Privacy policy

Privacy policy

The confidentiality and security of your data is important for EFGH. 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 February, 15, 2019.
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 will store and handle that data, and keep it safe.

Who we are

EFGH is a non-profit organization registered in Houston, Texas, USA with its registered office address at 14119 Swallowfield Dr, Houston TX 77077.

When collecting your personal data, we will 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 organization 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 pictures 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, contact details and address)
  • characteristics (such as language, and citizenship)
  • medical (such as allergies, medication)
  • 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 admin portal and our marketing campaigns distribution lists to receive our newsletters.

Student data is essential for EFGH’ operational use. Whilst the majority of student information you provide to us is mandatory, some of it is 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 the information is on a voluntary basis.

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 unauthorized access. Any payment transactions will be encrypted.
Where we engage third parties to process personal data on our behalf, they :

  • must comply with the requirements of data protection laws ;
  • must 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 organizational 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 fulfill 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 unauthorized 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 could share global information (statistics) with :

  • the Department for Education of the French Embassy
  • the AEFE
  • 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.
The Department for Education of the French Embassy collects general data from educational settings.

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 info@efghouston.org

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 us at info@efghouston.org.
This privacy notice was last updated on February, 15 2019.