Privacy and Non-Discrimination Policies

Emma Willard School (“We”, “the School” or “Us”), originally called Troy Female Seminary and often referred to simply as Emma, is an independent university-preparatory day and boarding school for young women, located in Troy, New York, offering grades 9–12 and postgraduate coursework.
 
For the purposes of this policy, Emma Willard School is the "data controller" of personal information ("your personal information") about current, past, and prospective students ("students"); and their parents or guardians ("parents"), as well as employees and applicants for employment (“employees”).

This Privacy Notice is intended to provide information about how We will use personal information about individuals, including: students, parents, and employees and applicants for employment. This information is provided in accordance with the rights of individuals under Data Protection Laws (as applicable) to allow you to understand how your personal information is used. All constituents are encouraged to read this Privacy Notice and understand our obligations to you and the entire school community. 

This Privacy Notice applies alongside any other information we may provide about a particular use of your personal information, for example when collecting information via an online or paper form.
 
This Privacy Notice applies in addition to other relevant terms and conditions and policies we have in place, including:

• Any contract between the school and student parents;
• The taking, storing, and using images policy (media consent);
• Safeguarding, residential life, or health and safety related policies, including as to how concerns or incidents are recorded; and
• IT policies, including Student’s Acceptable Use and Personal Device policy.

Anyone who works for, or acts on behalf of, the School (including staff, volunteers, and service providers) are made aware of and should comply with this Privacy Notice and our data protection procedures.
 

We have appointed a Data Protection Officer (DBO) to act as our Data Protection Lead with the overall responsibility for data protection in the School, and who will deal with all your requests and inquiries concerning our uses of your personal information (see section on Your Rights below). We will endeavor to ensure that all personal information is processed in compliance with this policy and Data Protection Laws (as applicable). The Data Protection Officer can be contacted by email: dpo@emmawillard.org
 

Personal Information, often referred to as data, is information that identifies you as an individual. This includes information such as your contact details, emergency contacts, medical history, and financial information. We may also hold demographic information such as your ethnic group. Surveillance footage, photographs, and video recordings of you are also personal information as defined in this Policy.

Our goal is to collect the minimum amount of information necessary - whether from students, parents, employees, or contractors.
We collect information you provide to us. A person’s interaction with Emma Willard School occurs during the admissions process, throughout a student’s enrollment at Emma Willard School, during matriculation, and as alumnae.  We also collect information from applicants for employment as well as employees and contractors of the school.

Generally, we receive personal information from the individual directly (including, in the case of students, from their parents). This may be via a form, or simply in the ordinary course of interaction or communication (such as via email or written assessments).
However, in some cases personal information may be supplied by third parties (for example, another school, or other professionals or authorities working with that individual); or collected from publicly available resources such as internet searches in the course of due diligence of prospective donors.

It is important to the School to protect the privacy of young children who may use our website.  The School does not knowingly solicit or collect the personal information of children under the age of 13 on this website.  Children under the age of 13 are not permitted to submit an inquiry form or application to the School.  Parents or legal guardians of a child under the age of 13 must complete the inquiry form and consent to the submission of an application to the School.

Types of Personal Information We Process

Here are some examples of types of Personal Information we typically process:

• Names, addresses, telephone numbers, e-mail addresses and other contact details;
• Car details (for those who use our car parking facilities);
• Financial information, e.g. about parents who pay fees to the school, including in some cases information from third parties such as credit reference agencies or a previous school;
• Past, present, and prospective student academic, disciplinary, admissions and attendance records (including information about any special needs), and examination scores;
• Where appropriate, information about health and welfare, and contact details for emergency contacts;
• References given or received by us about students, and information provided by previous educational establishments and/or other professionals or organizations working with students;
• Correspondence with and concerning students and parents;
• Images of students (and occasionally other individuals) engaging in school activities, and images captured by the school's  surveillance system in accordance with the school's policy on taking, storing and using images of children;
• Careers and professional information to support our student Signature and Practicum programs;

