SPM's Privacy Notice and Data Protection

Under international data protection laws, individuals have a right to be informed about how the school uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.

This privacy notice explains how we collect, store and use personal data about students.

We, Sekolah Perkumpulan Mandiri, are the ‘data controller’ for the purposes of data protection law.

Personal data that we may collect, use, store and share (when appropriate) about students and prospective students includes, but is not restricted to:    

• Contact details, contact preferences, date of birth, identification documents
• Results of internal assessments and externally set tests
• Student and curricular records
• Characteristics, such as ethnic background, or special educational needs
• Exclusion information
• Details of any medical conditions, including physical and mental health
• Attendance information
• Safeguarding information
• Details of any guardian issues
• Photographs
• CCTV images captured in school
• Evidence of learning (Worksheets, projects, presentations, audio, video and photographs)

We may also hold data about students that we have received from other organisations, including other schools, local authorities and the Department for Education.

We use this data to:

• Support student learning
• Monitor and report on student progress
• Provide appropriate pastoral care
• Protect student welfare and safety
• Assess the quality of our services
• Administer admissions waiting lists
• Carry out research
• Comply with the law regarding data sharing

We only collect and use students’ personal data when the law allows us to. Most commonly, we process it where:

• We need to comply with a legal obligation
• We need it to perform an official task in the public interest
• We need it to comply with a department of Education regulations

Less commonly, we may also process students’ personal data in situations where:

• We have obtained consent to use it in a certain way
• We need to protect the individual’s vital interests (or someone else’s interests)

We have obtained consent to use students’ personal data within the registration form completed by parents upon application to our school. Some of the reasons listed above for collecting and using students’ personal data overlap, and there may be several grounds which justify our use of this data.

While the majority of information we collect about students is mandatory, there is some information that can be provided voluntarily.

Whenever we seek to collect information from you or your child, we make it clear whether providing it is mandatory or optional. If it is mandatory, we explain the possible consequences of not complying. For example, in following Government enforced vaccination programs.

We keep personal information about students while they are attending our school. We also keep this information beyond their attendance at our school per Department of Education regulations.

The School stores Student data on the local server within the school grounds and each student has their own data folder. We guarantee the security of student data stored on our local server by applying a high level of security standards.

In addition to the local server, we also store student data in Google Drive in the SPM School account with the aim that students can access their data remotely. This data is stored under Google Education’s rules and regulations.

The data that a person stores within his/her folder or account is the property of that individual. They then have the authority to share that data with others.

We do not share information about students with any third party without consent unless the law and our policies allow us to do so.

Where it is legally required, or necessary (and it complies with data protection law) we may share personal information about students with:

• Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions
• The Department for Education – to meet our legal obligations and as it is necessary for the performance of a task carried out in the public interest and in the exercise of authority
• The student’s family and representatives - to meet our legal obligations to share certain information with them, such as safeguarding concerns and exclusions
• Educators and examining bodies - to meet our legal obligations and as it is necessary for the performance of a task carried out in the public interest and in the exercise of authority
• Our regulator, e.g. DIKNAS – to meet our legal obligations and as it is necessary for the performance of a task carried out in the public interest and in the exercise of authority
• Suppliers and service providers – to enable them to provide the service we have contracted them. e.g. Insurance Providers
• Our auditors – necessary for compliance with a legal obligation
• External survey and research organisations – with parents/carers consent
• Health authorities – necessary for compliance with a legal obligation, such as safeguarding. In other cases, the health professional seeks consent through the school
• Professional advisers and consultants – necessary for the performance of a contract
• Charities and voluntary organisations - necessary for the performance of a task carried out in the public interest and in the exercise of authority
• Police forces, courts, tribunals – necessary for compliance with a legal obligation
• Professional bodies – necessary for the performance of a contract

We are required to provide information about Students to the Department for Education as part of statutory data collections.

Some of this information is then stored in the National Student Database, which is owned and managed by the Department and provides evidence on school performance, and individual student performance to inform research.

The database is held electronically so it can easily be turned into statistics. The information is securely collected from a range of sources including schools, local authorities and exam boards.

The Department for Education may share information from the National Student Database with other organisations which promote children’s education or wellbeing. Such organisations must agree to strict terms and conditions about how they use the data.

Individuals have a right to make a ‘student data access request’ to gain access to personal information that the school holds about them. Most common in cases where students transfer to another school outside of Indonesia.

If you make a subject access request, and if we do hold information about your child, we will:

• Give you a description of it
• Tell you why we are holding and processing it, and how long we keep it for (following Department of Education Guidelines)
• Give you a copy of the information in an intelligible form (if all school fee payments are up to date). 

Individuals also have the right for their personal information to be transmitted electronically to another organisation in certain circumstances.

If you would like to make a request, please contact our Student Services Department.

Under international data protection law, individuals have certain rights regarding how their personal data is used and kept safe, including the right to:

• Object to the use of personal data if it would cause, or is causing, damage or distress
• Prevent it being used to send direct marketing
• Object to decisions being taken by automated means (by a computer or machine, rather than by a person)
• In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
• Claim compensation for damages caused by a breach of the data protection regulations

To exercise any of these rights, please contact our student services department. If any of these data issues conflict with school requirements, then a win-win solution has to be found.

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our student services:

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• +62816-1690-005