CSB.School recognizes and supports the privacy interests of all individuals, and respects those interests when CSB.School collects and processes Personal Information. In particular, CSB.School respects the confidentiality of its customers, suppliers and employees, and other persons with whom CSB.School maintains professional relations. In addition to the restrictions and obligations in this Policy, CSB.School complies with applicable national laws that protect the privacy of Personal Information, including the EU General Data Protection Regulation 2016/679, which is effective May 25, 2018, and all laws and regulations of the jurisdictions in which CSB.School operates.
This Policy applies to:
(1) Personal information that is collected, administered, used or otherwise processed by any Global Business Unit, Business Support Service/Activity or Affiliate of CSB.School. This Policy applies to all CSB.School sites. It constitutes the binding basis for the use of Personal Data and can only be replaced by more stringent national regulations;
(2) Personal information in any format, including computer files and electronic information, as well as paper records; and
(3) Personal information that CSB.School collects and uses for its own business purposes. In some cases, CSB.School processes Personal Information that belongs to other companies, in particular within the framework of Service Provision Contracts. In such cases, CSB.School will protect Personal Information in accordance with this Policy, comply with all laws that regulate information, and use information only as authorized by the data owner as set forth. specifically in a Service Agreement.
The terms of this Policy are also intended to apply to agents and contractors who handle and process Personal Information on behalf of CSB.School.
For the purposes of this Policy, the following definitions will apply:
“Personal Information” (or Individual Information) – also known as Personally Identifiable Information (NI) or Personal Data – means any information that can be used to directly or indirectly identify an individual. It includes any information that allows an individual to be identified from that piece of data alone, or from that data and other data that is or may be available, such as name, home address, email address, ID number, salary and benefits. There is no distinction between Personal Information about an individual that relates to their private, public or professional life, as they are all covered by this Policy.
“Processing” means any operation or series of operations that is performed on Personal Information, whether or not by automatic means, such as collection.
“Sensitive Personal Information” means Personal Information that reveals health or disease status, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the person’s sex life or sexual orientation.
Principles of confidentiality
(1) Data Collection or Use – Purposes
CSB.School collects and uses Personal Information to support and help improve its business. CSB.School processes Personal Information only for limited, explicit and legitimate purposes and always in accordance with applicable law. The types of information and the purposes for which we collect Personal Information may include:
CSB.School collects and uses Personal Information as necessary for human resources and employment processes from current and prospective employees as well as independent contractors.
For customers, suppliers, service providers and subcontractors
Even though our customers, suppliers, service providers and subcontractors are mainly companies, CSB.School collects Personal Information about people who are employed by them. These professional details and other personal information are used to administer existing and future business arrangements, provide and manage training actions, manage higher education establishments and anything that, directly or indirectly, facilitates the achievement of its object.
Additional Personal Information may be collected, used and disclosed for the purposes for which it was collected and for compliance with the law, including regulatory reporting, investigation of allegations of wrongdoing, and management and defense of legal claims and actions, and compliance with subpoenas, court orders and other legal obligations. For example, we may collect information about people who visit our establishments.
CSB.School collects this information only in a reasonable and lawful manner.
(2) Privacy Notice – Transparency
When required, CSB.School informs individuals about its processing of their information and also makes this information available upon request. In particular, its privacy notices contain:
- the type of information we collect;
the purposes for which we collect Personal Information;
the types of parties to whom we disclose Personal Information;
the privacy and information safeguards we employ; and
how to access, correct or erase Personal Information (if applicable).
CSB.School also provides transparency with regard to international information transfers. Where possible, privacy notices include information about how Personal Information may be used within the CSB.School Group and by third parties, the purposes of such transfers, the potential recipients, and the protections that
CSB.School has put in place to help ensure an adequate level of protection for the information transferred.
(3) Lawfulness and fairness of processing
CSB.School processes Personal Information lawfully and fairly in relation to the individual. This implies that all processing is based on legitimate grounds, such as the need for processing to (i) draw up and/or perform a contract with the person, (ii) comply with a legal obligation imposed on CSB.School , (iii) protect the vital interests of the person, (iv) perform a task carried out in the public interest, or for (v) legitimate interests pursued by CSB.School or by a third party except when the interests or rights and fundamental human freedoms that require protection of Personal Information outweigh those interests.
In addition, where an individual’s consent for the collection, use, or disclosure of Personal Information is required by law, contract, or agreement, CSB.School must obtain such consent before processing or the transfer of Personal Information.
(4) Sensitive Information
There are certain types of Personal Information that CSB.School considers to be particularly sensitive and for which CSB.School provides additional and appropriate privacy protection and confidentiality. CSB.School will collect and use such Sensitive Personal Information only where there is a legal basis, or where the individual’s consent has been obtained or where there are compelling business reasons where permitted by law.
(5) Accuracy of information
CSB.School uses reasonable means to keep Personal Information reasonably accurate, complete, and up-to-date, as necessary for the purposes for which it was collected.
(6) Disclosure of Information
In general, Personal Information may be shared within CSB.School where permitted by law for reasonable and appropriate corporate purposes. However, even within CSB.School, access to Personal Information is restricted to employees, agents, or subcontractors who need to access it to perform the functions entrusted to them.
Disclosure of Personal Information beyond employees, agents, or contractors of CSB.School may be made only as permitted or required by law or legal process, or pursuant to an agreement , business necessity, or with the consent of the person. Specifically :
CSB.School may disclose Personal Information about workers and employees to a range of third parties who provide services to its employees, such as payroll or benefits administration.
CSB.School may also disclose Personal Information about Learners undergoing training to a range of third parties who provide services to its Learners, such as passing and obtaining certifications, access to inherent digital resources to the training courses taken.
Personal Information may always be disclosed in connection with legal compliance initiatives, in response to a government request for information, or in the course of due diligence, negotiation and conclusion of a sale or transfer of all or part of our business.
(7) Location of Personal Information and International Transfers
Personal Information may be stored and processed at the head office of CSB.School, on the sites of an Affiliate of CSB.School or of our service providers and in the Cloud via our service providers and always in accordance with applicable laws.
(8) Protection of Personal Information
To help protect the confidentiality of Personal Information, CSB.School employs security protections appropriate to the sensitivity of the information. These safeguards include reasonable administrative, technical and physical measures to protect the confidentiality and security of Personal Information against anticipated threats and unauthorized access to Personal Information. CSB.School also administers an effective incident and breach management program relating to Data Protection and Privacy.
Where required by applicable law, CSB.School will report breaches of Personal Information to the appropriate authority and/or notify the affected individual.
(9) Access and Correction – Rights of persons
CSB.School will generally offer individuals, upon request, the opportunity to review their own Personal Information, confirm the accuracy and completeness of their Personal Information, and have their Personal Information updated. staff, if applicable. CSB.School provides individuals with a reasonable opportunity to object to the collection, use, and disclosure of their Personal Information.
CSB.School endeavors not to retain Personal Information for longer than permitted under applicable laws.