At iScoil, your privacy is very important to us. We want you to feel confident that a young person’s personal information and that of parents/guardians is safe and secure when using our service.

It is important that you know exactly how we handle personal information that you and others provide to us, why we gather it and what this means to you.

We will explain how we collect and use the personal information/data we hold, why we do so and how we treat your information.

We will also explain your rights and how you can exercise those rights.

This Privacy Policy is provided to embrace our obligations under the Data Protection Act 2018 and General Data Protection Regulation (GDPR), which requires greater accountability and transparency from organisations such as iScoil with regard to your information.

Please take time to read this policy carefully. If you are a young person under 16 years of age, please read this summary with a parent or guardian and ensure you both understand it. If you have any questions about how we use your information, please contact our Data Protection Officer by email at dpo@iscoil.ie or call the iScoil office on 01 4537570.

Throughout this policy, “we”, “us”, “our” and “ours” refers to iScoil:

• A Quality and Qualifications Ireland (QQI) registered education provider, offering accreditation within the National Framework of Qualifications (NFQ) and an alternative path to education for young people who may not be in mainstream education
• A registered charity and company located at the office address of:
  iScoil, Acorn Centre, Warrenmount, Blackpitts, Dublin 8, D08 W2X8
• A provider of education in a place other than a recognised school under Section 14 of the Education Welfare Act 2000,
  whose staff are “Mandated Persons” under the Children First Act 2015

Typically the personal information of a young person and/or parent/guardian is provided to iScoil by an Education Welfare Officer, or other authorised persons acting on behalf of a young person or parent/guardian in an official capacity, as part of a referral or application process.

On occasion a local agency or organisation (for example a youth service) may contract iScoil to provide a learning service. With a parent’s or guardian’s permission, where needed, they will provide us with the relevant information we need to provide our service.

You may have provided information directly to iScoil yourself voluntarily or upon request, as the young person (where appropriate) or as the parent/guardian on behalf of the young person.

Other information, will have been requested and collected, generated or noted by a support worker in a partner centre or iScoil staff during a young person’s application process or time on iScoil.

While the majority of information we collect is required to provide our service, there is some information that can be provided voluntarily. When we collect such information, we make it clear whether providing it is required or optional.

The referral form on our website is intended for official use only, referrals submitted by parents directly or anyone we believe to not have authorisation to do so will be anonymised and/or deleted where appropriate.

For a young person referred to iScoil (whether accepted or not) the information we keep includes:

• your name, address, contact details, PPSN, nationality, ethnicity and language
• the reasons and details of your referral/application to iScoil
• your parents/guardians’ details and circumstances
• your previous school, behaviour and attendance
• your health, mental health, emotional well being, any special educational needs, safety and welfare, personal circumstances
• how and where you plan to access iScoil if accepted
• records of any data protection requests

For a young person accepted onto iScoil, we also keep information about:

• any and all changes to the information listed above while on iScoil
• your academic engagement and performance while on iScoil, and details of the qualifications achieved during your time on iScoil
• your iScoil attendance, login times, IP Address, how and where you access iScoil from, reasons why you may not have logged in or completed coursework
• your Moodle account and profile picture, coursework you submit including any image/photos/videos you submit as part of your coursework
• records of all communications such as emails, letters, correspondence, details of phone calls, SMS texts, live web calls, moodle messages and forum posts
• your progression details after you leave iScoil
• other administrative documents such as those required by the
  Quality and Qualifications Ireland (QQI), Dept of Education and Skills, or Tusla
• records of any child protection concerns
• records of any data protection requests

iScoil uses your personal information for the following:

• to help iScoil decide if our service is a good solution for you
• to keep statistics on the range of reasons young people are referred to iScoil
• to get in touch with you and your parents/guardian when we need to
• to help tailor our service to the educational needs of young people
• to check and maintain a young person’s progress and educational development so they can achieve their accreditation
• to keep a record of the qualifications and accreditation achieved should you ever need it for the future
• to gather statistics on the learning outcomes of the students that have used our service
• to check, maintain and report on the quality of iScoil’s education service
• to administer, research, develop and improve iScoil’s education service
• to coordinate, evaluate, fund and organise educational programmes
• to process grant applications and scholarships
• to provide appropriate duty of care and sensitivity to each young person’s personal circumstances
• to safeguard and act in the best interests of young people accessing our service
• to comply with our legal obligations, process appeals, resolve disputes, and defend any legal claims
• to market or promote iScoil’s service, in the case of any consent required to do so, we will contact you to give you the opportunity to opt in or opt out

In addition, for reassurance, the public results of any statistical or research projects iScoil carries out, that use your personal information, are done so anonymously and will not contain any personally identifiable information.

We collect and use personal information to meet legal requirements and legitimate public interests as set out in the Education Welfare Act 2000 and/or the Children First Act 2015, Data Protection Act 2018, General Data Protection Regulation (GDPR).

To comply with GDPR, any information iScoil holds and uses, fulfils one of the following reasons from Article 6 of GDPR:

• 1(c) it is necessary for compliance with a legal obligation to which iScoil is subject
• 1(d) it is necessary to protect the vital interests of a person. This would apply if iScoil became aware that you, or anybody else, were at risk of serious danger for any reason
• 1(e) it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in iScoil under the acts mentioned above
• 1(f) it is necessary for the purposes of iScoil’s legitimate interests of providing and developing quality education and accreditation
• In the case that we want to use your information for anything other than these reasons we will contact you or your parents/guardians to confirm your consent in accordance with Article 6 1(a). You or your parents/guardians may withdraw this consent at any time. We will make this clear when we ask for consent, and explain how to go about withdrawing consent.

