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If there is a need of using your data for other purposes that are not specified in this policy, we will ask for your consent before proceeding, unless it is to fulfill a legal obligation imposed on the school, or as a result of our contractual relationship with colleagues, or to serve our legitimate interests (for example, internal investigations, preventing fraud and other illegalities in our system, and investigate illicit activities), situations in which we can use them, observing limitations imposed by current legislation and best practices.
We guarantee that the protection of your personal data is one of our priorities and in case of any accidental, illegal or unplanned access happens, we will take all plausible measures to mitigate and or reduce possible damage. In accordance with article 48 of LGPD and applicable regulations, Avenues will report such occurrences to the appropriate authorities.
Collected Information
Below we describe the main data obtained by Avenues:
1) Data provided in the Avenues admissions process:
Data provided by parents or guardians relating to themselves and students, such as name, phone number, date of birth, email and address are necessary for scheduling a visit to Avenues and for receiving marketing materials about our services.
Data provided by parents or guardians relating to themselves, students and their siblings, such as name, phone number, email, gender, ethnicity, address, citizenship, date of birth, grade, academic information, school records, letters of recommendation, family issues and information about the student’s conditions, information about the necessity of scholarships and other information provided voluntarily are necessary for Avenues’ admissions process and participation in school inclusion programs. For this purpose, parent and guardian information such as RG, passport, marriage certificate, credit card information, employer and educational level are also necessary.
Data provided by candidates to Avenues’ positions about themselves (and, when applicable, about family members), such as name, address, email, phone number, credentials and licenses, curriculum information, academic history, professional experience, photo, gender, ethnicity, class demonstration video, extracurricular activities, documents, health conditions, biographical information, salary, social media profiles, assessments written by reference contacts, criminal history and other information provided voluntarily are necessary for the hiring process of Avenues teachers and employees and for participation in the school’s diversity programs.
2) Data provided by parents or guardians and students regarding scholarship request:
Data provided by parents or guardians about themselves and students, such as name, annual income, properties and assets, information about positions held, salary and benefits, costs and expenses, supporting documents (such as income tax return and bank statements) are necessary for evaluating scholarship applications.
3) Data provided by enrolled students:
In addition to data provided in the admissions process, data provided by parents or guardians about themselves and students, such as ID, CPF, birth certificate, photo, transfer declaration and school records are necessary to complete the student’s enrollment at Avenues, to deliver the contracted services, including but not limited to registration in internal and educational systems and applications used by the school and for activities carried out at and outside the school (eg trips and excursions).
Data on student health, such as medical records, medical statements, medications in use and treatments, allergies and medical and psychological conditions, health plan data, physical limitations, learning disabilities, vaccines and emergency contacts are necessary to ensure the safety, health and physical integrity of students and campus community, as well as the provision of services related to students’ academic and social development.
Student data, such as participation in governmental programs or native communities, school grades and reduced mobility are necessary for the fulfillment of legal obligations.
4) Data provided by hired faculty and staff:
Data provided by hired faculty and staff about themselves (and their dependents, when applicable), such as documentation (proof of residence, ID, CPF, driver's license, marriage certificate, army discharge certificate, diplomas), photo, banking information, disabilities and health information are necessary to hiring teachers/employees, completing a background check, conceding benefits and for registration in internal and educational systems and applications used by the school, and fulfillment of legal obligations.
5) Data collected by cookies on our website:
Our site uses cookies for site functionality and making your experience in our site better. For that purpose, the cookie we set keeps track solely of the pages you have visited on our site, your language preference and Country of origin.
In addition, we use third-parties’ systems in our site that may collect cookies according to the privacy policies of such parties. For more information, please consult their privacy policies:
Google
We use Google Analytics. By using Avenues’ web site and linked Avenues web sites, you agree to the terms of service and privacy policy of Google.
(https://policies.google.com/privacy)
HubSpot
We use HubSpot. By filling out an interest form, you agree to the terms of service and privacy policy of HubSpot
(https://knowledge.hubspot.com/reports/what-cookies-does-hubspot-set-in-a-visitor-s-browser)
How long we store your data for
The indicated personal data will be stored in our databases for as long as they are necessary to fulfill the described purposes, in accordance with the applicable legal bases. Anonymized personal data, with no possibility of association with the individual, might be stored for an undefined period of time.
Policy
Information Security Objectives
Information security is critical to the interests of the school and the many constituencies it serves. The following list provides some of the objectives of information security at Avenues: The World School. This list is representative and is not meant to suggest the full range of objectives of the school’s information security policy or program.
