is required. Depending on the nature of the processing in question, and the student's age maturity and level of understanding, it is sometimes more appropriate to rely on the pupils’ consent. Parents should be aware that in such situations they may not be consulted.

We work on the assumption that pupil consent is not required for ordinary disclosure of their personal data to their parents, for example for the purposes informing parents about the pupil's progress and behaviour, and in the interests of the student's welfare, unless, there is a good reason to do otherwise.

Disclosure of personal information may also be made in the event that the school believes that this is in the best interests of the pupil or other pupils or is required by law.

Pupils may make subject access requests for their own personal data, provided that they are mature enough to comprehend their request.  A person with parental responsibility will generally be entitled to make a subject access request on behalf of a pupil. However, but the information is always considered to belong to the child by law. A pupil of any age may ask a parent or other representative to make a subject access request on their behalf. Furthermore, depending on the age and maturity of the pupil, parental request may require the consent or authority may need to be sought by the parent making such a request.


CHANGES TO DETAILS

We try to ensure that all personal data held is as up to date and accurate as possible.  Please notify dpo@silverlineschool.com of any changes to important information, such as contact details.


THIS POLICY 

Our Privacy Policy should be read in conjunction with our other policies and terms and conditions.

This Privacy Policy will be updated from time to time. You will be informed directly of any substantial changes that affect how we process your personal data. These changes will also be posted on our website.

As a data subject, you have the right to address any concerns you may have regarding your data protection rights to the School’s Data Protection Officer by sending an email to dpo@silverlineschool.com

Any complaints you may have relating to any violation of your rights under the GDPR may be lodged with the relevant supervisory authority in Cyprus:

Officer of the Commissioner on Personal Data Protection
1, Iasonos Str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: +357 22818456, Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
http://www.dataprotection.gov.cy