Privacy Policy
DATA CONTROLLER:
BROOKHOUSE SCHOOLS KENYA
Brookhouse School, Karen
Magadi Rd
Nairobi, Kenya
Brookhouse School, Runda
Off Kiambu Road
Nairobi, Kenya
Brookhouse Schools (also referred as “the School”) are part of Inspired Education Holdings Limited, which is a company registered in England with number 09268120 and registered address in Sixth Floor, 3 Burlington Gardens, London, W1S 3EP, United Kingdom. Inspired operates numerous affiliated schools globally via its regional offices in Europe, Africa, Middle East, Asia-Pacific and Latin America.
1. INTRODUCTION
This policy is drafted according to the Data Protection Act, 2019 (the “Act”) came into force on 25th November, 2019 and it is created with the aim to provide information to the data subjects about how the School processes the personal data.
2. TYPES OF PERSONAL DATA WE PROCESS
We process personal data from our current and former students and their families and/or legal representatives and also from our employees, candidates, suppliers, contractors, prospective customers and third parties interested in finding out more about our School within the systems controlled by the School as Data Controller.
The personal data processed is mainly the following:
- Names, addresses, telephone numbers, e-mail addresses and other contact details;
- Family details;
- Nationality, language and location;
- Safeguarding information (such as court orders and professional involvement);
- Education and employment data;
- Images, audio and video recordings, including CCTV footage (video images);
- Financial information;
- Educational centres previously attended.
Other types of data we may collect and process, according to the school purposes, are related to health condition, criminal records and other sensitive information related to an individual, such as:
- Information about health status or provision of health care linked to a specific individual;
- Behavioural information;
- Special educational needs;
- Criminal records linked to a specific individual;
- Biometric information;
- Ethnicity;
- Religion;
- Sexual orientation.
3. HOW WE COLLECT AND PROCESS PERSONAL DATA
The School collects information in several ways, including:
- Personally and over the phone;
- Through our website;
- Through cookies used on our website, through which we can collect login data, browsing behaviour, settings and actions in web applications;
- From email and hand delivery paper documentation;
- Through online tools, such as apps, educational platforms and other software used by the School;
- Through any CCTV cameras located at our premises;
- Through third parties, such as referees, professionals or authorities working with the individual;
4. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
The School processes personal data to lawfully and legitimately carry out the school’s educational activity. The school collects and keeps students and parents’ information when necessary:
- Attend your enquiries;
- Ensure that the student meets the School’s admission criteria;
- Provide educational services including the support of pupil learning, monitor and report on pupil progress;
- Offer to the students welfare and pastoral care services;
- Provide to the students medical and nurse attention, school uniform, catering service and bus routes, among other necessary services;
- Meet the educational, social, physical and emotional requirements of the student;
- Celebrate Alumni’s activities;
- Manage Summer Camp activities;
- Enable parents/guardians to be contacted in the case of emergency or in the case of school closure, or to inform parents of their child’s educational progress or about school events, etc.
- Celebrate School’s achievements and to keep a memory of our students. In this case we may take and use photographs and audio-visual recordings to be shared in our websites, social networks, and our yearbooks, always based on informed consent from parents or students of legal age. With your consent, these images can also be shared with Inspired Education Group and used in its global social media.
- Send commercial communications if previously authorised by the data subject. You will be able to unsubscribe from the receipt of commercial communications by clicking in the “unsubscribe” section found in all these kinds of e-mails sent by the School.
The personal data object of processing may only be communicated to other Schools within the Inspired group with the prior written consent of the data subject or when necessary and the personal data will be processed with the same legitimate purposes mentioned herein.n.
5. PROCESSING OF CANDIDATES DATA
If you want to send us your CV through the section “Careers”, you will have to create an account to make use of the employment platform and to send us your employment application. Your information will be shared with Inspired Education Group as the owner of the platform Global Careers Site in the terms exposed at: https://careers.inspirededu.com/data-privacy-statement and incorporated in the files owned by the Brookhouse Schools. Our Human Resources department will process your data with the purpose to include your candidacy in our selection processes.
