Escuela del Sol Privacy Policy

Introduction
Escuela del Sol Montessori, Inc. (Escuela) takes the privacy of our constituents seriously and wants people of all ages to feel comfortable participating in our school and our community art center. This privacy policy deals with personally identifiable information (referred to as “data” below) that may be collected. This policy does not apply to other entities that are not owned or controlled by Escuela, nor to persons that are not employees or agents of ESCUELA.

Definitions
Personal data: any data that could be used to identify an individual, including but not limited to names, any contact information, birthdates, and photographs.

Consent:The privacy of a student under the age of 13 when engaging with online websites that collect a student’s personal information is governed by the Children’s Online Privacy Protection Act (“COPPA”). COPPA applies to operators of websites directed to children under the age of 13, that collect, use, or disclose personal information from children and requires parental consent before collecting personal information from the child. The law allows schools to consent to the collection of personal information on behalf of parents when the website collects such information solely for the use and benefit of the school and for no other commercial purpose.

DPO - Data Protection Officer, responsible for compliance with applicable laws and regulations, as well as best practices on data security.

HIPAA - Health Insurance Portability and Accountability Act of 1996, which outlines specific rules for handling personal data relating to health care.

COPPA - Children's Online Privacy Protection Act (COPPA) of 1998, which governs the collection and use of the personal data of minor children.

GDPR - General Data Protection Regulation 2016/679 regulates data protection and privacy for all individuals within the European Union and the European Economic Area, even if the service provider lies outside the EU. Although Escuela is not subject to this regulation, it is now considered the gold standard for conscientious handling of personal data.

FERPA – The Family Educational Rights and Privacy Act, which protects the privacy of student education records.

1. Collection of Data
Data collected is used to answer questions, keep in touch with constituents, for program registration purposes and for product marketing and fundraising that benefit ESCUELA. As on many websites, the ESCUELA site may also automatically receive general information that is contained in server log files, such as your IP address and cookie information.

With consent, we collect and retain personal data from our staff, board members, donors, community artists, students, parents, campers, visitors, and users of our online properties, including our website, newsletter, and social media pages.

Collecting Personal Data from Minors
Escuela recognizes that while minor children can give assent to the use of their personal data, unemancipated minors under the age of 17 years can not give legal consent to the use of their data, and we require parental consent for use for all data collected from constituents under the age of 18.

Escuela respects the privacy of both children and their parents and does not collect any more personal information than reasonably necessary. We collect information online through a third party service, SchoolCues, and retain a privacy policy from that company (https://www.schoolcues.com/Privacy.html). With respect to our online information collection practices regarding children (and, specifically for the purposes of COPPA compliance, children under 13 years of age), Escuela collects the following types of personal information directly from parents registering online to participate in school or camp: personal information regarding the parents, guardians, family members and other parties associated with their students (e.g. physicians, emergency contact, authorized pickup etc.) This information may include, but not be limited to, employment, insurance, medical, financial and contact information.

Sawyer
https://www.hisawyer.com/privacy

Parental Review
Parents can review and amend the information that we have collected from their children in SchoolCues, prevent the further use or maintenance of such information, or request the deletion of their children’s personal information by:

  • Calling us at the telephone number provided above
  • E-mailing us at the above address
  • Writing to us at the above address
  • Contacting us via the appropriate contact links on our website at escueladelsol.org

2. Use of Data
Data may be used to customize and improve your user experience on the Escuela website (escueladelsol.org) or the Harwood Art Center website (harwoodartcenter.org). In the event you choose to use links that appear on these websites to visit other websites (such as SchoolCues, Wufoo, FAST Tuition Assistance application, Sawyer or Google forms), you are advised to read the privacy policies that appear on those websites.

Use of Data Collected From Minors
The information we collect from children is used:

  • For fulfillment of a requested transaction
  • For record keeping related to the conduct of school, camp or classes
  • To respond to children’s specific requests related to school, camp, or classes

3. Securing and Retaining Personal Data
The Escuela DPO assumes responsibility for securing this data, whether it exists in print or electronic formats; and securely destroying the data when it is determined to no longer be of use. Escuela retains personal data records for a minimum of three years. The DPO also serves as the point of contact for individuals wishing to know what personal data we are collecting and retaining on them; to destroy records of personal data; or to suppress the processing of specific personal data.

