Cool4School Privacy and Data Protection Policy
Cool4School is fully compliant with the GDPR law for the UK/EU from 01 September 2020
We keep securely the name and email address of the person or persons allocated by the school as the administrator(s) of the software for the school.
We supply a password and username. All passwords are encrypted and as soon as the administrator changes it, only the administrator knows what it is.
It is the responsibility of the administrator to ensure no student or any other unauthorised person has access to these logon credentials.
The administrator can also in certain circumstances ask Cool4School to undertake some of these tasks, in which case the operation will be carried out by a member of Cool4School staff trained in data protection.
Each school or establishment can allocate a generic student username and password supplied by Cool4School. The school administrator can change the password.
The administrator may in an emergency ask Cool4School to suspend the software. This will have the effect of stopping any user making use of the software.
Microsoft Azure Cloud : EU located data centre.
Data Processing in the European Economic Area (EEA)
A Cool4School “Data Region” is a set of data centres located within a defined geographical area where User data is stored. Personal data is not transmitted between Data Regions. For Users with accounts located in Cool4School’s European Data Region, all processing of personal data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the “Directive”), and the implementation of the Directive in local legislation. From May 25, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (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, known as the General Data Protection Regulation (“GDPR”), and Cool4School’s processing will take place in accordance with GDPR.
Cool4School processes personal data as both a Processor and Controller, as defined in the Directive and the GDPR. Consequently, Cool4School processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (“EEA”) only.
What are your choices regarding collection, use, and distribution of your information?
The disclosure of very limited personal information is required to create an account on our site, which is required to access certain services. If you do not wish to disclose the requisite information you are free to discontinue use of the Cool4School website and service.
You also have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies Cool4School may not be displayed or function in the way intended by Cool4School.
Right of confirmation – Users and Visitors will have the right granted by the European legislator to obtain from Cool4School the confirmation as to whether or not personal data concerning him or her his being processed. If a data subject wishes to avail him or herself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer.
Right of access – Users and Visitors will have the right granted by the European legislator to obtain from Cool4School free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information: (1) the purpose of the processing; (2) the categories of personal data concerned; (3) the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations; (4) where possible, the anticipated period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from Cool4School rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing; (6) the existence of the right to lodge a complaint with a supervisory authority; (7) where the personal data is not collected from the data subject, any available information as to its source; (8) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and anticipated consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data is transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail him or herself of this right of access, he or she may at an time contact our Data Protection Officer.
Right of rectification – Each User or Visitor shall have the right to obtain from Cool4School without undue delay, the rectification of inaccurate personal data concerning him or her; and to complete incomplete data.
Right of restriction of processing – Each User or Visitor shall have the right to obtain from Cool4School restriction of processing where: (1) the accuracy of the personal data is contested; (2) processing is unlawful and the data subject requests restriction rather than erasure; (3) Cool4School no longer needs the personal data for the purpose of the processing; or (4) the data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of Cool4School override those of the data subject.
Right to withdraw consent – Each Visitor and User shall have the right to withdraw his or her consent to processing of his or her personal data at any time by contacting our Data Protection Officer.
Cool4School will keep securely names, addresses and email addresses of teachers who ask for trial versions or otherwise ask for more information. This information will be used in the following ways:
•To tell trial users their logon credentials and to remind them.
•To send further details including prices
•To warn users of the ending of trials
Administrators will also be contacted from time to time with newsletters and information about the expiry of their subscription.
All contacts will have the right to have their details deleted from the database.
Privacy impact assessment
Cool4School has a number of strategies in place to secure data, with strict limits on the number of people who have access. Class teachers only have access to data for the student account to which they have been assigned. All data is protected by secret usernames and passwords. Passwords are hidden and encrypted.
In the extremely unlikely event of data being stolen, the impact will be limited to teacher names and usernames. No student names, email addresses, phone numbers, gender information, age, date of birth or address are stored.
The only other data stored consists of the teacher’s names, school email addresses and school address.