Privacy Policy

Safeguarding Personal Information of Parents and Students isa fundamental concern of Talmud Torah/HerzliahSchool (“School”)as it pursues its mission of providing excellent educational service. The law,namely, the Act respecting Access to Documents Held by Public Bodies and the Protection of Personal Information (the “Act”), requires that all Staff and board members of the School adopt certain behavior to protect the Personal Information the School collects,uses, and discloses (“Processes”).

This Privacy Policy (“Policy”) describes how and why the School Processes Students’ and Parents’ Personal Information and what the School does to protect it.

We have appointed Ms. Merav Cohen as Privacy Officer to ensure compliance with the Act. Ms. Merav Cohen can be reached at the following coordinates and we invite any privacy related questions, comments, or complaints to be directed to: mcohen@azrieli-tth.ca.

Scope

All School Staff members, contractors and volunteers are required to Process Personal Information according to this Policy.

Definitions

“Personal Information” means any information about an individual that can directly or indirectly identify them. This includes but is not limited to all paper and electronic records, photographs and video recordings.

 “Parent” means the parent, legal guardian or other legal representative of a student.“Student” means a prospective, current,or past studentof the School.

“Staff” means someone who carries out a duty on behalf of the School, paid or unpaid, or who is contracted to, or directly employed by the School.

Types of Personal Information the School Collects

The School limits the type of information it collects to what is required to accomplish the purposes listed below. This information includes but is not limited to:

 Nominative information: first and last names of Parents and Students as well as their addresses, School-provided emails, dates of birth,and permanent codes;

 Academic records: evaluation results, capability assessments, and references;

Health information: allergies, dietary restrictions, and any medication to be provided;

Government issued identification: passportand medicare numbers;

Biometric information: photographs, voice recordings, and videotape.

Purpose of Collection

The School limits the collection of Personal Information to what is strictly necessary to provide excellent education services and fulfill its duty of care toward Students. This includes but is not limited to:

●      communicating with students and parents about matters related to the Students’ schooling;

●      tending to Students’ educational, social, and health needs;

●      celebrating Students’ efforts and achievements;

●      identifying Parents and Students;

●      compiling student lists;

●      planning, sourcing,monitoring and evaluating the School’s services and functions including Parent participation;

●      daily administering of School activities;

●      ensuring payment of School fees;

●      facilitating Student,Parental, or alumni communication;

●      soliciting feedback from Parents;

●      complying with governmental reporting requirements;

●      complying with statutory and or other legal obligations;

●      investigating incidents or defending any legal claims against the School, its services or its staff;

●      complying with laws that impose specific obligations regarding the Processing of Personal Information;

●      facilitating fundraising; and

●      promoting the School (e.g. calendars, School Web site or other promotional material).

The School undertakes to identify the reasons for collection either before or at the time the Personal Information is collected. If the School wishes to use the Personal Information it collects for a purpose other than what it has identified, it will obtain appropriate consent unless not required to do so by law.

Please note that in the case of photographs and video recordings used for promotional purposes, the School will ask parents to provide explicit consent at the beginning of every schoolyear.

How the School Collects Personal Information

The School mostly collects Personal Information through its online COBA portal. Occasionally parents may also be asked to complete medical forms that request Personal Information.

By providing information through one of the means listed above,Students and Parents consent to the School’s Processing of this information for the purposes outlined in this Policy. Parents and Students are at liberty not to provide certain Personal Information and are free to with draw their consent to the elements that they have consented to provide at any time. Failure to provide the School with such Personal Information and/or a withdrawal of consent to the Processing of certain Personal Information may prevent the School from fully providing its education services or effectively meeting its duty of care.

Disclosure of Personal Information

The School limits the Personal Information it discloses to what is necessary to fulfill the purposes for which it was collected unless:

●      the person consents to the disclosure of their Personal Information;

●      there exists an imminent threat to the life, health, or safety of the person to whom the Personal Information pertains;

●      upon reasonable suspicion the School must investigate illegal activities;

●      upon reasonable suspicion the School must investigate a violation of Acceptable Use Policies; or

●      the School must satisfy legal requirements.

When information is disclosed to a third party,appropriate steps are taken to ensure that only the minimal set of information required for the said purposeis transferred, that it is transferred in a secure fashion, and that the information handling practices of the third party are at least as stringent as those of the School with respect to the disclosed Personal Information.