Safeguard personal data and the privacy of individuals and information
With the increasing risk of identity fraud and other potential misuses of personal information as well as compliance to regulations (e.g., LGPD), it is paramount that the school understand and safeguard personal information entrusted to its stewardship.
Support and maintain the ongoing functions of the school
As an increasing percentage of the school’s functions are handled electronically, it is critical that information and information systems be protected so the school can operate without interruption.
Comply with state and federal laws.
State and federal laws and regulations require the school to take reasonable steps to ensure the security of the data. Failure to safeguard this information could result in the legal action or cause the school to lose its ability to offer services.
Data Management
Data Access
Students, faculty, staff and contributors who use personally-owned systems to access school resources are responsible for the security of their personally-owned computers and other network devices and are subject to the following: the provisions of the school’s security policies, standards and guidelines for best practices for users of school computing and network facilities as well as all other laws, regulations, or policies directed at the individual users.
Unauthorized Account or System Access
You may not access or use, or attempt to access or use, any computer accounts other than your own assigned account or any computer system for which you have not been granted access. In other words, all colleagues should use only their own files, email accounts and accesses, those that have been designated as public, or those that have been made available to them with the knowledge and consent of the owner.
The school’s academic integrity code and its prohibitions against plagiarism and cheating, among other things, applies to student use of any files and information, including those obtained on computing resources used in the preparation of academic coursework.
Colleagues may not access computers, software, data or information, or networks without proper authorization, regardless of whether any damage is done or whether the computer, software, data, information, or network in question is owned by the school.
Campus colleagues all share in the commitment to safeguarding the school’s data. The school will rely on the principle of ‘least privilege’ in granting access to data and information.
Reporting Information Security Incidents
Reporting incidents is an ethical responsibility of all members of the Avenues: The World School community. All the information related to information security incidents should be reported promptly by contacting the Help Desk.
Loss of Computing Privileges/Disciplinary Implications
Protecting the security of school information and information systems is the responsibility of every member of the school community. Each student, faculty, staff and contributors is responsible for understanding and complying with all current and future approved IS & Technology policies and procedures including this Information Security Policy. Failure to comply with these policies may result in loss of computing privileges and/or disciplinary action, up to and including termination. An example of noncompliance include, but are not limited to inappropriately accessing and/or using school data. As described earlier, no person may store or use programs on school-owned systems that violate or hamper another person's use of computing resources. Examples of such programs are ones that attempt to obtain another user's password, acquire another user's files, circumvent system security measures, or crash the computer system.
Inappropriately accessing and/or using school data
No person may store or use programs on school-owned systems that violate or hamper another person's use of computing resources. Examples of such programs are ones that attempt to obtain another user's password, acquire another user's files, circumvent system security measures, or crash the computer system.
Data transfer to third parties and abroad
Personal data may be shared with contractors (such as accountants and legal advisors), educational applications, governmental authorities and unions, other organizations within the Avenues group, and business partners. We may hire other companies and individuals to perform functions on our behalf or perform activities related to the contract with its holder. Examples include, but are not limited to, information management systems and servers, travel and excursion companies, health plans and companies hired to grant benefits to teachers and employees, photographers and security and food companies hired by Avenues. We will always be guided by current legislation determinations to complete such transfers and will instruct these business partners on how to treat such data and comply with the law.
We are part of a global community. It is possible that personal data is transferred to countries other than Brazil (eg. countries in which other Avenues campuses are located, such as New York, United States, and Shenzhen, China), or countries that host our technology information systems. In these cases, Avenues will take all measures to comply with current legislation and make use of reasonable and available technical measures to ensure that these transfers are conducted in accordance with applicable legislation, and that at least the same levels of protection will be adopted in these other countries.
In the event that Avenues is the object of a consolidation, acquisition, merger by a third party or any corporate or asset restructuring, we reserve the right to transfer the collected data to the third party involved in the operation, who must comply with the privacy rules set forth herein.
Procedures
Education
Creating a heightened awareness of the importance of information technology security is an important component in establishing an environment in which each individual feels responsible and empowered to act in his/her own and the community’s best interests.
Avenues recommended procedures to protect our organization:
Your Rights
Below we describe the rights held by our students and their families, and faculty and staff when it comes to their personal data:
Avenues has the right to not approve requests for data deletion in certain situations, such as, for example, fulfillment of legal or regulatory obligation by the data controller; existence of a valid contract with the holder; and if the law or regulations determine minimum deadlines for data retention.
