Ashbury College Privacy Policy

 Effective: May 26, 2020

This Privacy Policy is to be read in conjunction with other Ashbury College policies related to privacy considerations. This Policy will be updated from time to time and as required due to legislative changes.

Ashbury College complies with the following legislation surrounding privacy: the Ontario Education Act, the federal Personal Information Protection and Electronic Documents Actand the Personal Health Information Protection Act, as well as the European General Data Protection Regulation.

1. INTENDED PURPOSE

Ashbury College is committed to the protection of personal information under its control and to the individuals’ right of privacy regarding personal information that is collected, used, disclosed, and retained by Ashbury College.

Consent permitting Ashbury College to collect, store and use personal information is obtained in the annual enrollment contract and specifically as may be required.

2. WHAT IS PERSONAL INFORMATION

Personal information means any information about an identifiable individual.  The following are examples of what is considered personal information:

• Recorded information about an individual, such as report cards and class lists;
• Special education records, such as individual education plans, and safety and behaviour plans;
• Name, address, sex, age, education, and medical or employment history;
• Any identifying number or symbol assigned to an individual (e.g., a vehicle licence plate);
• Video images of an individual (e.g., pedestrians and students);
• Personal or political views or opinions.

3. WHAT PERSONAL INFORMATION IS COLLECTED

Ashbury College collects personal information about the following stakeholders:

• Prospective, current and past students, and their families;
• Current and former faculty, staff, and volunteers;
• Vendors, suppliers, and contractors;
• Donors, friends, and supporters of Ashbury College;
• Community affiliates and partners; and
• Website visitors.

Examples of the personal information that Ashbury College may collect include the following:

• Name, address, telephone number, email address, and other contact details;
• Family information;
• Admissions application;
• Open house information;
• Fundraising, communication, and advancement information;
• Academic information such as attendance, grades, progress reports etc., and information about special educational needs;
• Employment data;
• Photos and images, audio, and video recordings;
• Financial information;
• Website visitor information;
• Health information; and
• Police reference check information.

4. HOW PERSONAL INFORMATION IS USED

Ashbury College uses personal information as required to carry out its educational mission and to provide related services to its students and other community members.

Only certain individuals within Ashbury College are authorized to view and use the personal information of its stakeholders. Those individuals are permitted to use the information only for the purposes for which the information was collected.

Ashbury College does not sell to third parties any personal information it collects.

5. HOW PERSONAL INFORMATION IS SHARED

Ashbury College may disclose personal information to others outside of the College as and where permitted by law. For example, personal information may be disclosed to outside organizations that provide services to Ashbury College, such as educational platforms and trip providers, employment profiles, consultants, and communication services. In such cases, Ashbury College will only disclose the personal information necessary for the provision of the service(s). Ashbury College requests that all service providers comply with the College’s privacy policies and applicable laws with respect to personal information.

In some circumstances, Ashbury College may also be required by law to disclose personal information, such as to the Ontario Ministry of Education or in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation, or other legally valid request or enquiry.

Except as required or permitted by law, as outlined above, Ashbury College will not disclose personal information to others outside of the College without the consent of the individual or, in the case of a minor, without the consent of the minor’s parent or guardian. 

6. HOW PERSONAL INFORMATION IS STORED

Personal information at Ashbury College is mainly stored on two kinds of media:

• Hard copy: physical representations of data, such as paper printouts and printer records, on Ashbury College premises. This data includes, but is not limited to, notes, memos, messages, correspondence, transaction and employee records, and reports.
• Electronic copy: information stored on networks and electronic media, such as computer hard drives, copier and printer hard drives, and removable solid drives including memory, disks, and USB flash drives.

Ashbury College has implemented policies on the appropriate handling and safeguarding of personal information.  It also provides training to all faculty and staff on these policies, and requires their adherence to these policies.

Some of the electronic personal information collected by Ashbury College is stored by outside hosted databases and cloud storage providers. In some cases, personal information collected by Ashbury College may be stored outside Canada. In such cases, the personal information will be subject to the laws of other jurisdictions and may be available to foreign government authorities under lawful orders and laws applicable therein.

If you have any questions or concerns about this Privacy Policy, please contact Ashbury risk Management at risk@ashbury.ca.

Should you have any concerns with regard to the sharing of personal information, you should communicate your concerns as soon as possible with the Head of School for Ashbury College. The above policy will apply unless an objection is filed with the Head of School and an alternative resolution can be found.