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Privacy Policy

At Kingston International School, we prioritise the rights and freedoms of individuals. This encompasses our commitment to respecting your privacy and safeguarding your personal information. Our privacy policy outlines the methods through which we gather and utilise (or "process") your data, provides contact information, and highlights your rights concerning your personal information.


Who are we?


Kingston International School ("we", "our", "us") is an educational institution situated at 12-14 Cumberland Road, Kowloon Tong, Hong Kong (Kindergarten and Children Centre), 113 Waterloo Road, Kowloon Tong, Hong Kong (Lower Primary) and 105 Waterloo Road, Kowloon Tong, Hong Kong (Upper Primary). We offer comprehensive education to children ranging from Playgroup (1 year old) up to Year 6.


Why is this privacy policy in place?


The objective of this privacy policy is to furnish comprehensive information on how we handle personal data.
Please ensure that you review our privacy policy alongside our additional policies and terms and conditions that pertain to personal data.
Kindly read this policy attentively, and if you have any inquiries regarding your personal data or its utilisation, please reach out to the Data Protection Officer at enquiry@kingston.edu.hk
We will periodically update this Privacy Policy. In the event of significant changes that impact the processing of your personal data, we will provide notification on our website and directly to you, to the best of our ability.


What does the term "personal data" refer to?


The term 'personal data' pertains to any information that either directly identifies you or can be used, in combination with other details, to identify an individual.
The term 'data subject' denotes the individual to whom the personal data relates.

What type of personal data do we gather concerning you?


We engage in the processing of personal data concerning various individuals associated with or visiting our school, including but not limited to: visitors to our website, prospective, current, and former students and their parents, staff and contractors, donors and supporters, and other individuals connected to our institution.
The personal data we handle encompasses a range of information, such as:

  • Identifying details like names, addresses, telephone numbers, and email addresses, as well as emergency contact information.
  • IP addresses, location data, website statistics, and analytics.
  • Website cookies.
  • Essential information about students, including date of birth, nationality, and family particulars.
  • HKID card or passport/entry permit numbers.
  • Records pertaining to admissions, academics, disciplinary matters, education-related documents, references, examination scripts, and grades.
  • Employment data and educational background of parents.
  • Bank account details.
  • Images, audio recordings, and video recordings.
  • Financial information and identification documents (e.g., for bursary evaluation or fundraising purposes).
  • Employee and former employee data, covering recruitment, training, performance management, payroll, and other human resources (HR) details.
  • Criminal records.
  • Health-related and dietary requirements.
  • Special education needs.
  • Biometric data (e.g., fingerprints).
  • Information relating to safeguarding, child protection, and welfare.
  • Race, ethnicity or
  • Religion.


By what means do we acquire your information?


The majority of the personal data we handle is obtained directly from the individuals themselves, or in the case of students, from their parents. On occasions, we may also collect data from third parties, such as referees/references or previous educational institutions, as well as from publicly available sources.
We gather data about you in the following circumstances:

  • When you express an interest in having a student attend our school and/or when a child is enrolled, and we conduct the school's admission assessment.
  • When you register to attend or have attended one of our events.
  • When you visit our website.
  • When you subscribe to receive our email newsletter and/or prospectus.
  • When you express an interest in working for or collaborating with us.
  • When you are employed by us or an organisation with which we have a business relationship.


By selecting Kingston International School for your child's education and consequently providing personal data to us, you are giving your consent to the application of this Privacy Policy. This includes the collection, use, access, transfer, disclosure, storage, and processing of your own and your child's personal information to the extent necessary for delivering educational programs and related services to the student, as described in this Policy.


In what manner do we store and maintain your personal data?


Kingston International School, being an educational institution, acknowledges that the personal data you provide to us in Hong Kong may be transferred, processed, stored, and accessed globally for the purpose of delivering our educational programmes. This includes activities such as secondary school applications and the Year 6 Overseas Trip. Furthermore, we may disclose and transfer personal data to government organisations, other educational institutions, and relevant individuals involved in providing services or fulfilling your requests, specifically in relation to school activities. By enrolling your child(ren) in Kingston International School, you explicitly consent to such transfers.


