ISA-Tokyo is committed to protecting the privacy and security of personal information. This privacy policy describes how we collect and use personal information about Clients, in accordance with the Act on the Protection of Personal Information (APPI) of Japan.
Who Collects This Information?
ISA-Tokyo is an education service provider which provides educational services for Clients. We are a ‘personal information controller’ (PIC), which means that we are responsible for deciding how we hold and use personal information about Clients (including students and parents), forthwith referred to as ‘Principals’ (data subjects).
What Personal Information do we Collect, Process, Hold and Share?
We may collect, store and use the following categories of personal information:
• Student information such as name, date of birth, gender and contact information
• Family information such as names, relationship, phone numbers and email addresses
• Characteristics (such as language, nationality, country of birth and interests)
• Attendance details (such as sessions attended, number of absences and reasons for absence)
• Financial details (in regard to payments)
• Educational performance and assessment information
How do we collect the information?
We will ask you for certain information when you register for any of our services. Whilst most of the information you provide to us is mandatory, some of it is provided to us on a voluntary basis. We will inform you whether you are required to provide certain information to us or if you have a choice in this. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Information regarding students may be collected whilst they undertake any of our services. This will be for educational purposes only.
How Will We Use Your Personal Information?
We will use your personal information to:
• Provide educational services to students and parents, and monitor progress and educational needs
• Support teaching and learning
• Give and receive information and references about past, current and prospective pupils and to provide references
• Inform our marketing and advertising
• Enable pupils to take part in assessments and to record pupil achievements
• Run analytics
• Fulfil any legal and regulatory purposes and to comply with legal obligations and duties of care
• Ensure safe and secure online access
• Allow for any other purpose which is reasonably necessary, including to obtain appropriate professional advice and insurance.
How The Law States We Can Use Your Information
We will only use your information when the law allows us to. Most commonly, we will use your information in the following circumstances:
• Consent: clear consent has been given to process their personal data for a specific purpose
• Contract: the processing is necessary for a contract with the individual
• Legal obligation: the processing is necessary to comply with the law (not including contractual obligations)
• Public interest: the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law; it is necessary to protect the life, health, or property of an individual
• Legitimate Interests – the processing is necessary for the purposes of the Organization’s legitimate interests (or a third party); that is provided those interests are not overridden by the rights and freedoms of the Principal (data subject).
We need all the categories of information in the list above primarily to allow us to comply with legal obligations. Please note that we may process information without knowledge or consent, where this is required or permitted by law.
Sharing Data
We may need to share your data with third parties where it is necessary. There are strict controls on who can see your information. We will not share your data if you have advised us that you do not want it shared unless we are legally required to do so. We share student information with:
• ISA-Tokyo tutors
• Admission teams of international schools (if requested by Clients)
• Third parties whose services we may outsource as part of one of our assessment and learning services
• Law enforcement officials
• Professional advisors such as lawyers and consultants
• Support services, e.g. IT support, etc.
• Government Agencies
Information will be provided to those agencies securely or anonymised where possible. The recipient of the information will be bound by confidentiality obligations, we require them to respect the security of your data and to treat it in accordance with the law. We may need to transfer your personal information outside Japan. If we do, you can expect a similar degree of protection in respect of your personal information.
Storing Data
ISA-Tokyo keeps information on computer systems. Except as required by law, ISA-Tokyo only retains information for as long as necessary in accordance with timeframes imposed by law and our internal policy.
Security
We have put in place measures to protect the security of your information (i.e. against it being accidentally lost, used or accessed in an unauthorised way). Security measures include, but are not limited to, the use of firewalls and endpoint protection, browser certification technology, encryption, limited access principle, malware protection, and use of artificial intelligence based ransomware and exploit protection. Only employees who need the information to perform a specific job are granted access to your information. ISA-Tokyo uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason ISA-Tokyo cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet. If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.
Requesting Access To Your Personal Data
Under data protection legislation, Principals (data subjects, including parents and students) have the right to request access to information about them that we hold. However, access may be refused if there is the chance of injury to the life, property or rights/interests of ISA-Tokyo or any third party; a material interference with ISA-Tokyo’s business operations; or a violation of other Japanese laws prohibiting disclosure.
You also have the right to:
- Revise, correct, amend or delete your personal data
- Request your data is no longer used if it is used for a purpose not originally stated or if it was acquired by unlawful means
- Access any records of data transfers to third parties
- Require the cessation of use of your personal data if it is no longer needed, a data breach has occurred, or it is likely that your rights will be infringed
If you want to exercise any of the above rights, please contact ISA-Tokyo at admin@isa-tokyo.com in writing. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right To Withdraw Consent
In circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact ISA-Tokyo at admin@isa-tokyo.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Cookies
We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content. Most web browsers allow some control of most cookies through the browser settings.
Log files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
Links to external websites
ISA-Tokyo’s website may contain links to other external websites. Please be aware that ISA-Tokyo is not responsible for the privacy practices of other such sites. When you leave our site, we encourage you to read the privacy notices of each website that collects personally identifiable information. This privacy statement applies solely to information collected by ISA-Tokyo.
Changes To This Privacy Policy
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you about the processing of your personal information via other methods occasionally.
2023.07.06 updated