DATA MANAGEMENT POLICIES

Clear Desk Policy

Purpose

The purpose of a clear desk policy is to ensure that all sensitive/confidential materials of students, staff, intellectual property, and clients are removed from the staff workspace and locked away when the items are not in use or staff leaves his/her workstation.

Objective

To increase staff awareness about protecting sensitive/confidential information and personal data as part of standard basic privacy controls.
To empower staff within an organised environment and provide a good impression for clients of Killarney School of English.
To reduce the threat of security to confidential information. That means everyone in Killarney School of English must protect documents and data from unauthorised access, internally and from outsiders.

Scope

Clear desk policy not only includes documents and notes, but also post-its, business cards, and removable media.

Sensitive/Confidential Data

Employees are required to ensure that all sensitive/confidential information in hardcopy and/or electronic form is secure in their work area at the end of the day and when they are expected to be gone for an extended period.

Filing cabinets containing restricted, confidential and/or sensitive information must be kept closed when not in use.

Keys used for access to be restricted, confidential and/or sensitive information must not be left at an unattended desk.

Printouts containing restricted, confidential and/or sensitive information should be immediately removed from printers.

Restricted, confidential and/or sensitive documents should be shredded in the official shredder bins or placed in locked disposal bins daily.

At known extended periods away from your desk, such as a lunch break, working papers are expected to be placed in locked drawers.

PCs and Laptops

PC screens must be locked, requiring PIN to unlock, when workspace is unoccupied.
PC’s must be shut down completely at the end of the work day.

Daily Operations

Passwords must not be written down.
Clear your workstation before you go home that includes removing cups, dishes, glasses, etc.
Avoid printing off emails to read them. This generates increased amounts of clutter and should be shredded immediately.
Go through items on your desk to make sure you need them, dispose of as appropriate.
Try to handle any piece of paper only once, act on it, file it, scan or shred it.
If in doubt – shred it.

Compliance

Killarney School of English management will verify compliance to this policy through various methods, including but not limited to, periodic observations, and internal audits.
Any exception to the policy must be approved by the Management of Killarney School of English in advance.
Any staff found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

Data Breach Policy

Purpose

If personal data is inadvertently released to a third party without consent, this may constitute a breach of the General Data Protection Regulation (GDPR) (EU) 2016/679.

Data security breaches are increasingly common occurrences whether these are caused through human error or via malicious intent. As technology trends change and the creation of data and information expands, there are more emerging ways by which data can be breached.

Killarney School of English have in place a robust and systematic process for responding to any reported data security breach. This will ensure Killarney School of English can act responsibly and protect its information assets as far as possible.

Sometimes a breach of personal information/data security may occur because this personal information/data is accidentally disclosed to unauthorised persons or, lost due to a fire or flood or, stolen as result of a targeted attack or the theft of a mobile computer device. The purpose of this policy is to ensure that a standardised approach is implemented throughout Killarney School of English In the event of a personal information/data breach.

Scope

The policy applies to all stakeholders, specifically including employees, students, service providers, contractors and third parties that access, use, store or process personal information on behalf of Killarney School of English

Killarney School of English is legally required under the General Data Protection Regulation(GDPR) (EU) 2016/679 to ensure the security and confidentiality of the information/data it processed on behalf of its students, clients, service providers and employees.

A data security breach is considered to be “any loss of, or unauthorised access to Killarney School of English’s personal data”. Examples of data security breaches may include but not limited to: –

Loss or theft of personal data
Loss of unencrypted equipment storing personal data
Human error for example sending personal data to the wrong email address
Unforeseen circumstances such as a fire or flood
Hacking attack
‘Blagging’ offences where information is obtained by deceit

Roles and Responsibilities

Information users
All information users are responsible for reporting actual, suspected, threatened or potential information security incidents and for assisting with investigations as required, particularly if urgent action must be taken to prevent further damage.

Data Owners
Data Owners are responsible for ensuring that staff in their area act in compliance with this policy and assist with investigations as required.

Contact Details
In the event that the Incident Management Team need to be contacted, contact info@ksoe.com

Data Classification

Data security breaches will vary in impact and risk depending on the content and the quantity of the data involved, therefore it is important that Killarney School of English is able to quickly identify the classification of the data and respond to all reported incidents in a timely and thorough manner. All reported incidents will need to include the appropriate data classification for an assessment of risk to be conducted. Data classification referred to in this policy see Personal Data Register.

