Privacy Notice for Emirates British Nursery (EBN)

This Privacy Notice describes how the Emirates British Nursery (“EBN” or “We”) collects and uses the Personal Data of children attending the Nursery (“Child” or “Children”), and the parents of the Children (“Parents”) (known collectively as “You” or “Your”), in accordance with the General Data Protection Regulation (GDPR) and the UAE Personal Data Protection Law. EBN is committed to protecting the privacy and security of your Personal Data.

EBN is a “Data Controller” and is responsible for deciding how we hold and use Personal Data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to Parents. This notice does not form part of any contract of employment or other contracts to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that Parents read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data Protection Principles

We will comply with the data protection law. This says that the Personal Data we hold about You must be:

Used lawfully, fairly, and in a transparent way.
Collected only for valid purposes that we have clearly explained to You and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told You about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told You about.
Kept securely.

The Kind of Information We Hold About You

Personal Data means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data that require a higher level of protection, such as information about an individual’s health, religion, ethnicity, race, or sexual orientation.

Children

We will collect, store, and use the following categories of Personal Data about Children:

First Name & Last Name.
Date of Birth.
Home Address.
Gender.
Nationality.
National identification number.
Passport number.

We may also collect, store, and use the following “Special Categories” of more sensitive personal information:

Information about the child’s religion/religious beliefs.

Parents

We will collect, store, and use the following categories of Personal Data about Parents:

First Name & Last Name.
Home Address.
Personal Email.
Contact Number.

How Is Your Personal Data Collected?

Children & Parents

We collect Personal Data about Children and Parents from when the initial inquiry is made by the Parents through the website/call, throughout the enrolment process, and until the child stops using the Nursery’s services.

How We Will Use Information About You

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in either of the following circumstances:

Where we have obtained explicit consent from parents to do so;
Where we need to perform the contract, we have entered into with you;
Where we need to comply with a legal obligation; and
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your Personal Data in the following situations, which are likely to be rare:

Where we need to protect Your interests (or someone else’s interests); and
Where it is needed in the public interest or for official purposes.

Situations In Which We Will Use Children’s Personal Data

We need all the categories of information in the list above (see Children Section within the Paragraph entitled ‘The Kind of Information We Hold About You’) primarily to allow us to perform our obligations (including our legal obligations) to Children. The situations in which we will process the Personal Data of Children are listed below:

To ensure we meet the needs of the Children.
Report on a Child’s progress whilst with the Nursery.
Upon consent from the Parents, the Personal Data of Children will be shared with schools for progression into the next stage of their education.
To check safeguarding records.
To check complaint records.
To check attendance patterns are recorded.
When a Child’s Progress Report is given to its Parent for the Parent to pass the same Progress Report to a school for application or enrolment purposes.
Personal Data of Children will be shared with local authorities without the consent of Parents where there is a situation where child protection is necessary.

Situations In Which We Will Use Parent’s Personal Data

We need all the categories of information in the list above (see Parents Section within the Paragraph entitled ‘The Kind of Information we Hold About You’) primarily to allow us to perform our contracts with Parents and to enable us to comply with legal obligations. The situations in which we will process the Personal Data of Parents are listed below:

The Personal Data of Parents will be shared with local authorities without the consent of Parents whenever required.
To report on a Child’s attendance.
To make parents aware of the various conferences/exhibitions being conducted by the nursery (For marketing purposes).
To be able to contact a Parent or a Child’s emergency contact about their Child.
To ensure nursery fees are paid.

If Parents Fail to Provide Personal Data

If Parents fail to provide certain information when requested, we may not be able to perform the respective contracts we have entered into with Parents, or we may be prevented from complying with our respective legal obligations to Children, and Parents.

Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify the Parents, as is appropriate in the circumstances, and we will explain the legal basis which allows us to do so.

Please note that we may process a Child’s, or a Parent’s Personal Data without their respective knowledge or consent, as relevant to the circumstances, in compliance with the above rules, where this is required or permitted by law.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL DATA

Special categories of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing, and using this type of Personal Data. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of Personal Data in the following circumstances:

In limited circumstances, with the Parent’s explicit written consent.
Where it is needed in the public interest, such as for equal opportunities monitoring.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect a Child, or a Parents’ interests (or someone else’s interests) and the Parent is not capable of giving consent, or where the Parent has already made the information public.