   
Website Usage Information, Site Activity and Location Information
We automatically collect information regarding the actions you take on the school’s website ("Usage Information"). Usage Information helps us understand trends in our users’ needs and improve our website and its functionality.  We also may use Usage Information for general marketing purposes. This Privacy Policy in no way restricts or limits our collection and use of Usage Information, and we may share Usage Information about our users with third parties for various purposes, including to help us better understand your needs and improve our website. Some examples of the Usage Information we may collect include: the type of Web browser you use, your operating system, your web requests, your Internet Service Provider, your IP address, referring/exit pages and URLs, the pages you view and how you interact with links on our website, the time and duration of your visits to the website, and other such information. We may store such Usage Information itself and/or such information may be included in databases owned and maintained by agents or service providers. We may also collect information that identifies the device you use to access the website, your device’s unique device ID, the IP address of your device, your operating system, connection type (e.g. WiFi or cellular) and GPS technology (or other similar technology) to determine your current location when you use a mobile device to access the website. If you do not want us to have your location information, you should turn off the location services before accessing the website from a mobile device. We may use such information and pool it with other information to track, for example, the total number of visitors to our website, the number of visitors to each page of our website, among other data points of interest. 

Cookies
We use cookies (a small text file placed on your computer to identify your computer and browser) to improve the experience of the site and services we provide, such as pre-populating your username for easier login, to allow user-specific messaging or to permit user-specific advertising. We do not use cookies to collect Personal Information.

There is a cookie that ASP.NET automatically creates and uses for maintaining website sessions. This cookie does not gather Personal Information and expires when the browser is closed, or the session is ended.

Most Web browsers are initially set up to accept cookies. At this time, the school does not recognize automated browser signals regarding tracking, including "do-not-track" signals. You can remove persistent cookies and change your privacy preferences by following directions provided in your Internet browser’s "help" directory. However, certain features of the site or services may not work if you delete or disable cookies. Some of our third-party providers may use their own cookies in connection with the services they perform on our behalf.

Email and Web Inquiries
You also may send us Personal Information, for example, in an email message containing a question or comment, or by completing a web form that provides us with this information.  We use Personal Information from these communications primarily to respond to you.  We may forward your correspondence to school representatives who are better able to answer your questions.  We may also use your email to contact you in the future about our programs that we deem may be of interest to you.  We do not share your name or email address with any third parties. 

Admissions
It is expected that information shared with Emma Willard School during the admission process is given with the consent of a parent.  The school does not knowingly collect information from anyone under the age of 18 without the consent of a parent. 
During the admissions process, Personal Information will be collected and stored about the applicant and family for the purposes of evaluating the applicant.  Emma Willard School will also use the information for communicating with the family during the admissions process.

Personal Information about applicants and their parents and siblings will be collected via our website (the Inquiry Form), as well as by The Standard Application Online administered by the Enrollment Management Association, The Gateway to Prep School Application, or other similar common applications administered by a third party.  Additional information may be collected by the admissions office via various interviews, phone calls, reference checks, and emails.

Types of Personal Information collected include names, addresses, phone numbers, emails, gender, dates of birth, race, ethnicity, nationality, citizenship, educational history, and legacy status.  Further, we collect information about the student’s academic and disciplinary history, athletic and extra-curricular records and interests, and possibly financial information (to process financial aid requests). Additional information regarding the applicant’s parents such as employment and marital status  will also be collected.
As part of the admissions process, the school also may gather or receive information from other sources regarding medical/educational records, standardized tests, and other evaluative material.  The types of information we collect in these cases may be specific to the individual.

We receive and process such Personal Information pursuant to your agreements with such third-party service providers, and in furtherance of your agreement with us concerning your application and matriculation, and pursuant of our legitimate interests in assessing your application.  For information on the privacy practices of such third parties, please consult your agreements with them and their own privacy policies.

You are required to provide this information if you would like to apply to or be enrolled at Emma Willard School.  Without this information, Emma Willard School cannot process a student’s application or enroll them. To the extent that any requested Personal Information is not necessary for the performance of Emma Willard School’s agreements and policies, such requests will be separately identified, and the appropriate consent obtained.  

Applicant information is kept permanently. 