Public Data:
Information intended for public use, or information which can be made public without any negative impact on Killarney School of English.

Internal Data:
Information regarding the day-to-day business and operations of Killarney School of English Primarily for staff though some information may be useful to third parties who work with Killarney School of English.

Confidential Data:
Information of a more sensitive nature for the business and operations of Killarney School of English, representing the basic intellectual capital and knowledge. Access should be limited to only those people that need to know as part of their role within [Killarney School of English

Data Security Breach Reporting

In the case of a personal data breach, staff must inform privacy senior management immediately (given that Killarney School of English have only 72 hours to report the breach to the Data Protection Commissioner).

Confirmed or suspected data security breaches should be reported promptly to info@ksoe.com . The report should include full and accurate details of the incident including who is reporting the incident and what classification of data is involved. Where possible the incident report should be completed as part of the reporting process.

Details of the Personal Data Breach to be reported: –

describe the nature of the personal data breach
systems used
classification of personal data lost
details of when, where and how this personal data was lost
including where possible, the categories and approximate number of data subjects concerned
approximate number of personal data records concerned
describe the likely consequences of the personal data breach

Once a data breach has been reported an initial assessment will be made to establish the severity of the breach. All data security breaches will be centrally logged in the incident reporting system.

Data Breach Management Plan

The management response to any reported data security breach will involve the following four elements: –

Containment and Recovery
Assessment of Risks to the rights and freedom of those affected
Consideration of Further Notification of those affected
Evaluation and Response

An activity log recording the timeline of the incident management should also be completed.

Reporting to the Data Protection Commissioner

In the case of a personal data breach, Killarney School of English should report to the Data Protection Commissioner https://www.dataprotection.ie/en within 72 hours after having become aware of it unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the Data Protection Commissioner is not made within 72 hours, it shall be accompanied by reasons for the delay.

Any service provider processing personal data on behalf of Killarney School of English should notify Killarney School of English without undue delay after becoming aware of a personal data breach.

The following information should be provided about the personal data breach: –

describe the nature of the personal data breach including, where possible, the categories and approximate number of data subjects concerned, and the categories and approximate number of personal data records concerned
communicate the name and contact details of the Data Protection Manager or other contact point where more information can be obtained
describe the likely consequences of the personal data breach
describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects

Killarney School of English will document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken.

Communication of a personal data breach to the affected individuals: –

When the personal data breach is likely to result in a high risk to the rights and freedoms of the individuals affected, Killarney School of English will communicate the personal data breach to the individuals affected without undue delay
The communication to the individuals affected will describe in clear and plain language the nature of the personal data breach
Killarney School of English will provide the name and contact details of the Data Protection Manager, describe the likely consequences of the personal data breach and describe the measures taken or proposed to be taken to address the mitigation of the data breach including, if appropriate, measures taken

Communication to the affected individual is not required if any of the following conditions are met: –

Killarney School of English has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
Killarney School of English has taken subsequent measures which ensure that the high risk to the rights and freedoms of affected individuals is no longer likely to materialise;
It would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the affected individuals are informed in an equally effective manner.

Data Management Policy

Purpose of This Policy

This Data Management Policy outlines how Killarney School of English collects, stores, uses, protects, and disposes of personal data belonging to students, staff, host families, agents, and visitors. The school is committed to complying with the EU General Data Protection Regulation (GDPR) and the Data Protection Acts 1988–2018 (Ireland).

Scope

This policy applies to:

All employees and contractors, of the school
All systems, processes, and activities involving personal data
All personal data processed in paper or digital formats

Definitions

Personal Data: Any information relating to an identified or identifiable person.
Special Category Data: Sensitive information such as health data, learning needs, or biometric data.
Data Subject: Any individual whose data is collected by the school.
Data Controller: The school, which decides how personal data is processed.
Data Processor: Any external party processing data on behalf of the school.

