ICS Coral Gables (“ICS”) is committed to protecting the privacy of our families, students, employees, alumni, and other individuals about or from whom we collect personal information. We value the trust of those we deal with and of the public and recognize that maintaining this trust requires that we be transparent and accountable in how we treat the information that you choose to share with us.
ICS Coral Gables ensures that all personal information is properly collected, used only for the purpose for which it’s collected, and disposed of in a safe and timely manner when no longer required.
During our various projects and activities, we frequently gather and use personal information. Anyone from whom we collect such information should expect that it will be carefully protected and that any use of or dealing with this information is subject to consent. Consent is given upon signing the ICS Application for Admission, as well as the Student/Parent Handbook Consent Forms/Waiver Package signature page. Our privacy practices are designed to achieve this.
ICS may add, modify or remove portions of this Privacy Policy when it is considered appropriate to do so, and any such changes will be effective upon giving notice of the revised policy.
DEFINITIONS
In this Privacy Policy, the following terms have the meanings set out below:
“personal information” means any information about an identifiable individual. Personal information does not include the position name or title, business telephone number, business address, business email, and business fax number of an individual;
“parent” means the parent, guardian, or other legal representative of a student who has entered into a contract with ICS;
“student” means a prospective, current, or past student of ICS Coral Gables;
“collect” means to gather, receive, or record personal information from any source or by any method;
“use” means the management of personal information by ICS for any purpose;
“disclose” means to make personal information available to, or known to someone outside of ICS;
“record” includes books, documents, maps, letters, papers, photographs, and any other thing on which information is recorded or stored by graphic, electronic, mechanical, or other means.
DEFINING PERSONAL INFORMATION
Personal information is any information that can be used to distinguish, identify, or contact a specific individual. Most of the information that ICS collects comes to the School directly from parents or students or is information regarding a student’s school activities, performance, or behavior, such as attendance records or grades. This also includes information on academic, health, and personal matters needed by the School to provide its students with education and co-curricular programs.
Exceptions: business contact information and certain publicly available information, such as names, addresses, and telephone numbers as published in telephone directories, are not considered personal information.
Where an individual uses his or her home contact information as business contact information as well, we consider that the contact information is business contact information, and is not therefore subject to protection as personal information.
ACCESS
Every individual has the right, upon written request, to obtain an account of personal information that concerns him/her and which is held by the school, and to be informed of how the personal information has been and is being used, and the names of the individuals and organizations to whom it has been disclosed.
ICS will make a reasonable effort to:
- Assist an individual who is requesting personal information;
- Respond accurately and completely to written requests; and
- Provide the requested personal information, or provide an opportunity to examine the information where it cannot reasonably be provided.
Students and Parents of students may access and verify any personal information with appropriate written notice, to allow the office the necessary time to supply the information required. ICS will respond within 30 days of a written request and will make reasonable efforts to provide the personal information requested sooner where possible.
In certain circumstances, ICS may not provide access to all or part of the personal information requested, for example, where disclosure would reveal personal information about another individual, where the information was collected for the purpose of an investigation, or where disclosure would threaten the safety or health of an individual.
In the event that ICS cannot provide access to personal information, it will inform the individual of the reasons why, subject to any legal or regulatory restrictions, and it will inform the individual regarding any available recourse.
PRIVACY PRACTICES
Personal information gathered by ICS Coral Gables is kept in confidence. Our personnel are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it is obtained. Safeguards are in place to ensure that information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent its being lost or destroyed.
PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED
ICS collects and uses personal information to provide students with the best possible learning experience. ICS requires the collection, use, and disclosure of personal information for, but not limited to, the following purposes:
- To communicate with students and parents, process applications, and assess and determine the suitability of a prospective or current student for admission and a particular grade, level, or classroom.
- To administer and provide educational and extra-curricular programs.
- To enable the school to operate its administrative functions, including payment and collection of school fees; administration; billing and accounting; and maintenance of non-educational school programs, including parent and volunteer participation.
- To maintain the smooth operation of building security policies, including sign-out registers and phone calls.
- To communicate with members of ICS staff about physical or emotional health issues that are deemed important for the safety of the student and for the maintenance of a safe and harassment-free environment.
- To monitor the use of ICS facilities, including email and internet use, in accordance with ICS Policies and Guidelines, a copy of which has been provided to each student’s parents.
- To communicate with current and former students and their parents regarding school activities, special events, future plans, and opportunities to volunteer.
- To comply with applicable statutes.
ICS may also use anonymous information, such as information collected through surveys or statistical information regarding students, to constantly improve our school.
Personal information is communicated within ICS only to persons for whom such information is necessary for the performance of their functions and duties.
ICS may provide personal information to outside organizations contracted by the school to perform specialized services such as printing, consulting, market research or data processing. Suppliers of specialized services are given only the information necessary to perform those services, and ICS takes appropriate steps to ensure that such information is securely transferred and stored and is used only to fulfill the purposes for which it was communicated to the service provider.
PROTECTION OF PERSONAL INFORMATION, SERVICE PROVIDER
Personal information stored on School premises is stored in password-protected databases or files that we have secured. Access to personal information is restricted to staff, teachers, and volunteers, who are authorized to use the information for the purposes described in this Policy, have received training in maintaining our privacy standards and applying our privacy policy and practices, and have signed a confidentiality agreement.
