PhilaFLAM enables bilingual children to enrich their French and their culture in a welcoming environment open to all, in a climate of trust. We are also attentive to the confidentiality and security of your data when you use our site.
As part of the amendments to the European Union’s data protection legislation, we have made changes to our Privacy Policy, the new version of which comes into force on May 25, 2018.
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how PhilaFLAM uses your data; for example we will explain things such as the legal reason for processing your personal data and how we ensure that your data is protected.
As the charity delivers a wide range of service, in addition to the information on our website, in some cases we are providing additional information about how we use data, for example to our members and parents that use our settings. We hope the following information will answer any questions you have but if not, please do get in touch with us.
Who we are
PhilaFLAM is a non-profit organization registered in Pennsylvania and New Jersey, with its registered office address at 575 W Valley Road, Wayne PA 19087.
When collecting your personal data, we’ll always make it clear to you, which data is necessary in connection with a particular service.
The law on data protection sets out a number of different reasons for which an organisation may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent.
For example when you tick a box to receive email newsletters, or when we send you certain marketing information. We will only send you our newsletter for as long as you continue to consent.
We also rely on consent when you allow us to take images of your child.
How we use student and parent information
The categories of student information that we process include:
- personal identifiers and contacts (such as name, unique student number, contact details and address)
- characteristics (such as language, and nationality)
- special educational needs(including the needs and ranking)
- medical and administration (such as insurance information, allergies, medication and dietary requirements)
- attendance (such as sessions attended, number of absences, tardies and any current and previous schools attended)
- assessment and attainment
Why we collect and use student information
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, where we have child protection concerns we are obligated to pass the information on to law enforcement and the relevant department within the Local Authority.
Legitimate interest
We collect and use student information, for the following purposes:
- to support student learning
- to monitor and report on student attainment progress
- to assess the quality of our services
- to keep children safe (food allergies, or emergency contact details)
- to meet the statutory duties placed upon us for GDPR data collections
We may also email you after your enquiry in order to follow up on your interest and ensure that we have answered it to your satisfaction.
You may be able to participate in research and surveys.
How we collect student information
We collect student information via our registration form, the parent portal, the teacher portal and blog, the admin portal and our marketing campaigns distribution lists to receive our newsletters.
Student data is essential for PhilaFLAM’ operational use. Whilst the majority of student information you provide to us is mandatory, some of it requested on a voluntary basis. In order to comply with the data protection legislation, we will inform you at the point of collection, whether you are required to provide certain student information to us or if you have a choice in this.
How do we protect your data
We take the security of your personal data seriously. We have internal policies and strict controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed and to prevent unauthorised access. Any payment transactions will be encrypted.
Where we engage third parties to process personal data on our behalf, they:
- are obligated to comply with the requirements of data protection laws;
- are obligated to only use the data for the purpose/s for which it was supplied;
- are under a duty of confidentiality; and are required to implement appropriate technical and organisational measures to ensure the security of your data.
Where do we store your data
All data you provide to us is stored on secure computers or servers located within the USA. We may also store paper records in locked filing cabinets or locked cupboards.
Your credit card details are passed to a third-party payment processor. We do not retain your payment information.
For how long do we keep your data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Who we share student information with
We sometimes share student information with:
- Our local authority (only where applicable)
- The Department for Education of the French Embassy
- The AEFE
- Schools that the students attend after leaving us
- Banking services to process payments
- Our insurance underwriter (only where applicable)
Why we share student information
We do not share information about our students with anyone without consent unless the law and our policies allow us to do so.
The information shared is limited to the child’s name, nationality, address and date of birth. However where a parent or guardian provides their consent, other information relevant to the provision of youth support services will be shared.
The Department for Education of the French Embassy collects personal data from educational settings. We are required to share information about our students for the purpose of those data collections, for school census.
Your rights
As a data subject, you have a number of rights. You can:
- request to access and obtain a copy of your data on request;
- request that we change incorrect or incomplete data; and
- request that we delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
Where we rely on consent to processing your personal data you can request to withdraw your consent at any time for example, you may choose to stop receiving one of our newsletters by clicking the unsubscribe link in any e-mail we send to you.
If you would like to exercise any of these rights, please contact our DATA PROTECTION OFFICER at contact@philaflam.com
You also have the right to:
- object to processing of personal data that is likely to cause, or is causing, damage or distress
- prevent processing for the purpose of direct marketing
- object to decisions being taken by automated means
- in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
- a right to seek redress, either through the CNIL, or through the courts
Changes to this notice
We keep this notice under regular review. Any changes to this notice will be posted on our website, so that you may be aware of how we use your data at all times.
If you have a concern or complaint about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the CNIL https://www.cnil.fr/fr/tag/gdpr
Contact
If you would like to discuss anything in this privacy notice, please contact the PhilaFLAM Executive Director at contact@philaflam.com
Date of this privacy notice
This privacy notice was last updated on 24 May 2018.