We ensure that any processing of personal data is carried out in compliance with applicable laws and regulations, particularly those pertaining to safeguarding and employment. Only authorised staff members process the personal data provided by individuals for the specific purposes it was collected.
To safeguard personal data, we have implemented appropriate technical and organisational measures. These measures include policies governing the use of technology, devices, and access to school systems.


During the course of our school operations, it may be necessary to share personal data, including special category personal data when required, with third parties such as examination boards, professional advisors, and relevant authorities.

In certain instances, we may be obligated to disclose personal data to other organisations for legal or statutory purposes, or with your explicit consent. Additionally, certain school systems, such as hosted databases, the school website, the school calendar, school posts, the school portal, or cloud storage providers, may be managed or operated by third parties.

When sharing personal data with these parties, we ensure that contractual agreements are in place to guarantee the secure handling and processing of personal data in accordance with our specific instructions. We do not transfer personal data provided by individuals unless we are confident that it will receive an equivalent level of protection.
Furthermore, the school may provide necessary information, including relevant personal data of the respective child, to students and parents to facilitate school operations.

In the event of data transfers to other countries, we rely on adequacy agreements or standard contractual clauses as part of our agreements with data processors. For more information regarding data transfers to other countries, you can request details by contacting our Data Protection Officer at enquiry@kingston.edu.hk


The reasons for which we process personal data


As an independent school, we process personal data to support our operations. Specifically, we utilise the data for the following purposes:

  • Selection and admission of students.
  • Provision of education and enrichment to students, including curriculum administration, monitoring academic progress, reporting to parents, managing student entries to public examinations, and providing references.
  • Provision of educational support and related services to students.
  • Safeguarding students' welfare and providing pastoral care, welfare, healthcare services, and support.
  • Creating a safe and secure environment for students, staff, and visitors.
  • Compliance with legal and regulatory requirements.
  • Operational management, including maintaining student records, administering invoices, fees, and accounts, managing school property, security, safety arrangements, and monitoring IT and communications systems. This also includes administering and implementing school rules and policies for students and staff, as well as preserving historical archives.
  • Staff administration, such as staff recruitment/contractor engagement, payroll and MPF administration, sick leave management, performance reviews, handling grievances, capability or disciplinary procedures, and maintaining human resources records for current and former staff. This also includes providing references.
  • Analysing website traffic, demographics, and behaviour using analytical tools and cookies.
  • Promoting the school through our website(s), prospectus, publications, and communications, including social media accounts.
  • Maintaining relationships with alumni and former employees.
  • Keeping records of historical and memorable events relevant to maintaining a historical record.


On what grounds do we lawfully process your personal data?


We may process your personal data for the purposes mentioned above, relying on one or more of the following legal bases:

  • Consent: We may process personal data if we have obtained your consent or the consent of your parent/guardian, if applicable. You have the right to withdraw your consent at any time by contacting us at enquiry@kingston.edu.hk.
  • Contractual necessity: We may process personal data if it is necessary for the performance of a contract, such as an employment contract with a staff member.
  • Legal obligations: We may process personal data to comply with our legal obligations. This includes using personal data to exercise or fulfil our rights and obligations imposed by law, including employment-related obligations. It may also involve the prevention and detection of crime and cooperating with police and other competent authorities in investigations.
  • Legitimate interests: We may process personal data if it is necessary for our legitimate interests or the legitimate interests of a third party. These legitimate interests include providing high-quality education, fostering relationships within the school community, and effectively managing and operating the school.
  • Vital interests: In certain limited circumstances, such as when a student experiences a life-threatening accident or illness at school, we may process personal data to protect the vital interests of the individual. This ensures that prompt and appropriate medical attention can be provided.
  •  Legal claims: Personal data may be processed if it is necessary for the establishment, exercise, or defence of legal claims.
  • Substantial public interest: In some cases, processing personal data may be necessary for reasons of substantial public interest, particularly for safeguarding purposes.
  • Archiving, research, or statistical purposes: Personal data may be processed for archiving, research, or statistical purposes while ensuring appropriate safeguards and anonymization to protect individual privacy.
  • By relying on these legal bases, we ensure that the processing of personal data is lawful and aligned with applicable regulations and requirements.


