Privacy Policy

Washington International School (WIS) is committed to securely and appropriately collecting and processing personal data that is provided to us. This Privacy Policy explains the School’s practices related to personal data and the security measures and policies in place to protect it. We may update this Privacy Policy from time to time and the last posted version will be the current version. This Privacy Policy gives information regarding your personal data as defined under the Privacy Laws (defined below) and describes the basis on which we process your personal data, for what purposes, your privacy rights under applicable privacy laws including the General Data Protection Regulation (“GDPR”) and other UK and European data privacy laws (the “Privacy Laws”) and how we protect your personal data. The Privacy Laws only apply to residents of the European Economic Area, Switzerland and the UK. Under the Privacy Laws, WIS is the data controller and our contact details are listed below.

CONSENT
Sharing personal information with WIS is voluntary. By providing your personal information to WIS — through any means such as an application, email, or form — you give your consent for the School to collect and process your data. Children may not provide personal information to WIS. Only individuals over the age of 16 may provide personal information. We may also collect personal data provided by you in recorded calls. We may also collect special categories of personal data (as defined in the GDPR and including health, disability and religious or ethnicity information) where provided by you, with your consent, for purposes required by you such as scheduling of meetings or access to our premises.

DATA COLLECTED, PURPOSE & RETENTION
The personal information you share with WIS is used to provide you with school-related services, including academic reports, publications, and activities. WIS stores the personal information that you choose to provide (which may include name, contact information, date of birth, gender, citizenship, ethnicity, and employment and background information such as educational and work details). We use the personal data for the performance of contractual obligations (including taking pre-contractual steps) with you. We are also permitted to process the personal data to comply with our legal and regulatory obligations or otherwise in our legitimate interests. We also use the personal data for marketing purposes where you have consented to receive marketing communications. The personal data is processed by us and our vendors in the United States, which may have a lower standard of data privacy laws than in your country of residence. We do not allow any third parties to have access to your personal data, except as required or permitted by applicable laws or in accordance with the Privacy Policy. We may disclose your personal data to the subcontractors, agents, or payment service providers (who may be located in the United States) that we contract with to assist us in providing the services including providing advisory services and background screening services, provided that any such subcontractors or agents shall agree in writing to comply with the privacy and security standards required by the Privacy Laws.

WIS will retain an individual’s personal data for the purposes for which it was provided and for any legal or regulatory requirements thereafter.

After a student has graduated or otherwise left the School, the student’s personal data, the personal data of their relationships, and the student’s school records will be retained for seven years (unless the individual requests that it be destroyed earlier).

After seven years, if the student and/or their relationships have not continued their business with the school as an alumnus, their personal identifying information will be destroyed. After seven years, a student’s file, with the exception of the academic transcript, will be destroyed. Documents that will be destroyed may include: emergency contact information, academic progress reports, immunization records, court orders, disciplinary records, social developmental evaluations, and academic testing.

Academic transcripts — which may include primary, middle, and upper school grades, enrollment history, and proof of graduation — will be retained by the School for as long as the purpose for which that data is used by the School remains ongoing, but for not longer than 75 years. The transcript must contain student name and academic year. It may also contain additional personally identifying information including address, birth date, and names of parent/guardian.

If, after seven years following their graduation or departure from the School, a former student and/or their relationships continue to conduct relevant business with the School as an alumnus, their personally identifying information will be retained. Seven years after that relevant business relationship has ended, the personal data that was provided will be destroyed.

DATA SOURCES
As noted above, the majority of data collected by WIS is provided by individuals who choose to share their information. Please note the following exception regarding our Advancement Office.

The Advancement Office supports the WIS mission by fostering relationships between and among the School's constituents, and by securing charitable gifts. To support its work, the Advancement Office collects and maintains data including: names; contact details/preferences; attendance at events; volunteer service; relationships with other members of the WIS community; education; employment; professional activities; interests and activities; as well as publicly available information on financial assets, philanthropy, and service. The Advancement Office collects data provided through the school’s admissions process, event registrations, conversations with WIS staff and volunteers, change-of-address notifications and donation forms. In keeping with common practice among independent schools, WIS also updates records with data collected from publicly available sources such as Facebook, LinkedIn, Research Point, and Alumni Finder.

In accordance with WIS protocols, the Advancement Office does not share personal data with third parties, other than those that process data on behalf of the school for specified, legitimate educational or operational purposes. The Advancement Office may share data with school constituents who are working on behalf of the school to assist in volunteer programs, alumni activities, and fundraising efforts.