Matriculation
It is expected that information shared with Emma Willard School during a student’s enrollment is given with the consent of a parent. The school does not knowingly collect information from anyone under the age of 18 without the consent of a parent.
Once enrolled, Emma Willard School continues to collect and process Personal Information for the purposes of caring for and educating the student.  The Personal Information is used to keep you informed about the school and to offer you access to school services.  Personal Information will also be collected, created, and stored about the student and family for the purposes of tracking student progress at Emma Willard School.

The information collected from enrolled students and their families includes names, addresses, phone numbers, emails, gender, and dates of birth.  Health and medical information regarding the student is collected to ensure their well-being while on campus.  Further, we collect information about the enrolled student’s academic, athletic, and extra-curricular records and interests, and possibly financial information. Information about performance (classes, co-curricular activities, etc.) and images of the student engaged in academic, athletic, and extra-curricular activities also may be collected and maintained.  We may post information about performance and images of the student on the internet and in publications.

Emma Willard School may gather or receive Personal Information from other sources, such as testing agencies (including, medical/educational, standardized tests, etc.).  The types of information we collect in these cases may be specific to the individual.  We receive and process such information pursuant to your agreements with such third-party service providers, and in furtherance of your agreements with us concerning your matriculation. For information on the privacy practices of such third parties, please consult your agreements with them and their individual policies.

This information collection is required if one wants to be enrolled at Emma Willard School.  To the extent that any requested personal information is not necessary for the performance of Emma Willard School’s agreements and policies, such requests will be separately identified, and the appropriate consent obtained.

Student records are kept permanently.

Alumnae and Friends
Alumnae, friends, and parents are lifelong members of Emma Willard School community.  The Advancement Office of Emma Willard School is dedicated to keeping our alumnae, friends, and parents (past and present) connected to the school.  

Types of information collected from alumnae and friends of the school include name, address, phone number, email, gender, date of birth, employment, gifts received, and events attended.  Credit card numbers are collected and used only for donation or payment processing through an encrypted, secure, third party processing system, and are not retained for other purposes.

The Personal Information we collect from alumnae and friends is used for a variety of reasons, including:

• Directory information, including the online alumnae community;
• Communicating with you to let you know about receptions, reunions, and other events with alumnae or Emma Willard faculty/administrators in the area;
• Making you aware of projects and opportunities to support the school (via volunteering, gifts, etc.);
• General fundraising;
• Surveys; and
• Promoting services we may offer to alumnae.

Since Emma Willard School likes to keep in contact with you for life, we retain these records permanently.
For any questions regarding the collection or use of alumnae information, please contact the school’s Data Protection Officer (DBO) at dbo@emmawillard.org.

Applicants for Employment, Employees and Contractors
Emma Willard School collects information from applicants for employment, employees, and contractors of the school.  The school uses an employment application to collect Personal Information, such as biographical information, gender, date of birth, employment history, and employment/personal references on all applicants for employment.  This information becomes part of the employee’s file once hired.  Emma Willard School also conducts extensive background checks and, if applicable, a credit report on its employees.  Upon hire and throughout employment at the school, the employee may provide additional information to the school, such as bank information, health information, beneficiary and dependent information, and other information related to such employment.   The school collects EIN or social security numbers from contractors and may collect bank information for payment purposes.  Certain contractors with direct, unsupervised access to students will need to provide personal information such as biographical information, date of birth, employment history, and employment/personal references. The school also will conduct background checks of such contractors with direct, unsupervised access to students.
 

In order to carry out our ordinary duties to students and parents, we need to process a wide range of Personal Information about you as an individual (whether as a current, past, or prospective student or parent). Our primary reason for using Personal Information is to provide education services.

Sometimes we will need to collect information in order to fulfil our legal rights, duties, or obligations, including those under a contract with our students’ parents.

Other uses of Personal Information will be made in accordance with our legitimate interests, or the legitimate interests of another, provided that this is not unfair to individuals, and provided it does not involve special or sensitive types of information.