Consent


According to data protection laws, the rights pertaining to personal data belong to the individual to whom the data relates, known as the data subject. When it comes to processing personal data of students, where consent is the lawful basis, we generally rely on parental consent. However, depending on the specific processing activities, the age and understanding of the student, it may be more appropriate to rely on the student's consent.
It is important for parents to understand that in certain situations, they may not be consulted, taking into account the child's interests, the parents' legal rights or contractual obligations, and considering all relevant circumstances.

In most cases, we assume that students' consent is not required for routine sharing of their personal data with their parents. This includes keeping parents informed about the student's activities, progress, behaviour, and welfare, as it is in the best interest of the student. However, if a student explicitly requests to raise concerns confidentially with a staff member and expressly withholds consent for their personal data to be disclosed to their parents, we may have an obligation to maintain confidentiality. There may be exceptions to this obligation if, in our opinion, it is in the best interests of the student or other students, or if disclosure is required by law.


What are our obligations regarding the protection and management of your personal data?


We are committed to upholding and, whenever feasible, surpassing globally accepted standards for safeguarding personal privacy. Our commitment aligns with the requirements set forth in the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region ('the Ordinance'). You can access and review the Ordinance by visiting the government's website by following this link. 


What are the rights available to you regarding your personal data?


In accordance with data protection laws, you are entitled to exercise the following rights:

  • Access: You can request access to and obtain copies of the personal data we hold about you, with certain legal exceptions and limitations.
  • Correction: If the personal data we hold about you is inaccurate or incomplete, you have the right to request its correction.
  • Erasure: Under certain circumstances, you can request the deletion of your personal data. This applies, for example, if the data is being used for purposes other than originally specified or if it was acquired unlawfully.
  • Restriction: In certain situations, you can request that we limit our processing of your personal data.
  • Data Portability: You have the right to receive the personal data you have provided to us in a reasonable and specified format of your choice. This allows you to transmit the data to another data controller if desired.
  • Objection: If our processing activities have a disproportionate impact on your rights and interests, you can object to specific processing activities. This includes the right to object to receiving fundraising or communications and to object to being profiled for fundraising or communication purposes.
  • Withdrawal of Consent: If our processing is based on your consent, you have the right to withdraw your consent at any time. This withdrawal does not affect the lawfulness of our processing based on your consent before its withdrawal.

These rights are designed to empower you and protect your privacy. We are committed to respecting and facilitating the exercise of these rights in accordance with applicable data protection laws.


We strive to maintain accurate and up-to-date personal data for each individual. If there are any significant changes to important information, such as contact details, please inform the relevant school department.


Parents have the option to review and update their personal data through the Parent Portal at any time. For access, correction, deletion of personal data, or information about our policies and practices regarding personal data, a written request must be sent to us via registered postal mail. The Personal Data (Privacy) Ordinance specifies the form required for a data access request, which can be found here. A reasonable fee may be charged for processing such requests.
It is important to note that these rights are not absolute, and there may be exceptions or exemptions that allow us to refuse certain requests. We will make every effort to respond to written requests promptly, within the statutory time limits.


If you have any questions or concerns regarding the use of your personal data or if you wish to exercise your information rights, please contact us at enquiry@kingston.edu.hk. We are here to assist you.

What are our procedures for preserving and storing your personal data?


We ensure that all personal data is securely stored in compliance with applicable laws. We only retain personal data for legitimate purposes, utilising the lawful bases mentioned earlier. The retention period is limited to what is necessary for fulfilling those purposes or as mandated by law.

Contact us


If you have any inquiries, requests, or concerns, please inform us of how we can assist you. Our Data Protection Officer can be contacted at: enquiry@kingston.edu.hk
Data Protection Officer Details
The Data Protection Officer
Kingston International School
113 Waterloo Road
Kowloon Tong
Hong Kong