Types of Data Collected

The school collects the following categories of data:

Students

Name, contact details, date of birth, nationality
Passport/ID, visa/immigration documents
Emergency contact information
Attendance, academic records, assessment results
Medical information (only when necessary for duty of care)

Staff

Contact information, CVs, qualifications, references
Payroll and contract information
Garda Vetting records

Host Families

Contact details
Banking information (for payments)
Garda Vetting Documents
Photos of the house to send to students
Use of Google map with address to send students

Legal Basis for Processing

Personal data is processed on one or more of the following bases:

Performance of a contract (e.g., student enrolment, employment contracts)
Legal obligation (e.g., immigration compliance, attendance monitoring)
Legitimate interests (e.g., quality assurance, safety)
Consent (e.g., photos for marketing, optional medical disclosures)

Consent, where used, must be freely given, specific, informed, and withdrawable at any time.

Data Collection and Storage

Data is collected through enrolment forms, online systems, email, and in-person interactions.
Digital data is stored on secure, password-protected systems.
Paper records are stored in locked cabinets with controlled access.
Access is limited to staff members (Feargal, Nicola and Sheena) who require information for their roles.

Data Sharing

Personal data may only be shared when necessary and lawful, such as:

With Irish immigration authorities (INIS/ISD)
With accrediting bodies (e.g., ACELS/QQI)
With host families for duty-of-care purposes
With service providers (IT support, payroll providers) under GDPR-compliant data processing agreements

The school does not sell personal data to third parties.

Data Retention


Student enrolment & academic records	3 years after course completion
Attendance records	3 years
Financial records	7 years (Revenue requirement)
Staff records	3 years after employment ends
Garda Vetting records	As per National Vetting Bureau guidelines

When retention periods expire, data is securely deleted or shredded.

Data Security

The school ensures:

Password-protected systems and regular password updates
Encrypted devices and secure backups
Antivirus and firewall protection
Restricted access to sensitive or special-category data
No use of personal devices for school data unless authorised and secured
Staff training on data protection responsibilities

Data Breach Procedures

If a data breach occurs:

The incident must be reported immediately to the Data Protection Officer (DPO) Sheena Murphy or either School Director.
The school will record the breach, investigate, and take corrective action.
If there is a high risk to individuals’ rights, the Data Protection Commission (DPC) will be notified within 72 hours, and affected individuals will be informed promptly.

Rights of Data Subjects

Data subjects have the following rights under GDPR:

Right to access their personal data
Right to rectification
Right to erasure (“right to be forgotten”)
Right to restriction of processing
Right to object to processing
Right to data portability
Right to withdraw consent at any time

Requests may be submitted in writing to the school’s DPO.

Use of Photography and Video

Consent is required for use of identifiable images in marketing materials or social media. Students may opt out at any time.

Policy Review

This policy will be reviewed annually or sooner if legislation or operations change.

Data Protection Policy – Employees

Killarney School of English processes personal data of all employees. Killarney School of English will process all such data in accordance with the General Data Protection Regulation (GDPR) in force from 25^th May 2018.

The purposes for which we process the personal data on employees are: –

To manage the progression of each employee throughout their tenure of employment
To ensure that correct training and development is provided
To ensure employees are correctly rewarded for their service to the appropriate bank accounts
To engage with Revenue for payment of employment taxation
To comply with all relevant law
To ensure contact details of employees are available if required for the purpose of providing our services
To manage any disputes, should they arise
To ensure a next of kin can be contacted if required

Killarney School of English can share employee details with external bodies such as Revenue, Social Welfare, outsourced Employment Law advisors, auditors, pension brokers and insurers.

Killarney School of English does not transfer any employee personal data to a 3rd country.

Killarney School of English ensures all employees personal data is processed subject to sufficient organisational and technical safeguards to protect employee data.

Types of Personal Data (i.e. any information relating to an identified or identifiable person)		Legal Basis	Retention Period
Demographic Data	e.g. name, date of birth, age,	Contract	End of Employment plus 7 years
Contact Details	e.g. home/work landline phone number, personal/work mobile, home/work postal address, personal/work email address	Contract	End of Employment plus 7 years
Financial Data	e.g. bank account number,	Contract	End of Employment, when P45
Special Data	e.g. data relating to racial or ethnic origin, political, religious or, philosophical beliefs, trade union membership, health, sexual life or orientation, genetic or biometric data	Not Collected	Not Collected
Criminal Offences/Convictions	N/A	N/A	N/A
Government Identifiers	income tax number	Contract	End of Employment plus 7 years for Income Tax, End of Employment
Time Records	Timesheets	Compliance	3 Years

I.I Right to Erasure

When have I the right to all my personal data being deleted by Killarney School of English?

