ONLINE ENROLMENT PRIVACY STATEMENT - ELIGIBILITY VERIFICATION

Content

1.     Preliminary remarks

2.     What are the categories of personal data collected in the enrolment application?

3.     What are the purposes for which personal data are collected?

4.     What is the legal basis for the processing of personal data?

5.     Who has access to the personal data and whom do we share them with?

6.     How do we protect and safeguard your information?

7.     How long do we keep personal data?

8.     What are your rights?

9.     Who should you contact in the event of a complaint?

10.   Changes to this Privacy Statement

The European Schools are committed to respecting your privacy and to complying with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the ‘GDPR’).

‘Personal data’ means any information related to an identified or identifiable natural person. In the School, ‘data subjects’ are in particular the pupils and the legal representatives/parents.

As defined by Article 4(7) of the GDPR, the data ‘controller’ is the natural or legal person, public authority, agency or other body which alone, or jointly with others, determines the purposes and means of processing personal data. As regards the enrolment of pupils in the European Schools, the Central Enrolment Authority (hereinafter referred to as the ‘CEA’) and the first preference European school/site (hereinafter referred to as the ‘School’) act as joint controllers.

As each European School has its own legal personality^[1], the Director^[2] of each School is considered to be the data ‘controller’. As regards the CEA, the Secretary-General^[3] acting as President of the CEA is considered to be the ‘controller’.

This Privacy Statement for enrolment in the Brussels European Schools informs you about how the personal data collected from legal representatives/parents and pupils are processed. For instance, it sets out what kind of personal data are collected, why they are processed and what your rights are in relation to such data collection.

1. Preliminary remarks

At its meeting of 25 and 26 April 2006 the Board of Governors decided to create a CEA charged with deciding on enrolments in the Brussels European Schools.  

Applications for enrolment or transfer to one of the Brussels European Schools and supporting documents are submitted to the first preference School. Both the CEA and the School will process the pupils’ and legal representatives’ personal data during the enrolment procedure.

Following the approval by the Board of Governors on 18 March 2022, the European Schools started the process of temporary admission of Ukrainian pupils for the 2021-2022 school year.

The Board of Governors then approved the “Regulation relating to the enrolment of Ukrainian pupils at the Brussels European Schools for the 2022–2023 school year”. Hence, admissions of displaced Ukrainians pupils can only be requested by local agents of European Union representations in Ukraine, staff members of the European Schools and officials/staff of European institutions who are welcoming displaced Ukrainian children (hereinafter referred to as “host family’s member(s)”).

The term "displaced Ukrainian child" must be understood as per Article 2 of the Council Implementing Decision (EU) 2022/382 of 4 March 2022.

2. What are the categories of personal data collected during the eligibility verification process?

The personal data collected during the eligibility verification process are as follows:

• - Host family member(s)/Legal representative’s/parent’s first name and surname,
• - Child's first name and surname,
• - Siblings’ first name and surname, and if applicable the school attended and the level.
• - Host family member(s)/Legal representative’s/parent’s phone number and email address,
• - Whether the host family member(s)/legal representative/parent work at the European Schools,
• - Host family member(s)/Legal representative’s/parent’s employment information (Compulsory document to be completed by the Director of the HR department)

3. What are the purposes for which personal data are collected?

The European Schools are a sui generis intergovernmental organisation. Their purpose is to provide children with quality teaching and learning, in the public interest.

To award a place in one of the Brussels European Schools and to organise teaching and learning, the School needs to process their personal data and those of the legal representatives/parents.

Before doing so, the School has to verify the eligibility of the application.

4. What is the legal basis for the processing of personal data?

As indicated above, the purpose of the European Schools is to provide children with quality teaching and learning, in the public interest.

Hence, processing of the personal data collected (as stated in section 2) is necessary for the performance of a task carried out in the public interest^[4], pursuant to the ‘Convention defining the Statute of the European Schools’, the ‘General Rules of the European Schools’ and the ‘Policy on Enrolment in the Brussels European Schools’^[5].
 
5. Who has access to the personal data and whom do we share them with?

Personal data collected during the enrolment procedure will be processed by the first preference School and by the CEA.

6. How do we protect and safeguard your information?

In order to protect your personal data, a number of technical and organisational measures have been put in place. These include appropriate measures to address online security, physical security, risk of data loss, alteration or unauthorised access, taking into consideration the risk represented by the processing and the nature of the data being protected.

In addition, we restrict access to the databases containing personal data to authorised persons with a legitimate need to access such information, for the purposes described above.

7. How long do we keep personal data?

If the pupil is not eligible, the information provided will be kept for three years.

8. What are your rights?

With respect to the processing of your personal data, you have the right to be informed and to access your personal data. You also have the right to rectification and erasure and to object to processing.

Should you object to certain processing activities or request that we delete your information, the School/CEA may be unable to continue the procedure of enrolment of the pupil.

Where the School and/or the CEA processes personal data on the basis of consent, such consent may be withdrawn at any time.
To facilitate the exercise of your rights, you may submit your request to the Data Protection Officer Correspondent of the first preference School: XXX-DPO-CORRESPONDENT@eursc.eu^[6]

The School will respond to these requests without undue delay and within one month at the latest. Should the School decline to comply with a request, you will be informed of the reasons for such a decision.

9. Who should you contact in the event of a complaint?

If you consider that the School has not complied with the data protection laws applicable (including the GDPR) or that your rights have been infringed as the result of the processing of your personal data, you have the right of recourse and can contact the National Supervisory Data Protection Authority.

10. Changes to this Privacy Statement

We reserve the right to update this Privacy Statement at any time and will provide you with a new Privacy Statement when we make substantial changes.
 

^[1]  Article 6 of the ‘Convention defining the Statute of the European Schools’
^[2]  Contact details: XXX-DIRECTOR@eursc.eu (XXX corresponding to the first preference School’s initials: IXL, LAE, UCC, WOL)
^[3]  Contact details: OSG-SECRETARY-GENERAL@eursc.eu
^[4]  Article 6, paragraph 1(e) of the GDPR
^[5]  Available for consultation on https://www.eursc.eu/en
^[6] ‘XXX’ corresponds to the initials of the first preference School (IXL, LAE, UCC, WOL)