Privacy Policy

Safeguarding Personal Information of Parents and Students isa fundamental concern of Talmud Torah/HerzliahSchool (“School”)as it pursues its mission of providing excellent educational service. The law,namely, the Act respecting Access to Documents Held by Public Bodies and theProtection of Personal Information (the “Act”), requires that all Staff and board membersof the School adopt certain behavior to protect the Personal Information the School collects,uses, and discloses (“Processes”).

This Privacy Policy (“Policy”) describeshow and why the SchoolProcesses Students’ and Parents’ PersonalInformation and what the Schooldoes to protectit.

We have appointed Ms. Merav Cohen as Privacy Officer toensure compliance with the Act. Ms. Merav Cohen can be reached at the following coordinates and we invite anyprivacy related questions, comments, or complaints to be directed to: mcohen@azrieli-tth.ca.

Scope

All School Staffmembers, contractors and volunteers are required to Process PersonalInformation according to this Policy.

Definitions

“Personal Information” means any information about an individual that can directlyor indirectly identifythem. This includesbut is not limited to all paper and electronic records, photographs and video recordings.

 “Parent” means the parent, legal guardian or other legal representative of a student.“Student” means a prospective, current,or past studentof the School.

“Staff” means someonewho carries out a duty on behalfof the School, paid or unpaid, or who is contracted to, or directlyemployed by the School.

Types of Personal Information the School Collects

The Schoollimits the type of information it collects to what is required to accomplish the purposes listedbelow. This information includes but is not limitedto:

 Nominative information: first and last names of Parents and Students as well as their addresses, School-provided emails, dates of birth,and permanent codes;

 Academic records: evaluation results, capability assessments, and references; Health information: allergies, dietary restrictions, and any medication to be provided;Government issued identification: passportand medicare numbers;

Biometric information: photographs, voice recordings, and videotape.

Purpose of Collection

The School limits the collection of Personal Information to what is strictly necessaryto provide excellenteducation services and fulfill its duty of care toward Students. This includes but is not limited to:

●      communicating with students and parents about matters relatedto the Students’ schooling;

●      tending to Students’ educational, social, and healthneeds;

●      celebrating Students’efforts and achievements;

●      identifying Parentsand Students;

●      compiling studentlists;

●      planning, sourcing,monitoring and evaluating the School’s servicesand functions includingParent participation;

●      daily administering of Schoolactivities;

●      ensuring paymentof School fees;

●      facilitating Student,Parental, or alumnicommunication;

●      soliciting feedbackfrom Parents;

●      complying with governmental reporting requirements;

●      complying with statutory and or other legal obligations;

●      investigating incidentsor defending any legal claims against the School, its services or its staff;

●      complying with laws that impose specificobligations regarding the Processing of Personal Information;

●      facilitating fundraising; and

●      promoting the School (e.g. calendars, SchoolWeb site or other promotional material).

The School undertakes to identify the reasons forcollection either before or at the time the Personal Information is collected. If the School wishes to usethe Personal Information it collects for a purpose other than what it has identified, it will obtainappropriate consent unless not requiredto do so by law.

Please note that in the case of photographs and video recordings used for promotional purposes, the School will ask parents to provide explicitconsent at the beginning of every schoolyear.

How the School Collects Personal Information

The School mostlycollects Personal Information through its onlineCOBA portal. Occasionally parents may also be asked to completemedical forms that request PersonalInformation.

 By providing information through one of the means listed above,Students and Parents consent to the School’sProcessing of this information for the purposesoutlined in this Policy. Parents and Students are at liberty not to providecertain Personal Information and are free to withdrawtheir consent to the elementsthat they have consented to provide at any time. Failure to provide the School with such PersonalInformation and/or a withdrawalof consent to the Processing of certain Personal Information may prevent theSchool from fully providing its education servicesor effectively meetingits duty of care.

Disclosure of Personal Information

The School limitsthe Personal Information it discloses to what is necessary to fulfill the purposes for which it was collectedunless:

●      the person consents to the disclosure of their PersonalInformation;

●      thereexists an imminent threat to the life, health, or safety of the person to whomthe Personal Information pertains;

●      upon reasonable suspicion the School must investigate illegalactivities;

●      upon reasonable suspicion the School must investigate a violation of Acceptable Use Policies; or

●      the School must satisfylegal requirements.

When information is disclosed to a third party,appropriate steps are taken to ensure that only the minimal set of information required for the said purposeis transferred, that it is transferred in a secure fashion, and that the information handling practices of thethird party are at least as stringent as those of the School with respect tothe disclosed Personal Information.

The School does not sell, lease, or trade information to other partiesbut may share it with organizations such as the Federation CJA for the purposes specifiedabove.