You have the right to have your personal data deleted without undue delay if: –

The personal data is no longer necessary in relation to the purpose(s) for which it was collected/processed
You are withdrawing consent and where there is no other legal ground for the processing
You object to the processing and there are no overriding legitimate grounds for the processing
The personal data has been unlawfully processed
The personal data must be erased so that we are in compliance with legal obligation
The personal data has been collected in relation to the offer of information society services with a child

What happens if Killarney School of English has made my personal data public?
If we have made your personal data public, we, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform those who are processing your personal data that you have requested the erasure.

What happens if Killarney School of English has disclosed my personal to third parties?
Where we have disclosed your personal data in question to third parties, we will inform them of your request for erasure where possible. We will also confirm to you details of relevant third parties to whom the data has been disclosed where appropriate.

Would Killarney School of English transfer the personal data to another service provider if I requested this?
We can transfer this data to another company selected by you on your written instruction where it is technically feasible taking account of the available technology and the feasible cost of transfer proportionate to the service we provide to you.

Under what circumstances can Killarney School of English refuse?
You will not be able to obtain, or have transferred in machine-readable format, your personal data if we are processing this data in the public interest or in the exercise of official authority vested in us.

Will Killarney School of English provide me with my personal data if the file contains the personal data of others?
We will only provide you with your personal data, ensuring we protect the rights and freedoms of others. Where personal data of another person may be on the same files as yours, we will redact the full details of the other person.

Right for Automated Individual Decision Making including Profiling

What are my rights in respect of Automated Decision making?
Killarney School of English does not have any automated decision-making processes. Where any such processes are introduced, we will provide you with the relevant information required under the “General Data Protection Regulation”.

When can I object to Killarney School of English processing my personal data?

You can object on grounds relating to your situation.

Killarney School of English will stop processing your personal data unless: –

we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms.
the processing is for the establishment, exercise or defence of legal claims.

What are my rights to object for direct marketing purposes?

Where your personal data is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, we will no longer process this data for such purposes.

When can I restrict processing?
You may have processing of your personal data restricted: –

While we are verifying the accuracy of your personal data which you have contested.
If you choose restricted processing over erasure where processing is unlawful.
If we no longer need the personal data for its original purpose but are required to hold the personal data for defence of legal claims.
Where you have objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our legitimate grounds override.

What if Killarney School of English has provided my personal data to third parties?
Where we have disclosed your personal data in question to third parties, we will inform them about the restriction on the processing, unless it is impossible or involves disproportionate effort to do so.

How will I know if the restriction is lifted by Killarney School of English and/or relevant third parties?
We will inform on an individual basis when a restriction on processing has been lifted.

What can I do if Killarney School of English is holding incorrect personal data about me?
Where you suspect that data we hold about you is inaccurate, we will on demand rectify any inaccuracies without undue delay and provide confirmation of same.

Right to withdraw Consent

Under what circumstances could I withdraw consent?
You can withdraw consent if we are processing your personal data based on your consent.

When can I withdraw consent?
You can withdraw consent at any time.

If I withdraw consent what happens to my current data?
Any processing based on your consent will cease upon the withdrawal of that consent. Your withdrawal will not affect any processing of personal data prior to your withdrawal of consent, or any processing which is not based on your consent.
Contact us at info@ksoe.com

Can I lodge a complaint with the Data Protection Commissioner?
You can lodge a complaint with the Data Protection Commissioner in respect of any processing by or on behalf of Killarney School of English of personal data relating to you.

How do I lodge a complaint?
Making a complaint is simple and free. All you need to do is write to the Data Protection Commissioner giving details about the matter. You should clearly identify the organisation or individual you are complaining about. You should also outline the steps you have taken to have your concerns dealt with by the organisation, and what sort of response you received from them. Please also provide copies of any letters between you and the organisation, as well as supporting evidence/material.

What happens after I make the complaint?
The Data Protection Commissioner will then take the matter up with Killarney School of English on your behalf.