Our legal grounds for using your Personal Information will fall within one or more categories of "legitimate interests":

• For the purposes of student selection (and to confirm the identity of prospective students and their parents);
• To provide education services, including musical education, physical training, and extra-curricular activities to students, and monitoring student's progress and educational needs;
• Management planning and forecasting, research and statistical analysis, including that imposed or provided for by law;
• To enable relevant authorities to monitor the school's performance and to intervene or assist with incidents as appropriate;
• To give and receive information and references about past, current and prospective students, including relating to outstanding fees or payment history, to/from any educational institution that the student attended or where it is proposed they attend; and to provide references to potential employers of past students;
• To enable students to take part in national or other assessments, and to publish the results of public examinations or other achievements of students of the school;
• To safeguard students' welfare and provide appropriate student life care, which may involve the collection  of information about relevant court orders or criminal petitions;
• To monitor (use of our IT and communications systems in accordance with the school's Information Security policy and Students' Acceptable Use policy;
• To make use of photographic images of pupils in our publications, on our website, and on our social media channels in accordance with our policy on taking, storing and using images of children;
• To carry out or cooperate with any School or external complaints, disciplinary, or investigation process;
• For security purposes, including surveillance monitoring and recording in accordance with our Surveillance monitoring policies;
• Where otherwise reasonably necessary for the School's purposes, including to obtain appropriate professional advice and insurance for the School;
• To maintain relationships with the school community and alumnae, including parents of former students, including sending information and invitations about school events, activities, and fundraising efforts;  and
• Donor due diligence, and to profile prospective donors and their background and relevant interests.

In addition, we will on occasion need to process special category personal information  These reasons will include:

• To safeguard students' welfare and provide appropriate student life care, and to take appropriate action in the event of an emergency, incident, or accident, including by disclosing details of a medical condition or other relevant information where it is in your interests to do so, such as for medical advice, social protection, safeguarding, cooperation with police or social services, insurance purposes, or to caterers or organizers of school trips who need to be aware of dietary or medical needs;
• To provide educational services in the context of any special educational needs of a student;
• As part of any school or external complaints, disciplinary, or investigation process that involves such information, i.e. if there are health or safeguarding elements involved; or
• For legal and regulatory purposes (for example child protection, diversity monitoring, and health and safety) and to comply with the school’s legal obligations and duties of care.

We may ask for your consent to use your information in certain ways.

If we ask for your consent to use your personal information you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. Please contact the Data Protection Officer if you would like to withdraw any consent given.

In most cases we will rely on one of the grounds above for a particular use of your information.

Sharing Personal Information with third parties.

Occasionally, we will need to share Personal Information relating to our community with third parties, such as professional advisers (lawyers and accountants) or relevant authorities (DHR, police, or local authorities). In accordance with our legal obligations, we will share information with local authorities, Child Protective Services (SCR), and local law enforcement, when, for example, we have any safeguarding concerns.

We share personal information with our mailing house to support our Communications and Advancement Department.

For students that are not United States citizens, we must ensure that you have the right to study in the United States. We might have to provide information about you to The Student and Exchange Visitor Program (SEVP) and Department of State (DoS) to comply with our duties as a sponsor.

If you are a parent and have unpaid fees while your child is at the school, we may share information about this with other schools or educational establishments to which you intend to send your child.

If your child leaves us to attend another school we may need to provide that school with information about you. For example, details of family circumstances for safeguarding reasons.

Personal Information collected by the school will primarily remain within the school and will be processed by appropriate individuals only in accordance with established access protocols (i.e. on a 'need to know' basis). Particularly strict rules of access apply in the context of:

• Medical records held and accessed only by the school medical staff, or otherwise in accordance with express consent; and
• Student life or safeguarding files held by the Head of School and Dean of Students and Wellbeing.

However, a certain amount of relevant information for any student with special educational needs will need to be provided to staff more widely in the context of providing the necessary care and education that the student requires.

We are under duties imposed by law and statutory guidance to record or report incidents and concerns that arise or are reported, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This may include file notes on safeguarding files, and in some cases referrals to relevant authorities, such as local law enforcement. For further information about this, please view the Healthy Boundaries, Discrimination and Harassment Policy.