Accuracy

The School uses reasonable efforts to ensure that thePersonal Information it Processes is kept as accurate, complete, and up to date as required to meet the purposes forwhich it is processed. To help us maintain andensure that Personal Information is accurate and up to date, we inviteParents and Students to inform us, without delay, of any changein their PersonalInformation.

Retention

The School will not retain Personal Information longerthan is necessary to fulfill the purpose(s) for which it was collected including for the purposes ofsatisfying any legal, accounting, or reporting requirements and, where required to assert or defend against legalclaims, until the end of the relevant retention period or until the claims in question have been settled. As thispurpose varies depending upon the Personal Information involved, please contactMs.Merav Cohen at the above coordinates for any specificinquiries.

 Upon expiry of the retentionperiod, the Schoolwill securely destroyPersonal Information in compliance with applicable laws and regulations and in accordance with our documentretention policy.

Security

The School protects theconfidentiality, integrity, and accessibility of Personal Information withtechnological, administrative, andphysical safeguards appropriate to the sensitivity of the information. Accessto Personal Information is provided to Staff on a need-to-know basis only.

The School trains Staff on the importance of protectingPersonal Information. It has also implemented a breach response and notification procedure to address efficiently andeffectively any security failure affecting Personal Information.

Some information systems will be outsourced to third parties thathost data off site and/or outside Canada (e.g.Google Apps for email communication), in which case the Schoolwill verify that the privacyand security practices of the outsourcing company match or exceed those of the School.

Rights and How to Exercise Them

Parents and Students have certain rights with respectto the School’s Processing of their PersonalInformation:

(a) Access:They have the right to request whether the School holds Personal Information onthem and to request a copy of such information.

(b) Accuracy:They have the right to have their Personal Information kept accurate, current,and complete for the purposes forwhich it is Processed. Please contact Ms. Patricia Revah at the contact detailsprovided above if any PersonalInformation is not accurate or changes, so that the School can update thePersonal Information.

(c) Mobility: They have the right to request that computerized Personal Informationcollected from them be communicated to them in a commonly used technological format as wellas to any person or body authorizedby law to collect such information. This right does not extend to informationthat was created or inferred fromPersonal Information and the School is under no obligation to communicate suchinformation if doing so raisesserious practical difficulties.

(d) Complaints:If they believe that their Personal Information protection rights have beenviolated, they have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedythrough the courts.

The School will generally respondto all Personal Information requestswithin 30 days of the receipt of all necessary information. In circumstanceswhere it is not able to provide access, or if additional time is required to fulfilla request, it will advisein writing.

The School may not release certain types of informationbased upon exemptions specified in applicable laws. Where possible, it willsever the information that will not be disclosed and provide access to theremaining information. Should theSchool be unable to provide access to or disclose Personal Information, it willprovide an explanation, subjectto restrictions.

In certain circumstances, such aswhere the request is excessive or unfounded, the School may charge an administration fee for access to PersonalInformation. It may also charge for additional copies. It will advise of any fees before proceeding with a request.

Resolving Concerns

Any report, concern, complaint or incident of which theSchool becomes aware that involves conduct that may contravene this Policy will be treated confidentially to theextent possible. However, some disclosure may be necessary to adequately address issues raised,aid enquiry and implement solutions, as appropriate.

Concerns about the Processing of Personal Informationmay be reported directly to Ms. Patricia Revah at the contact details provided above. Ms. Merav Cohen will engage theappropriate levels of management to assist with resolution of the issue.

While the Schoolis committed to resolving all Personal Information matters internally, nothingin the Policy precludes a Parent or Student from contacting the Commission d’accèsà l’information du Québec (“CAI”).

The School will not retaliateagainst a person who, in good faith and on the basis of reasonable belief, raises questionsor concerns regardingtheir Personal Information.

Roles and Responsibilities

The School is responsible for communicating this Policy and ensuring that Staff membersfully comply with all relevantaspects of the Policy and any accompanying guidelines.

The School’s Staff members that Process PersonalInformation are responsible for ensuring that they do so in compliance with the Policy.

The School’sPrivacy Officer, Ms. Merav Cohenis responsible for:

(a) developing the School’s PersonalInformation protection strategy;

(b) developing and maintaining this Policy, accompanying guidelines and any other policyor procedure relatedto Personal Information in compliance with applicable law; and

(c) serving as the official liaisonwith the CAI.

Modification

Revised January 1, 2024 and supersedes all prior versions. The next revision is scheduled for January 1, 2025.

 The School reserves the right to interpret the Policy at its sole discretion and to make changes, as it deems appropriate from time to time without the requirement of advanced notice.