Automated Decision-Making

Automated decision-making takes place when an electronic system uses Personal Data to make a decision without human intervention. We may use automated decision-making in the following circumstances:

Where we have notified Parents of the decision.
Where it is necessary to perform the contract with a Parent and appropriate measures are in place to safeguard the Child’s, or the Parent’s rights as is appropriate.
In limited circumstances, with explicit written consent from the Parent, as is appropriate, and where appropriate measures are in place to safeguard the Parent’s rights.

If we make an automated decision based on any particularly sensitive personal information, we will either obtain explicit written consent from a Parent as is appropriate, or it must be justified in the public interest, and we shall also put in place appropriate measures to safeguard a Child’s or Parent’s right as is relevant in the circumstances.

You will not be subject to decisions that will have a significant impact on You based solely on automated decision-making unless we have a lawful basis for doing so and we have notified the Parent as is appropriate in the circumstances.

Data Sharing

We may have to share Child, or Parent data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of Your data and to treat it in accordance with the law.

Why might the Nursery share Child, or Parent personal Data with third parties?

We will share Your Personal Data with third parties where required by law, where it is necessary to administer the working relationship with You, or where we have another legitimate interest in doing so.

Which third-party service providers process my Personal Data?

” Third parties” includes third-party service providers (including contractors and designated agents), local authorities, regulatory bodies, healthcare professionals, schools, and other entities within our group.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect Your Personal Data in line with our policies. We do not allow our third-party service providers to use Your Personal Data for their own purposes. We only permit them to process Your Personal Data for specified purposes and in accordance with our instructions.

When might you share my Personal Data with other entities in the group?

We will share Your Personal Data with other entities in our group as part of our safeguarding procedures, transitions into schools, and any relevant healthcare professionals if the need arises.

What about other third parties?

We may share Your Personal Data with other third parties. In this situation we will, as far as possible, share anonymized data with the other parties. We may also need to share Your Personal Data with a regulator to comply with the law.

Data Retention

How long will you use my information?

We will only retain Your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process Your Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize Your Personal Data so that it can no longer be associated with You, in which case we may use such information without further notice to You. Once you are no longer a Child benefiting from the Nursery’s services or a Parent, as is appropriate, we will retain and securely destroy your Personal Data in accordance with applicable laws and regulations.

Privacy Rights

It is important that the Personal Data we hold about You is accurate and current. Please keep us informed if Your Personal Data changes during your working relationship with us.

Your rights in connection with the Personal Data

Request access to Your Personal Data (commonly known as a “data subject access request”). This enables You to receive a copy of the Personal Data we hold about You and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about You. This enables You to have any incomplete or inaccurate information we hold about You corrected.
Request the erasure of your Personal Data. This enables Parents to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove Your Personal Data where You have exercised Your right to object to processing (see below).
Object to processing of Your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about Your situation which makes You want to object to processing on this ground. You also have the right to object where we are processing Your Personal Data for direct marketing purposes.
Request the restriction of processing of Your Personal Data. This enables Parents, as is appropriate, to ask us to suspend the processing of Personal Data.
Request the transfer of Your Personal Data to another party.

If You want to review, verify, correct, or request the erasure of Your Personal Data, object to the processing of Your Personal Data, or request that we transfer a copy of Your Personal Data to another party, please log your request.

No Fee is Usually Required

You will not have to pay a fee to access Your Personal Data (or to exercise any of the other rights).

What We May Need From You

We may need to request specific information from You to help us confirm your identity and ensure Your right to access the information (or to exercise any of Your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

Right to Withdraw Consent

In the limited circumstances where You may have provided Your consent to the collection, processing, and transfer of Your Personal Data for a specific purpose, You have the right to withdraw Your consent for that specific processing at any time. To withdraw Your consent, Once we have received notification that You have withdrawn Your consent, we will no longer process Your information for the purpose or purposes You originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide You with a new privacy notice when we make any substantial updates. We may also notify You in other ways from time to time about the processing of your Personal Data.