We have in place software to monitor student use of technology (e.g. email, internet, mobile devices) for the following purposes:

• To safeguard or promote student welfare;
• To avert a perceived risk of serious harm to students or to another person at the School; or
• To alert our staff to a particular vulnerability the student may have.

In accordance with Data Protection Laws (as applicable), where processing activity is carried out on our behalf by third parties, such as third-party IT systems, web developers, or cloud storage providers, they will have access to Personal Information. This is always subject to contractual assurances that such information will be kept securely and only in accordance with the school's specific directions.

How long we keep personal information.

We will keep Personal Information securely and only in accordance with how long it is necessary to keep for a legitimate and lawful reason. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.

We can keep information about you indefinitely if needed for historical, research, or statistical purposes. 

If you have any specific queries about how our retention policy is applied or wish to request that Personal Information that you no longer believe to be relevant is considered for erasure, please contact the Data Protection Officer. However, please bear in mind that we will often have lawful and necessary reasons to hold on to some Personal Information, even following such a request.

A limited and reasonable amount of information will be kept for archiving purposes, for example years of attendance at the School and transcripts; and even where you have requested we no longer keep in touch with you, we will need to keep a record of that fact in order to fulfil your wishes. Information may also be maintained in standard and customary system backups.

Keeping in touch and supporting us.

In order to carry out our charitable aims, the School may from time to time use the contact details of parents, alumnae and other members of the school community to keep them updated about the school, fundraising activities, or events of interest, including by sending updates and newsletters by email and by postal mail.

Unless you object, we may also collect information from publicly available sources about parents' and former students' occupation and activities, in order to maximize the school's fundraising potential.

Should you wish to limit or object to any such use, or would like further information about them, please contact the Data Protection Officer. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the school may nonetheless need to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).

Rights of Access

As Individuals, you have various rights under Data Protection Laws (as applicable) to access and understand what personal information is held by us, and in some cases ask for it to be erased or amended, or have it transferred to others, or for us to stop processing it, subject to certain exemptions and limitations.

If you wish to access or amend your Personal Information, or wish it to be transferred to another person or organization, or you have some other objection to how your personal information is used, you should put your request in writing to the Data Protection Officer.

We will endeavor to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits for responding.

Requests that Cannot be Fulfilled

You should be aware that the right of access is limited to your own personal data, and certain information is exempt from the right of access. This will include information that identifies other individuals, (and parents need to be aware this may include their own child, in certain limited situations, as further described below), or information that is subject to legal privilege (for example, legal advice given to or sought by the School, or documents prepared in connection with a legal action).

We are not required to disclose any student examination scripts or other information (consisting solely of student test answers), provide examination or other test marks ahead of any ordinary publication, nor share any confidential reference given by the school itself for the purposes of the education, training, or employment of any individual.

You may have heard of the "right to be forgotten". However, we will sometimes have compelling reasons to refuse specific requests to amend, delete, or stop processing your (or your child's) Personal Information,  for example, a legal requirement to maintain such information, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.

Student Requests

Students can make subject access requests for their own Personal Information, provided that, in our reasonable opinion, they have sufficient maturity to understand the request they are making (see the  Whose Rights? below). A student of any age may ask a parent or other representative to make a subject access request on their behalf.

Indeed, while a person with parental responsibility will generally be entitled to make a subject access request on behalf of students, the law still considers the information in question to be the child's. The parent making the request will need to evidence their child's authority for a specific request.

Emma Willard students are generally assumed to have a level of maturity sufficient to have a say in this decision, although this will depend on both the child and the Personal Information requested, including any relevant circumstances at home.

All information requests from, or on behalf of, students - whether made under subject access or simply as an incidental request - will therefore be considered on a case by case basis.

Parental requests

It should be clearly understood that the rules on subject access are not the sole basis on which information requests are handled. Parents may not have a statutory right to information, but they and others will often have a legitimate interest or expectation in receiving certain information about students without their consent. We will consider whether there are lawful grounds for sharing with or without reference to the student.