Processing of Special Categories of Personal Data

Information such as, a young person’s PPSN, ethnicity, health and mental health or behaviour for example, are called “special categories of personal data”.
When we hold and use this type of special or sensitive information we do so for the following reasons as covered in Article 9 of GDPR:

• 2(c) it is necessary to protect the vital interests of a person.
  This would apply if iScoil became aware that you, or anybody else, were at risk of serious danger for any reason
• 2(f) it is necessary for the establishment, exercise or defence of any legal claims
• 2(g) it is necessary for reasons of substantial public interest under the acts mentioned above
• 2(j) it is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes

In the case that we want to use your information for anything other than these reasons we will contact you or your parents/guardians to confirm your consent to use special category data in accordance with Article 9 2(a). You or your parents/guardians may withdraw this consent at any time. We will make this clear when we ask for consent, and explain how to go about withdrawing consent.

iScoil staff are acutely aware and sensitive to the circumstances of the young people we work with. We take the storage and security of your personal information very seriously.

In particular:

• iScoil requires any platforms or service providers we may contract to store or manage your information to have strict confidentiality and data protection policies with industry standard security and technical measures in place to protect your and our information. However, the nature of the Internet is such that we cannot guarantee or warrant the security of any information transmitted via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. We will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal information
• we ensure robust iScoil staff login and access policies are in place on these platforms
• any physical hard copy information is kept in locked cabinets
• any information that is referred to us from other agencies is done so through encrypted means

The following will outline how long we hold personal information:

• we will not retain your information for longer than is necessary to fulfil the purpose it is being used for
• where possible we endeavour to minimise the amount of information we hold and use during this retention period and will anonymise and/or securely delete such information after this retention period
• for young people referred to but not accepted on iScoil: We will retain the information held until the young person is 25 years of age, or for a period of 7 years from the time of the last contact/interaction with iScoil, whichever is longer. After this time iScoil will anonymise and minimise the information held to gender, county and main reason for referral
• for young people accepted on iScoil: We will retain the information held until the young person is 25 years of age, or for a period of 7 years from the time of the last contact/interaction with iScoil, whichever is longer. After this time iScoil will minimise the information we hold to only the student’s name, address, contact details, PPSN, date of birth, gender, reason for referral, years with iScoil, qualification records, progression records, proof of consent (if applicable), child protection records. This remaining information will be kept indefinitely by iScoil
  
• as previously mentioned, referrals submitted by parents directly or anyone we believe to not have authorisation to do so will be anonymised and/or deleted within one month where appropriate

In general iScoil does not share your information with anyone outside of iScoil without a valid reason or your permission where needed. However, on occasion we will need to share certain information to meet our legal obligations, provide our service or for reasons in the best interest of the young person.

These include:

• registering a young person accepted on iScoil with Tusla and to update the Department of Education and Skills
• relevant details of a young person and their portfolio of coursework to Quality and Qualifications Ireland (QQI) so a young person can achieve their accreditation
• weekly reports of a young person’s progress sent to support workers (for centre based students) or to parents
• updates on a young person’s progress on iScoil to an Education Welfare Officer if requested or required
• details of your qualifications or any information we keep to a young peron’s parents/guardians up until they are 18 years of age
• to trusted platform and service providers who deliver and maintain the systems iScoil uses to provide and administer our service and organisation. As mentioned previously, these service providers are contracted by iScoil subject to strict confidentiality and data protection policies with industry standard security and technical measures in place to protect your and our information
• to other educational providers upon request, for example, a reference or confirmation of the qualifications achieved by a young person
• to other regulatory or statutory bodies, lawful agencies or emergency services in order to comply with our legal obligations and rights

Certain service providers who store information on behalf of iScoil may transfer personal information for processing outside the EU.
Where this is the case, iScoil ensures that the same GDPR appropriate policies are in place to protect this information.

iScoil does not engage in automated decision making/profiling in relation to your information.

To find more about how we use cookies please visit the links below:

• iScoil.ie Cookie Policy
• iScoil’s Moodle Cookie Policy

Under data protection legislation, young people and parents/guardians have the right to request access to personal information iScoil holds about them.

If we receive a request iScoil will need confirmation of you or your parent/guardian’s identity to 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 information is not disclosed to any person who has no right to receive it.

Other Rights

You also have the right to:

• object to processing of personal information that is likely to cause, or is causing, damage or distress
• object to decisions being taken by automated means
• in certain circumstances, have inaccurate personal information corrected, deleted or destroyed, or restrict iScoil from using it
• request transfer of your personal information in an electronically useable format you or another party can easily use
• as previously mentioned, in the limited circumstances where you may have provided your consent for iScoil to use particular information, you have the right to withdraw your consent for that specific information at any time, unless we have another legitimate basis for keeping it

To make an access request for your personal information or exercise any of your rights, contact iScoil’s Data Protection Officer dpo@iscoil.ie or call the iScoil office on 01 4537570.

In certain circumstances, iScoil may not be able to comply with the request for legal or practical reasons, but we will give a full explanation why at that time.

If you have a concern about the way we are collecting or using your personal data, we ask that you raise your concern by contacting us first.

You have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at https://www.dataprotection.ie/docs/Contact-us/b/11.html

Our Privacy Policy may change from time to time and any changes to the policy will be communicated to you by way of an e-mail, SMS or on our website.