6. LEGAL BASIS FOR DATA PROCESSING
The legal basis that supports the collection and processing of your data are the following:
- Execution of a contractual relationship of which the data subject is a party: The admission and registration of students, the provision of educational, academic, nursing, safeguarding and other related services, as well as the sending of communications relating to teaching activities and the administrative and billing management necessary for the provision of the aforementioned services;
- Compliance with our legal obligations: We must manage and maintain the data of students' parents, employees and suppliers to comply with the legal requirements of the relevant authorities, including the management of legal claims;
- Our legitimate interest: We may need to process statistical information from our School to carry out satisfaction surveys, and / or to modify the functioning of our school in addition to promote our activities by sending commercial communications (always under your consent);
- Vital interest: If we have to protect someone’s life or health, we will take immediate action to preserve them;
- Your consent: We may need the consent of the parents/legal guardians or the student over legal age to send commercial communications, as well as for the creation and use of images and videos to disclose the student's participation in our activities. school or for promotional campaigns.
7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
As a School, we may be lawfully required to share personal information with relevant authorities or third parties as permitted on statutory grounds, to comply with legal obligations or on the basis of a specific consent given by the individual concerned.
In the case of summer camps or other educational or extra-curricular activities, your data may be communicated to third parties involved in the rendering of the services.
We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing them to a third party.
Out of the cases previously described, no data will be communicated to third parties.
8. INTERNATIONAL DATA TRANSFER
In the event that, when necessary for the execution of the educational contract (which could include the use of computer tools and platforms offered from outside of Republic of Kenya), and / under other legal basis, personal data may need to be transferred to countries outside Republic of Kenya, to other countries that may offer a lower level of data protection. In these cases, we will implement the necessary measures to ensure adequate protection of your personal data in accordance with Data Protection Act, 2019. Likewise, parents / legal guardian or the student over legal age will be clearly and correctly informed. We will also collect the corresponding consent for such transfers to non-adequate countries when required by the specific exemptions stipulated in the regulations.
Your personal data shall be neither rented nor sold to third parties under any concept.
9. CONSERVATION OF DATA
Personal information will only be retained for the period required to fulfil the purpose for which it was collected unless for a longer time for public interest archiving, scientific or historical research, or statistical purposes. Once the personal information is no longer required or permitted to be retained for legal or business purposes, it will be safely destroyed or made anonymous.
10. YOUR RIGHTS
You can exercise your rights regarding the processing of your personal data. These rights are, however, subject to certain legal exemptions and limitations.
You have the right to:
- Be informed, at the time when personal data is collected, about the data we are processing about you;
- Access the information we process and how we process it as well as to obtain a copy of the personal data considering the legal limitations and exceptions;
- Obtain the correction of your personal data providing a supplementary statement;
- Ask for the deletion of false or misleading data about you;
- Object to processing for direct marketing purposes.
The School will reply to your request without undue delay from the receipt of your request according to the legal terms.
You can exercise your rights by sending a written request together with your ID card to our Data Protection Officer at: dpo@brookhouse.ac.ke.
11. CONSENT
You will have the right to withdraw your consent for any specific purpose granted at any given time without prejudice of the legality of processing according to the consent given before withdrawal.
12. STORING AND SECURING INFORMATION
The School applies the appropriate technical and organisational measures to ensure the security, confidentiality, integrity and privacy of your personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the data.
13. COMMON USE WITH SOCIAL NETWORKS
This website contains links to other websites such as social networks like Instagram, Facebook, and LinkedIn. Our School is not responsible for the privacy practices or the content of such sites. You should be aware that the processing of your personal information is carried out by those sites and governed by their respective privacy policies.
If you do not want these sites to collect and process your information, please review their corresponding privacy policies and / or disconnect from it before using our Services.
14. COOKIES USED IN OUR WEBSITE
We use cookies to provide you with a better experience in the use of our website, as well as to store information about our visitors. This information is related to your session ID and are a way of monitoring single user access.
The Web server is allowed to remember some data concerning the user, such as his preferences for visiting the pages of this server, name and password, products that are more interesting, etc.
The Cookies that we use in our website and that require informed consent by the user are the functional cookies and the targeting cookies. Consent is not required for required cookies, which are those of a technical nature necessary for the operation of the website or the provision of services expressly requested by the user.
You can find more information about our Cookies policy at: https://www.brookhouse.ac.ke/cookie-policy.
15. COMPLAINTS
If you are not satisfied with our response to your request, you would like to discuss anything regarding this privacy notice, or you believe we are processing your personal data disregarding the data protection regulations in force, please contact our Data Protection Officer at: dpo@brookhouse.ac.ke or you can address your complaint to the Office of the Data Protection Commissioner (DPC) at: https://www.odpc.go.ke/file-lodge-a-complaint/ although the Authority recommends that previous steps must be taken to resolve the matter with our School before involving the Authority.
16. PRIVACY NOTICE UPDATES
The School may need to update this privacy notice periodically so we recommend that you review this information from time to time.
This version was last updated in April 2024