When do I have the right to access my personal data from Killarney School of English
Where Killarney School of English process any personal data relating to you, you have the right to obtain confirmation of same from us, and to have access to your data.

What information will Killarney School of English provide to me?
If we are processing your personal data you are entitled to access a copy of all such personal data processed by us. We will also provide the following information including your full rights under Data Protection: –

why we are processing your personal data
the types of personal data concerned
the third parties or categories of third parties to whom the personal data have been or will be disclosed. We will inform you if any of the third parties are outside the European Economic Area (EEA)or international organisations
how your personal data is safeguarded where we provide your personal data outside the European Economic Area or to an international organisation
the length of time we will hold your data or if not possible, the criteria used to determine that period
your rights to: –
request any changes to inaccurate personal data held by us.
have your personal data deleted on all our systems.
restriction of processing of personal data concerning you.
to object to such processing.
data portability.
your right to lodge a complaint with the Data Protection Commission info@dataprotection.ie
where we have collected your personal data from a third party, we will provide you with the information as to our source of your personal data.
any automated decision-making, including profiling which includes your personal data. We will provide you with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

How long will it take to receive my personal data from Killarney School of English?
We will provide you with a copy of the personal data we are currently processing within 30 days of request. In rare situations if we are unable to provide you with the data within 30 days we will notify you, within 10 days of your request, explaining the reason for the delay and will commit to delivery within a further 60 days. i.e. 90 days in total.

How much will it cost me to receive my personal data?
We will not charge for providing your personal data unless we believe the request is excessive and the cost of providing your data is disproportionate to your services provided.

Can I request additional copies of my personal data?
If you require additional copies we will charge €20 to cover our administrative costs.

Can I receive my personal data electronically?
You can request your personal data by electronic means and we will provide your personal data in a commonly used electronic form if technically feasible.

What will Killarney School of English do if another person’s personal data is shared with my personal data?
We will only provide you with your personal data, ensuring we protect the rights and freedoms of others. Where personal data of another person may be on the same files as yours, we will redact the full details of the other person.

Contact us at info@ksoe.com

Killarney School of English will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives on at least an annual basis and more frequently if required considering changes in the law and organisational or security changes.

Data Protection Policy – Organisation

Everyone has rights with regards to how their personal information is handled. During Killarney School of English activities, we may collect, store and process personal information about staff, students, guardians, host families, educational partners, clients and service providers, and recognise the need to treat this data in an appropriate and lawful manner. Killarney School of English is committed to complying with its obligations in respect to all personal data it handles.

The types of personal data that Killarney School of English may be required to handle includes details of current, past and prospective employees, students, parents / guardians, educational partners, host families, suppliers, customers and others that Killarney School of English communicates with. The information, which may be held on paper or on a computer or other media is subject to certain legal safeguards specified in the General Data Protection Regulation(GDPR) (EU) 2016/679 and other regulations. The GDPR impose restrictions on how Killarney School of English may collect and process data.

In accordance with GDPR, Feargal Courtney is the designated ‘Data Protection Lead’ (DPL) within Killarney School of English and is responsible for all aspects of the Data Protection Policy and implementation of same.

This policy does not form part of any employee’s contract of employment and it may be amended at any time. Any breach of this policy will be taken seriously and may result in disciplinary action up to and including dismissal.

Purpose and Scope of the Policy

This policy sets out Killarney School of English ’s rules on data protection and the legal conditions that must be satisfied in relation to the collection, obtaining, handling, processing, storage, transportation and destruction of personal and sensitive information.

If an individual considers that the policy has not been followed in respect of personal data about themselves or others they should raise the matter with the DPL.

Definition of Data Protection Terms

Data – Information which is stored electronically, on a computer, or in certain paper-based filing systems. This includes IT systems. The school does not have a CCTV system.

Data Subjects – For the purposes of this document includes all living individuals about whom Killarney School of English holds personal data.

Personal Data – Data relating to a living individual who can be identified from the data (or from that data and other information that is in, or likely to come into the possession of the data controller). Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).

Data controllers – The individuals or organisations who control and are responsible for keeping and use of data.

Data users – Employees whose work involves using personal data. Data users have a duty to protect the information they handle by following Killarney School of English ’s data protection security policies at all times.