Parents will in general receive educational and student life updates about their child, in accordance with the Parent Contract. Where parents are separated, the school will in most cases aim to provide the same information to each person with parental responsibility but may need to factor in all circumstances including court orders and the express wishes of the child.

All information requests, whether made under subject access or simply as an incidental request, will therefore be considered on a case by case basis.

Whose rights?

Data protection legislation gives you a number of rights regarding your information. 

The rights under Data Protection Laws (as applicable) belong to you, the individual, to whom the information relates. However, we will often rely on parental authority or notice for the necessary ways we process Personal Information relating to students - for example, under the parent contract, or via a form. 

Where consent is required, it may be necessary or appropriate, given the nature of the processing in question, and the student's age and understanding to seek the student's consent. Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents' rights at law or under their contract, and all the circumstances.

In general, we will assume that student consent is not required for ordinary disclosure of their Personal Information to their parents, e.g. for the purposes of keeping parents informed about the student's activities, progress and behavior, and in the interests of the student's welfare, unless, in our opinion, there is a good reason to do otherwise.

However, where a student seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their Personal Information being disclosed to their parents, we may be under an obligation to maintain confidentiality unless, in our opinion, there is a good reason to do otherwise; for example, where we believe disclosure will be in the best interests of the student or other students, or if required by law.

Students are required to respect the Personal Information and privacy of others, and to comply with the IT Acceptable Use policy and the School Community Rules outlined in Fine Print.

What decisions can you make about your information

• If information is incorrect you can ask us to correct it;
• You can ask what information we hold about you and be provided with a copy. We will also give you extra information, such as why we use this information about you, where it came from and what types of people we have sent it to;
• You can ask us to delete the information that we hold about you in certain circumstances, e.g. where we no longer need the information;
• You can ask us to send you, or another organization, certain types of information about you in a format that can be read by computer;
• Our use of information about you may be restricted in some cases, e.g. if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy;

Correction and Completion
You have the right to request correction of Personal Information that you believe is inaccurate.  Where you believe the information is incomplete, you have the right to complete the information, including by supplementing the information with a statement.  

Information Access
You may request confirmation of whether or not The Emma Willard School is processing Personal Information about you.  If so, you have the right to see or obtain a copy of that information and to learn: for what purpose(s) we are processing that information; the categories of information; the identity of those who receive the information; if we receive personal information about you from other sources, any available information about those sources; and how long we keep the information or, if the period is not determined, the factors that we use to determine that period.

Right of Erasure or Right “To be Forgotten”
You have the right to request that The Emma Willard School permanently delete your personal information when:

• We no longer need your information for the purposes for which it was collected;
• We have been processing the particular information based only on your consent, you withdraw your consent, and there is no other legal ground for us to continue processing;
• You successfully object to the processing of certain information (see “Objection” below);
• The information has been unlawfully processed; or
• Erasure is required by law.

This right will not apply where continued processing of your information is necessary for:

• The exercise of the right of freedom of expression and information;
• Compliance with applicable law;
• Performance of a task carried out in the public interest or the exercise of official authority vested in The Emma Willard School;
• Ensuring the functionality and stability of said system;
• For reasons of public health;
• Certain types of archiving that is in the public interest, scientific, or historical research or statistical purposes; or
• The establishment, exercise, or defense of legal claims.

Although The Emma Willard School may remove most personal information, such as contact information (address, phone number, etc.), there may be information we cannot remove, including, but not limited to, certain records such as the user’s attendance at The Emma Willard School and their grades or information about certain donations made to the school.

Limited Information Portability
With respect to personal information that we have received directly from you (as opposed to information that we may receive about you from sources other than you), you have a right to request and receive such information in a structured, commonly used and machine-readable format.  You also have the right to transmit such information to another entity without interference from us.

Please note that this right of portability applies only in limited circumstances, such as:  where we are processing personal information on the basis of your consent or pursuant to our contractual agreements with you, and the processing is carried out by automated means.  If you request that we transmit your information directly to another individual or entity, we will comply where it is feasible to do so.