Personal data relating to health care (such as emergency medical forms required for travel, or requests made in relation to Individualized Education Plans) that is held in the cloud on a third-party platform will be retained for the duration of the period of enrollment, then destroyed. Medical information for adults will be kept sealed unless there is a medical emergency where the adult cannot give consent for treatment. All medical records, for minor children and adults, will be handled in compliance with HIPAA and with COPPA. Escuela retains all student and family data as hard copies and in an offline database with limited access.

4. Sharing Personal Data
Escuela does not share any personal data with outside entities unless legally required. If you do not want your personal information shared within the school community (such as with other parents in your child’s class), please make that request in writing to the school administrator.

Third party handling of data
Escuela stores or shares some personal data with third party services (including SchoolCues, MailChimp, MRX, Google, Sawyer and FAST Tution Assistance) and also collects personal data, with consent, through some third party services (SchoolCues, Sawyer). Review of these services’ policies affirms a commitment to privacy that meets our own standards. Escuela keeps all current third party privacy statements on file and these are available on request.

Escuela will not share your information with third parties unless your consent is obtained, such as when you choose to opt-in or opt-out from the sharing of data; however Escuela may be required to share information pursuant to a law enforcement request. Escuela will never sell your personal data.

Sharing Minors’ Personal Data
Escuela does not allow outside organizations to use personal information Escuela collects, except as noted herein.

With respect to sharing information, no other party has access to a child’s personal information beyond those who may be entering the registration information (e.g., parents, teachers, counselors, etc.); and those who provide technical support for the internal operations of the Escuela website or affiliated third party sites. All third parties with whom Escuela shares information have agreed to maintain the security and integrity of such personal information.

Please note that parents may consent to the above collection and use without necessarily consenting to the disclosure of personal information to third parties. If you have concerns about Escuela sharing your minor child’s data, please send us a written request by email or mail.

5. Editing or deleting your account information
When you use Escuela’s online services, such as registration, feedback, or contact forms, we may collect personal information. Some of the third party services we use, as well as account management in our official website, provide you with the ability to edit the information in your user account that you created during registration. You may request deletion of your user account by contacting office@edelsol.org.

Content or other information that you may have provided, and that is not contained within your user account, such as public comments on social media, may remain available even though your information is deleted.

You may also request a review of your personal data, the suppression of processing of personal data (e.g. adding your name to our mailing list), or destruction of personal data. If we are not able to fully comply with requests for destruction, due to federal regulations regarding data retention or other factors, we will notify you of what steps we have been able to take to destroy records of your personal data.

In case of a data breach (of our online properties or or of third party services holding your personal data), Escuela will take necessary steps to re-secure your personal data, then make every effort to communicate with account holders to notify them in a timely manner of the breach.

6. Changes to this privacy policy
Changes may be made to this policy from time to time. Please check this privacy policy periodically for all updates.

7. No Guarantees
While this privacy policy states standards for maintenance of data, and while efforts will be made to meet the said standards, Escuela is not in a position to guarantee compliance with these standards. There may be factors beyond Escuela’s control that may result in disclosure of data. Consequently, Escuela offers no warranties or representations regarding maintenance or nondisclosure of data.

8. Contact information
If you have any questions about this policy or this website, contact office@edelsol.org.
www.escueladelsol.org is the official website of Escuela.
Our postal address is: 1114 Seventh Street NW, Albuquerque, NM 87102.
Our telephone number is (505) 242-3033.

Tech Security Policy

Objectives
This policy is designed to enhance the confidentiality, integrity and availability of Escuela del Sol Montessori’s essential data so that:
  • All information and data are properly secured and protected from unauthorized users.
  • All data is complete, intact, accurate and current, to the greatest possible extent.
  • Systems are ready and available when needed.
If you would like a full copy of the Tech Security Policy, or have questions about Escuela del Sol’s tech security policy, please contact IT Director Ellen Dornan.
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