Processing – Performing any operation or set of operations on data including: –

Obtaining, recording or keeping data
Collecting, organising, storing, altering or adapting the data
Retrieving, consulting or using the data
Disclosing the information or data by transmitting, disseminating or otherwise making it available
Aligning, combining, blacking, erasing or destroying the data

Sensitive personal data – KSOE does not gather Information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health condition or sexual life, criminal convictions or the alleged commission of an offence. Sensitive personal data could only be processed under strict conditions and will usually require the express consent of the person concerned.

Data Protection Principles

Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be: –

Obtained and processed fairly

GDPR’s are intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the DPL is, in this case Feargal Courtney the purpose for which the data is to be processed by Killarney School of English, and the identities of anyone to whom the data may be disclosed or transferred.

For personal data to be processed lawfully, certain conditions must have been met. These may include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, more than one condition must be met. In most cases the data subject’s explicit consent to the processing of such data will be required.

Kept only for one or more specified, explicit and lawful purposes

Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for other purposes specifically permitted by GDPR. This means that personal data must not be collected for one purpose and used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose before any processing occurs. Any employee personal data collected by Killarney School of English is used for ordinary Human Resources purposes. Where there is a need to collect employee data for another purpose, Killarney School of English will notify the employee of this and where it is appropriate will get employee consent to such processing.

Used and disclosed only in ways compatible with these purposes

Personal data should only be collected to the extent that it is required for the specific purposes notified to the data subject. Any data which is not necessary for that purpose should not be collected in the first place.

Kept safe and secure

Killarney School of English and its employees must ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

GDPR require Killarney School of English to put in place procedures and technologies to maintain the security of all personal data. Personal data may only be transferred to a third-party data processor if the third party has agreed to comply with those procedures and policies or has adequate security measures in place.

The following must be maintained: –

Confidentiality – Only people authorised to use the data can access it. Killarney School of English will ensure that only authorised persons have access to an employees’ personal file and any other personal or sensitive data held by Killarney School of English. Employees are required to maintain the confidentiality of any data to which they have access.
Integrity – Personal data is accurate and suitable for the purpose for which it is processed.
Availability – Only authorised users should be able to access the data if they need it for authorised purposes

Security Policy / Procedures include: –

Secure lockable desks and cupboards. – Clear desk policy, all desks and cupboards remain locked when not in use. (Personal information is always considered confidential) and treated with extra precautions ensuring no one can see work that contains the same.
Methods of disposal. – Paper documents must be shredded. All removable media should be wiped and physically destroyed when no longer required.
Equipment – Data users should ensure that individual monitors do not show confidential information to passers-by and that the screen saver starts as soon as their PC is unattended.

Kept accurate, complete and up to date

Personal data must be accurate and kept up to date. Information which is incorrect, or misleading is not accurate, and steps should be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data should be destroyed. Employees should ensure that they notify the DPL and Human Resources of any relevant changes to their personal information so that it can be updated and maintained accurately. Examples of relevant changes to data would include a change of address.

Adequate, relevant and not excessive

Retained for no longer than is necessary for the purpose or purposes for which it was collected

Personal data should not be kept longer than is necessary for the purpose. For guidance in relation to data retention to data retention employees should contact their manager. Killarney School of English has various legal obligations to keep certain employee data for a specified period. In addition, Killarney School of English may need to retain personal data for a period to protect its legitimate interests.

Provided to data subjects as requested

Data must be processed in line with data subject’s rights. Data subjects have a right to: –

Request access to any data held about them by the Data Controller
Prevent the processing of their data for direct marketing purposes
Ask to have inaccurate data amended
Prevent processing that is likely to cause or distress to themselves or anyone else

Dealing with Subject Access Requests

A formal request from a data subject for information that Killarney School of English holds about them must be made in writing. Any employee who receives a written request in respect of data held by Killarney School of English should forward it to the Data Controller.

Providing Information Over the telephone

Any employee dealing with telephone enquiries should be careful disclosing any personal information held by Killarney School of English over the phone. The employee should: –

Check the identity of the caller to ensure that information is only given to a person who is entitled to that information
Suggest that the caller put their request in writing if the employee is not sure about the identity of the caller and in circumstances where the identity of the caller cannot be verified
Refer the request to their manager and/or the Data Controller for assistance in difficult situations. No employee should feel forced into disclosing personal information.