Restriction on Processing
You have the right to request that The Emma Willard School stop or restrict the processing of your personal information where:

• You are contesting the accuracy of your personal information, in which case processing could be restricted for the period of time necessary for us to determine the accuracy of the information;
• The processing is unlawful and you oppose the erasure of the personal information and request instead that processing be restricted;
• We no longer need the personal information for the purposes of the processing in question, but you need the information for the establishment, exercise or defense of legal claims; or
• You object to the processing of certain information (see “Objection” below), in which case processing could be restricted for the period of time necessary for us to determine our response to the objection.

If you successfully exercise this right of restriction, we will process the information in question only: (i) where we have your consent to do so; (ii) for the establishment, exercise, or defense of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.  In the event that any such restriction is lifted and processing resumes, we will inform you beforehand.

Objection
You may object to the processing of your Personal Information that is based on The Emma Willard School’s determination that such processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, or that such processing is necessary for the purposes of the legitimate interests pursued by The Emma Willard School.

If we process your Personal Information for purposes of direct marketing, you may object at any time. Direct communications from The Emma Willard School that are for marketing, promotional, or solicitation purposes may contain an option for unsubscribing and if so, will provide instructions for how to do so.

We will endeavor to ensure that all Personal Information held in relation to you is as up-to-date and accurate as possible. You must please notify us of any significant changes to important information, such as contact details.

You have the right to request that any out-of-date, irrelevant, or inaccurate information about you is erased or corrected (subject to certain exemptions and limitations under Data Protection Laws (as applicable)). Please see above for details of why we may need to process your information, of who you may contact if you disagree.

We will take appropriate technical and organizational steps to ensure the security of personal information about individuals, including policies around use of technology and devices, and access to school systems. All employees will be made aware of this policy and their duties under Data Protection Laws (as applicable) and receive relevant training.

The school employs commercially reasonable physical, electronic, and procedural safeguards to protect the confidentiality and security of personal information and other information and data transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. You acknowledge and accept the data security risks of using our website and our services.

Our website offers links to other sites that are not owned or affiliated with The Emma Willard School. These sites have their own security policies, terms of use and privacy policies. If you choose to visit one of these websites you should review the policies of that particular site. The Emma Willard School exercises no control over and is not responsible for the privacy practices or the content of such websites.

This site is hosted and the provision of our services are in the United States. If you are accessing the site or using our services from the European Union, other countries in Europe, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from U.S. laws, please be advised that through your continued use of the site or our services, which are governed by U.S. law and this Privacy Policy, you are transferring your personal information to the U.S., and you consent to that transfer. Your personal information may also be accessible to law enforcement and national security authorities in the United States, without notice to you and without the knowledge or consent of the school. The laws in the U.S. may not be as protective of your privacy as those in your location. By using our site and services, you agree that the applicable laws in the U.S. will govern the collection, use, transfer, and disclosure of your information. If you do not agree to these terms, do not use this site or our services.

The Data Protection Officer is the person responsible at our school for managing how we look after Personal Information and deciding how it is shared.

Like other organizations we need to keep your information safe, up to date, only use it for what we said we would, destroy it when we no longer need it, and, most importantly, treat the information we obtain fairly.

Please speak to the Data Protection Officer if:

• You object to us using your information for fundraising purposes, e.g. to send you information about school developments. We will stop using your information for fundraising purposes if you tell us not to; or
• You would like us to update the information we hold about you; or
• You would prefer that certain information is kept confidential.

Any comments or queries on this policy should be directed to the Data Protection Officer using the contact details: dpo@emmawillard.org

We will attend to your request promptly and will respond within a reasonable time. If you are dissatisfied with our handling of your request, we ask that you give us the opportunity to resolve the issue; however, you have a right to lodge a complaint with the supervisory authority where you are located.  

The School reserves the right, in its sole discretion, to change this Privacy Policy in whole or in part, at any time. Your continued use of the website after any changes to the Privacy Policy have become effective will be considered acceptance of those changes. When we make changes we will also revise the "last modified" date of the Privacy Policy page. We encourage you to review this Privacy Policy periodically.

Effective: February 21, 2020

Updated: November 1, 2022