Diamonds International School > Privacy Policy

 Privacy Policy for Diamonds International School (DIS), Ikoyi, Lagos

1. Introduction and General Information

Diamonds International School (DIS), located at 87, Lafiaji Way, Dolphin Estate, Ikoyi, Lagos, Nigeria, is committed to protecting the privacy and personal data of its students, parents/guardians, staff, and other stakeholders.

This Policy outlines how DIS collects, uses, protects, and discloses personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable laws and regulations.

2. Definitions

    • Data Subject (You): Any identifiable natural person whose personal data is collected and processed by DIS. This includes students, parents/guardians, employees, and applicants.
    • Personal Data: Any information relating directly or indirectly to an identified or identifiable natural person.
    • Sensitive Personal Data: Includes data relating to health, religious beliefs, biometric data, and other data specified by the NDPA.
    • Processing: Any operation performed on personal data, such as collection, recording, storage, use, disclosure, or deletion.
    • School (We, Us, Our): Diamonds International School.
    • NDPA: The Nigeria Data Protection Act 2023.

3. Personal Data We Collect

The School collects and processes various categories of Personal Data for its educational, administrative, and safeguarding purposes.

3.1. Data Collected from Students and Parents/Guardians:

    • Identification and Contact Details: Name, date of birth, gender, address, email, phone numbers, nationality, passport details, photographs, and school-issued ID.
    • Educational Records: Academic records, results, attendance, disciplinary records, educational progress, and special educational needs (SEN) information.
    • Health and Welfare Information (Sensitive Personal Data): Medical conditions, allergies, doctor’s details, immunisation records, and health-related reports.
    • Financial Information: Payment records, bank details (for fees and refunds).
    • Digital Data: School portal login details, website usage data (via cookies, if applicable), and CCTV footage for safety and security.

3.2. Data Collected from Staff and Job Applicants:

    • Identification and Contact Details: Name, address, phone number, email, next-of-kin details, photograph.
    • Employment Details: Qualifications, professional history, references, salary, bank account details, employment contracts, and performance reviews.
    • Sensitive Personal Data: Health information, and criminal records checks (where legally required).

4. Purpose and Legal Basis for Processing

We process Personal Data based on the following legal bases as permitted by the NDPA:

Purpose of Processing Legal Basis under NDPA
Education and Welfare (e.g., teaching, assessment, pastoral care, communicating with parents). Necessary for the performance of a contract (enrollment/employment) and Legitimate Interests (providing a safe and effective learning environment).
Admissions and Enrollment (e.g., processing application forms). Necessary for the performance of a contract (taking steps prior to entering a contract).
Legal Compliance and Safeguarding (e.g., child protection, tax/regulatory reporting). Necessary for compliance with a legal obligation.
Marketing and Communications (e.g., newsletters, school events, school promotion). Consent (where required, such as for the use of student photographs for marketing outside the school community).
Managing Employment (e.g., payroll, performance management). Necessary for the performance of a contract (employment contract).

Note on Children’s Data: As students are typically children (under 18) under the Child Rights Act 2003 and the NDPA, the School will obtain consent for processing their data from the parent or legal guardian.

5. Disclosure of Personal Data

The School treats all Personal Data confidentially but may disclose it to third parties only when necessary and with appropriate safeguards:

    • To School Service Providers: Third parties who provide services on our behalf, such as educational platforms, medical services, school bus operators, and IT support.
    • To Government and Regulatory Bodies: To comply with legal obligations (e.g., NDPC, tax authorities, examination bodies, or law enforcement, if legally required).
    • To Other Educational Institutions: Transfer of student records to a new school upon request.
    • Professional Advisors: Auditors, lawyers, and other professional consultants.
    • In Emergencies: Disclosure to medical professionals in the event of a medical emergency.

We ensure that all third parties are obligated to comply with the NDPA and only use the data for the specific purposes for which it was shared.

6. Security and Retention of Personal Data

6.1. Data Security

The School implements appropriate technical and organisational security measures to prevent unauthorised access, disclosure, alteration, or destruction of Personal Data. These measures include:

    • Secure storage of digital records using passwords and encryption.
    • Physical security for paper records (locked cabinets).
    • Restricting access to Personal Data to staff who have a legitimate need to know.
    • Regular training for staff on data protection principles.

6.2. Data Retention

We will retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.

    • Student Academic Records may be kept for a period after the student leaves for reference, verification, or legal purposes.
    • Financial Records are retained as required by financial regulations in Nigeria.

7. Your Rights as a Data Subject

Under the NDPA, you have the following rights regarding your Personal Data:

    • Right to Information: The right to be informed about the collection and use of your Personal Data (this Policy serves as this notice).
    • Right of Access: The right to request copies of your Personal Data held by the School.
    • Right to Rectification: The right to request the correction of inaccurate or incomplete Personal Data.
    • Right to Erasure (Right to be Forgotten): The right to request the deletion of your Personal Data, subject to our legal obligations for retention.
    • Right to Restrict Processing: The right to limit the way we use your Personal Data.
    • Right to Object to Processing: The right to object to the processing of your Personal Data in certain circumstances, including for direct marketing.
    • Right to Data Portability: The right to receive your Personal Data in a structured, commonly used, and machine-readable format.
    • Right to Withdraw Consent: Where the legal basis for processing is consent, the right to withdraw that consent at any time.

8. Updates to this Policy

This Policy may be updated periodically to reflect changes in our data processing practices or legal requirements. The most current version will always be available on the School’s official website or upon request.

9. Contact Information and Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a complaint regarding the processing of your Personal Data, please contact the School’s designated data protection contact person:

    • Data Protection Contact: The Head of School/Designated Data Protection Officer (or equivalent position)
    • Address: 87, Lafiaji Way, Dolphin Estate, Ikoyi, Lagos, Nigeria
    • Email: [Insert School’s designated Data Protection/Admin Email Address]
    • Phone: [Insert School’s designated Phone Number, e.g., 0700DIAMODS]

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.