 

AFFILIATE BUSINESSES (SUB-PROCESSORS OF DATA)
WIS shares information with affiliate businesses in order to better serve you. The School only shares information with affiliates who have secure privacy policies that meet industry standards. You will find a list of the School’s affiliates/sub-processors below. Information may also be shared with an affiliate for the following reasons:

  • In the unlikely event that the School has reason to believe that the disclosure is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with rights or property of WIS or anyone else that could be harmed by such activities or where the School believes in good faith that the law requires it or it is necessary to respond to a government request.
  • In the event of the sale or transfer of all or a portion of WIS’s business or assets to a third party, such as in the event of a merger, acquisition, or bankruptcy reorganization.
  • To comply with the law or respond to compulsory legal process (such as a search warrant or court order) or request for information from a regulator or otherwise for legal purposes.
  • To verify or enforce compliance with the policies governing our services.
  • With your consent.

In any instance where we need to share your personal data with third parties, we will restrict the nature and categories of personal data to that which is required to comply with our contractual obligations to you or our legal and/or regulatory requirements. We may de-identify your personal data to protect your privacy.

Student & Parent Data

Alumni Data

Employee Data

ACCESS TO DATA
Only authorized individuals at WIS (as determined by the School) and approved sub-processors have access to your personal data. You may request to view, update, restrict the use of or delete your personal information at any time by contacting registrar@wis.edu. You may also have rights of data portability under applicable Privacy Laws. Please contact us if you wish to exercise this right.

Your name, home address, email, cell phone number, job title, and employer (if provided) will be added to our password-protected community directory where it can be viewed by other parents, teachers, and staff. You may request to have your information hidden from view by contacting info@wis.edu. Parents may manage their email subscriptions by logging into the Parent Portal.

COOKIES
A cookie is a small text file stored by your browser that allows the website to “remember” your preferences (such as calendar settings and site bookmarks) on the site from visit to visit, or to maintain your “logged in” status when visiting protected areas. Subject to the Privacy Laws, usage of a cookie is in no way linked to any personally identifiable information while on our site. Web browsers have settings allowing you to reject cookies, or selectively accept cookies, or delete cookies previously accepted. Please be aware that rejecting or deleting cookies from our website may make certain functions unavailable to you. You can adjust your browser to delete cookies if you wish. See www.allaboutcookies.org for more information.

Our platform uses several different categories of cookies:

Necessary for Operation of the Site
Certain cookies are necessary for the operation of the site. For example, certain cookies are used to help keep track of your session status. This makes it possible for you to stay logged into the site as you move from page to page.

User Preferences
We may use cookies to store certain user preferences that you make as you use our site. This allows your preferences to be used when you visit the site at a future time.

Tracking
We use cookies and other tracking technologies to track what pages you visit and how long you stay on a page. We use this information to measure how our site is used and to improve our product. We also use this information to track what users have received administrative notices so we can only show these notices to each user once.

LOG FILES
We use website statistic packages such as Google Analytics to analyze trends in how our website is accessed and to make improvements so our community and visitors can find and navigate our website more easily. Information monitored includes internet protocol (IP) addresses, geographic location of visitors (country, city), browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, time spent on pages, and keywords used to find our site via search engines. This information is anonymous and cannot be directly linked to individual users.

LINKS
The WIS website may contain links to other sites. Please be aware that we are not responsible for the privacy practices of other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.

SECURITY
The WIS website takes every precaution to protect our users' personal information. Whenever users submit personal information (such as contact information or credit card information) via online forms, registration, or online purchase, upon submission that information is encrypted via the highest level of SSL (Secured Sockets Layer) available. Servers that store personally identifiable information are in a secure environment. Under no circumstances are credit card numbers permanently stored on our website servers.

WIS takes significance steps to help protect against the loss or theft of personally identifying information. For example, our firewall and Intrusion Detection/Prevention systems (IDS/IPS) at each campus protect the data stored and transmitted within our infrastructure. Also, antivirus and malware protection software is installed on all the servers and school-owned laptops (faculty, staff and student carts). Furthermore, all school-owned mobile devices such as iPads and cell phones are managed and supervised by a Mobile Device Management (MDM) application. Finally, Cisco OpenDNS umbrella is policing all the incoming and outgoing traffic to WIS network.

No data transmission over the Internet can be guaranteed as completely secure. As a result, we cannot guarantee the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your personal information.

Should there ever be a data security breach at WIS or through one of our sub-processors, WIS will contact the appropriate authorities immediately and all affected users will be notified within 72 hours.

CHANGES TO OUR PRIVACY POLICY
WIS will review the privacy policy as needed and at least annually. If changes are made to the policy, the School will publicize the changes on the website and through email.

QUESTIONS ABOUT OUR PRIVACY POLICY
If you wish to raise a complaint on how we have handled personal data, you can contact us at the email address below and we will investigate the matter and respond to you promptly. Under applicable Privacy Laws, you may also complain to any applicable data privacy authority in the country in which you are resident. If you have any questions about this privacy statement please contact: info@wis.edu or 202.243.1800. Our address is: 3100 Macomb Street NW, Washington, DC 20008.

 

This policy was last updated September 10, 2018.