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Personal Data Protection Policy

Purpose of this policy

The purpose of this document is to inform you of Lycée Français de Singapour (LFS)’ policies on data collection, usage, disclosure, processing and protection, which are subject to the Singapore Personal Data Protection Act 2012 (“PDPA”). This Act recognises both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.

The PDPA takes into account the following concepts:

- Purpose – Organisations may collect, use or disclose personal data in an appropriate manner for the circumstances, and only if they have informed the individual of purposes for the collection, use or disclosure;
- Consent – Organisations may collect, use or disclose personal data only with the individual's knowledge and consent (with some exceptions);
- Reasonableness – Organisations may collect, use or disclose personal data only for purposes that would be considered appropriate to a reasonable person in the given circumstances.

Data Collected and Purpose

LFS is collecting and may use student’s personal data (such as name, date of birth, photos, educational background, medical records) for the following purposes (list below not exhaustive):
- Regulatory Compliance (i.e. Compliance with the Singapore Ministry of Education, Agence pour l’Enseignement Français à l’Etranger (AEFE), Immigration and Check point authority (ICA), filing and other statutory filing, and Taxation etc.),
- Scheduling of courses and publishing students’ results,
- General Administration/Operations (i.e. Project management, Work-related/teaching-related communication),
- Educational Background (i.e. Awards/recognition certifications received, Educational attainment, and Schools attended),
- Student Registration (New enrollment, withdrawal/cancellation),
- Communication with parents and guardians (parents’ representative’s emails, teacher’s emails, crisis communication),
- School trips (i.e. Planning & logistics, Medical requirements, Dietary requirements, Registration),
- Registration for ECA (Extra-curriculum activities) events,
- Medical needs (i.e. allergies),                                               
- Pedagogical classroom activities,
- Class photos
- Registration for Transit Link,
- Insurance coverage.

LFS is collecting and may use students’ family members/guardians’ personal data (such as name, date of birth, e-mail, phone, bank particulars) for the following purposes (list below not exhaustive):
- Communication with parents and guardians (through parents’ representatives, teachers, School Management and administration),
- Medical needs, in case of emergency (i.e. to contact relatives in case of accidents and major risks),
- School trips (i.e. Planning and logistics, Medical requirements, Dietary requirements, Registration),
- Fundraising for School purposes,
- Billing and fee payment processing (i.e., Billing of school fees, Final settlement and payment history, Fee payment processing).


Subject to express consent in the “Legal Authorisations” form, LFS may:
- Give parent’s email address to the Parents Commission, Parent Representatives and LFS Orientation Department.
- Use student’s personal data (name, picture(s), film etc..) exclusively for non-commercial purposes, including:

- Internal uses: school reports, flyer, poster, yearbook, pedagogical projects etc…
- External uses: Agency for French Education Abroad, school’s Website, social networks and documents presenting the school etc…

Consent

Parental Consent

For the purpose of school students in grades up to and including “Terminale”, parental consent is sufficient.
LFS will collect and use personal data about students and students’ parents/guardians in accordance with Personal Data Protection Act (2012). Consent to LFS using such data as set out above can be given in the LFS’ Student Contract and Legal Authorisation Form.

Implied Consent

Where a person has made a free decision to opt in to a situation or process where the collection or use of personal data can be reasonably expected, then implied permission can be assumed. This includes:
- Student Admissions Applications
- CCTV on campus
- Events organised by LFS

Management and Care of Personal Data

Protection of Personal Data

LFS undertakes to:
- Implement appropriate security measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular when the processing of data involves the transmission or storage on or within a network; and
- Notify data subjects about any accidental or unauthorised access of their data that may lead to damage or harm.

Right of Access, Correction and withdrawal

Individuals have a right to see the data held about them (subject to the exemptions listed below) and to request for data to be corrected if it is incorrect. Parents will be provided access to data held about their children whilst they are students at LFS within the limitations of this policy.
To request data or for data to be changed that you do not have edit rights to, please file this request form: and send the original signed version to the admission department.
The school will consider the request and respond within four working days. The response may be to decline the request with reasons or to provide a time scale in which the data will be supplied.
The Legal Authorisation Form is submitted to you every year, along with the Student Contract. However, should you want to change your answers (in order to give or withdraw your consent on one or several items) during the School year, please contact our Data Protection Officer: dpo@lfs.edu.sg

Exemptions to Right of Access


The PDPA does not provide the right of access to any and all information held by an organisation. Therefore LFS retains the right to refuse access to:
- Opinion data kept for evaluative purposes
- Examination papers or the results of examinations
- Confidential references written to support a student's application to other educational institutions or courses
- Data or material that would provide personal data about other individuals in contravention of this policy or the PDPA.

Data Retention & Removal

LFS shall take reasonable effort to destroy or anonymize documents containing Personal Data as soon as it is reasonable to assume that:
- The purpose for which the Data was collected is no longer being served by retention of the Data; and
- Retention is no longer necessary for legal or business purposes.

Sharing Data with Third Parties

Personal Data may be disclosed by LFS to its third party service providers or agents in Singapore (such as travel agents, insurance companies and data hosting companies) for one or more of the Purposes. Personal Data may also be disclosed to some schools outside of Singapore or to the French Ministry of Education or any other institution under its responsibility which may be located outside of Singapore, for one or more of the Purposes.

LFS will only share data for the purposes of eliciting a necessary service from these third party organisations and not for commercial gain.
LFS signs contracts to ensure that the organisation is using the data purely for the intended purpose of providing the required service and that it is taking appropriate precautions to safeguard the data.
In some instances, for example for online services, explicit signed contracts do not exist. In these instances LFS will ensure that the terms & conditions of the service include clauses that:
- LFS remains the owner of the data.
- The service provider is not entitled to use any data held on its service for any purpose other than to provide the required service.
- The service provider is taking reasonable precautions to ensure the security of the data.
- Once LFS terminates its agreement with the service provider, that any and all data held will be deleted and not used for any other purpose.

Contact

In the event of any queries or complaints in relation to data protection, please contact our Data Protection Officer: dpo@lfs.edu.sg  

 



 

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