The School does not sell, lease, or trade information to other parties but may share it with organizations such as the Federation CJA for the purposes specified above.

Accuracy

The School uses reasonable efforts to ensure that the Personal Information it Processes is kept as accurate, complete, and up to date as required to meet the purposes for which it is processed. To help us maintain and ensure that Personal Information is accurate and up to date, we invite Parents and Students to inform us, without delay, of any changein their Personal Information.

Retention

The School will not retain Personal Information longer than is necessary to fulfill the purpose(s) for which it was collected including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. As this purpose varies depending upon the Personal Information involved, please contact Ms.Merav Cohen at the above coordinates for any specific inquiries.

 Upon expiry of the retention period, the School will securely destroy Personal Information in compliance with applicable laws and regulations and in accordance with our document retention policy.

Security

The School protects the confidentiality, integrity, and accessibility of Personal Information with technological, administrative, and physical safeguards appropriate to the sensitivity of the information. Access to Personal Information is provided to Staff on a need-to-know basis only.

The School trains Staff on the importance of protecting Personal Information. It has also implemented a breach response and notification procedure to address efficiently and effectively any security failure affecting Personal Information.

Some information systems will be outsourced to third parties that host data off site and/or outside Canada (e.g.Google Apps for email communication), in which case the School will verify that the privacy and security practices of the outsourcing company match or exceed those of the School.

Rights and How to Exercise Them

Parents and Students have certain rights with respect to the School’s Processing of their Personal Information:

(a) Access:They have the right to request whether the School holds Personal Information on them and to request a copy of such information.

(b) Accuracy:They have the right to have their Personal Information kept accurate, current,and complete for the purposes for which it is Processed. Please contact Ms. Patricia Revah at the contact details provided above if any Personal Information is not accurate or changes, so that the School can update the Personal Information.

(c) Mobility: They have the right to request that computerized Personal Information collected from them be communicated to them in a commonly used technological format as wellas to any person or body authorizedby law to collect such information. This right does not extend to information that was created or inferred from Personal Information and the School is under no obligation to communicate such information if doing so raises serious practical difficulties.

(d) Complaints: If they believe that their Personal Information protection rights have been violated, they have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts.

The School will generally respond to all Personal Information requests within 30 days of the receipt of all necessary information. In circumstances where it is not able to provide access, or if additional time is required to fulfilla request, it will advisein writing.

The School may not release certain types of information based upon exemptions specified in applicable laws. Where possible, it will sever the information that will not be disclosed and provide access to the remaining information. Should the School be unable to provide access to or disclose Personal Information, it will provide an explanation, subject to restrictions.

In certain circumstances, such as where the request is excessive or unfounded, the School may charge an administration fee for access to Personal Information. It may also charge for additional copies. It will advise of any fees before proceeding with a request.

Resolving Concerns

Any report, concern, complaint or incident of which the School becomes aware that involves conduct that may contravene this Policy will be treated confidentially to the extent possible. However, some disclosure may be necessary to adequately address issues raised,aid enquiry and implement solutions, as appropriate.

Concerns about the Processing of Personal Information may be reported directly to Ms. Patricia Revah at the contact details provided above. Ms. Merav Cohen will engage the appropriate levels of management to assist with resolution of the issue.

While the School is committed to resolving all Personal Information matters internally, nothing in the Policy precludes a Parent or Student from contacting the Commission d’accèsà l’information du Québec (“CAI”).

The School will not retaliate against a person who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their Personal Information.

Roles and Responsibilities

The School is responsible for communicating this Policy and ensuring that Staff members fully comply with all relevant aspects of the Policy and any accompanying guidelines.

The School’s Staff members that Process Personal Information are responsible for ensuring that they do so in compliance with the Policy.

The School’s Privacy Officer, Ms. Merav Cohen is responsible for:

(a) developing the School’s Personal Information protection strategy;

(b) developing and maintaining this Policy, accompanying guidelines and any other policy or procedure related to Personal Information in compliance with applicable law; and

(c) serving as the official liaison with the CAI.

Modification

Revised January 1, 2025 and supersedes all prior versions. The next revision is scheduled for January 1, 2026.

 The School reserves the right to interpret the Policy at its sole discretion and to make changes, as it deems appropriate from time to time without the requirement of advanced notice.