We retain third parties to provide us with a variety of services, including mailing houses and information technology service providers. We choose our service providers carefully and impose obligations on them to protect any personal information that they use in the course of providing their services to the School. The security measures required of our service providers may include encryption and maintenance of personal information in secure facilities meeting generally accepted specifications and standards. We require our service providers to adhere to our privacy standards.
DISCLOSURE
Personal information may be disclosed to third parties to enable the school to perform the purposes set out above or in accordance with specific consent obtained in other circumstances, as described below.
DISCLOSURE WITHOUT CONSENT
ICS may, without the consent of the student or the student’s Parent, disclose personal information it holds about the student or student’s Parent in the following circumstances:
- a) as permitted or required by applicable law or regulatory requirements, most often in relation to family court issues, legal proceedings, court orders, or government tax reporting requirements;
- b) to a person responsible for the prevention or detection of a crime or a statutory offense;
- c) to comply with valid legal processes such as search warrants, subpoenas, or court orders;
- d) to a government body that collects such information as part of its functions;
- e) to a person who must act urgently to protect the life, health, or safety of the person concerned or of other individuals;
- f) to law enforcement authorities or investigation agencies when ICS has serious reasons to believe that a fraud or statutory offense may be or has been committed.
In the above-mentioned situations, ICS will endeavor not to disclose more personal information than is required under the circumstances.
WEBSITE AND ELECTRONIC COMMUNICATIONS
Our website, our teaching, learning, and communications platform, are available for the benefit of our families, students, employees, alumni, and those interested in supporting our organization. They are free for use by individual web users.
All personal information, such as e-mail addresses and financial information collected by ICS Coral Gables’ website, is knowingly and specifically supplied to us by the website or user. We use password protocols and encryption software to protect the personal and other information we receive when a product or service is transacted and/or paid for online. We expect that all Internet users are running the latest version of their Web browser and that security features are enabled.
For website users under 18, please be sure to obtain your parent’s or guardian’s permission before you send any information about yourself to us or anyone else over the Internet. We encourage parents to get involved with their children’s online usage and to be aware of the activities in which they are participating.
For website users under 18, please be sure to obtain your parent’s or guardian’s permission before you send any information about yourself to us or anyone else over the Internet. We encourage parents to get involved with their children’s online usage and to be aware of the activities in which they are participating.
Some sections of our website use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how people use our sites. The information generated by the cookie about your use of the website includes your Internet network address. This information will be transmitted to and stored by Google on its servers. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for our website administrators, and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your network address with any other data held by Google. To disable Google Analytics tracking of your usage of our site, you may disable cookies in your browser; however please note that by doing so you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. To learn more, visit the Google Analytics Privacy Overview and Google’s privacy policy. In addition, please see Google Analytics’ currently available opt-outs for the web.
RETENTION
ICS retains personal information to satisfy the purposes for which it was collected, to satisfy its legal obligations, and to protect its interests. ICS will destroy personal information or render it anonymous when the purpose for which that information was collected is no longer being served, and retention is no longer necessary for legal, governmental, or business purposes.
ACCURACY
ICS recognizes that it is important to keep personal information accurate, complete, and up-to-date and will take appropriate steps to ensure that the personal information collected is as accurate and complete as is reasonably required in connection with the purposes for which it was collected, used, or disclosed. Students and parents must report changes in personal information (address, telephone number, etc.) to ICS administration within 5 business days of such change and in writing. ICS does not continually update the personal information it holds regarding a student unless this is necessary for the purposes for which this information was collected.
SECURITY
ICS will protect personal information by security safeguards that are appropriate to the sensitivity level of the information to ensure the confidentiality of the information and to prevent loss, unauthorized access, collection, use, disclosure, copying, modification, or disposal.
The School’s Employees
In the course of daily operations, all personal information is treated as confidential and is only used by ICS employees or disclosed to third parties if needed for the performance of their duties or the execution of their mandates, except where use or disclosure without consent is permitted or required by law. For example, teachers will have access to personal information about students but not your account with the School.
All employees are appropriately educated about the importance of privacy and their obligation to ensure that such information is safeguarded and agree to respect and maintain the confidentiality of personal information which they may handle or have access to in the course of their duties.
Student Files
Student files are stored in secured filing cabinets. Access is restricted to only those employees (teachers, teacher-aides, counselors, secretaries, etc.) who, by nature of their work, are required to see them.
Electronic Security
The school manages electronic files appropriately with passwords and security measures that limit access by unauthorized personnel. The school’s security practices are reviewed periodically to ensure that the privacy of personal information is not compromised.
CONSENT
ICS will obtain students’ and students’ Parents’ consent to the collection, use, and disclosure of personal information except where we are authorized to so do without consent.
Consent can be provided orally, in writing, or electronically, through a Parent.
QUESTIONS, CONCERNS
Any questions or concerns about ICS’ privacy and confidentiality policies and practices should be directed to ICS Coral Gables:
3930 South LeJeune RoadCoral Gables, FL 33134
Telephone: 305-445-8918
Email: info@icscoralgables.com