Direct Marketing

At Killarney School of English, it is our policy not to contact any potential individuals without their permission. To comply with this policy, our pre-sales employees are requested to ensure the following: –

Do not call or email another organisation until it is confirmed that they have a web presence or already in the public domain with their contact details such as address and telephone number published on the same.
When a call is made, permission must be sought to get the correct contact information such as the relevant decision maker with regards to IT purchasing. A record must be kept of whom our employee spoke to and date and time of the call.
All email contact must contain an ‘Opt-Out’ clearly identified options.
We do not market via Postal, Text or Fax.
All Opt-Outs must be respected (telephone or electronic) by deleting the contact permanently.

Policy Review

General Data Protection Regulation

Killarney School of English shall be the Data Controller of all personal processed Killarney School of English relation to its services as a School
Killarney School of English comply to all aspects of the GDPR
Killarney School of English shall also be a Joint Controller with regards to Educational Partners.
If Educational Partners collect further data for marketing purposes Killarney School of English shall not be responsible for this Data as it is not processed by it or on its behalf.
Killarney School of English may collect Personal Data on Students, Host Families, Sub Contractors and Staff. The Data collected is limited to what is required to manage the Students ‘education and welfare whilst in Ireland and whilst under the responsibility of the School.
Special Categories of Data, specifically ‘known allergies’ and/or ‘medical conditions’ will be collected on Students. The purpose for this is their care and will be in the ‘Vital Interest’ of their wellbeing.
Killarney School of English’s Privacy Statement and Cookie Policy is available on its web site https://www.ksoe.com/privacy-statement/ and https://www.ksoe.com/ksoe-cookie-policy/
Killarney School of English may outsource specific services to another Organisation, the categories of which are as follows:
- IT Services
- Payroll Services
- Cleaning Services
- Accounting
- Courier
- Online Backup
- Alarm Security
Killarney School of English does not make automated decisions on Individuals
Killarney School of English does not ‘Profile’ individuals
Killarney School of English is committed to the implementation of appropriate Technical and Organisational Measures in order to protect all information assets which Killarney School of English
Killarney School of English transfers Data to and from ‘Educational Partners’ who can be based inside and/or outside of the EEA.
Killarney School of English transfers Data to and from Government Departments and Agencies, where this Data is required by law.
All senior staff (Feargal, Nicola and Sheena) are in-house trained on Data Security including ‘Breach Management’ .
All communications between Killarney School of English and its clients is deemed to be of a Business nature and therefore not Personal.
Killarney School of English will make available to our clients any information necessary to demonstrate compliance.
Our contact for Data Protection compliance is info@ksoe.com

Leaving policy– To retrieve any personal data and update social media

Information Security and Return of Killarney School of English Property

Terminating employees are required to return to their manager all Killarney School of English owned property, equipment and materials which were issued to them during their employment. These items shall be returned on or before the last day of the individual’s employment. Your manager or other responsible administrators shall determine a date to revoke access rights to various Killarney School of English property and information, including but not limited to building access, computer systems, accounts and information access privileges on or before the date of termination.

Retrieval of any personal data from devices

Terminating employees who have downloaded Killarney School of English data including personal data onto their own devices must delete all data on or before termination of employment. This may include but not limited to smart phones/tablets/USB’s/iPads/home computers or any other personal device used to access Killarney School of English data.

Retrieval from your personal backups

The deletion includes backups stored in the cloud/hard drives/or other storage devices such as USB’s.

Private Email Accounts

Should an employee at any stage of employment email Killarney School of English data to their personal email account, this data must be deleted from your personal account before the date of termination. It is the terminating employee’s duty to ensure they fully delete all Killarney School of English data from personal emails, history files, devices and backups before date of termination.

Refusal of deletion of Killarney School of English Property included data

Refusal to return to Killarney School of English of any personal data processed by Killarney School of English may be construed as theft and appropriate legal action taken.

Social Media

On the date of termination, the terminating employee must remove any reference to current employment in Killarney School of English ensuring all social media sites state your employment with Killarney School of English terminated on the agreed date.