GENERAL DATA PRIVACY POLICY
International School of Choueifat - Ras Al Khaimah
Last Modified: July, 2025
Effective since: July, 2025
GENERAL INFORMATION
This General Data Privacy Notice provides detailed information on how International School of Choueifat – Ras Al Khaimah ("we", "us", "our", "School") handles the Personal Data of its Students, Prospective Students, Parents and/or Legal Guardians (Or "Representatives" as defined below) within the scope of its activities.
The detailed provisions throughout this General Data Privacy Notice (the “Privacy Notice”) will apply to the collection, processing, transfer, retention of Personal Data during the application and registration process, the attendance of courses and/or any educational services offered by the School in the United Arab Emirates (“UAE”) territory.
1. DEFINITIONS
In this Privacy Notice, the following terms are used with their respective meaning:
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"Personal Data"
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means any and all data relating to an identified individual or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, geographic location, or one or more special features that express the physical, psychological, economic, cultural or social identity of such person. It also includes Sensitive Personal Data and Biometric Data identifiable person, such as a Student, a Prospective Student, or a Parent and/or Legal Guardian;
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"Special Category of Data"
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means any and all information relating to the special categories of data set out in the Federal Decree Law No. (45) of 2021. Within the scope of the activities performed by the School, this category of data is related to health or medical care data of Students, Prospective Students as well as racial, religious beliefs, physical, psychological, mental, mental, physical, genetic or sexual state, ethnic, or sex life origin;
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"Data Subject"
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refers to the individual whose data is the subject of data processing i.e. Students, Prospective Students, and Students' Parents/ Legal Guardians;
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"Data Processing"
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refers to any operation carried out with Personal Data, under the terms and limits determined by the Federal Decree Law (FDL). This includes collection, storage, recording, organization, adaptation, alteration circulation, modification retrieval, exchange, sharing, use or classification or disclosure of Personal Data by transmission, dissemination, or distribution, or otherwise making it available or aligning, combining, restricting, blocking, erasing, or destroying Personal Data or creating models thereof;
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“FDL”
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refers to Federal Decree Law No. (45) of 2021 on the Protection of Personal Data and its awaited executive regulations – responsible for the regulation of data collection, processing and transfer within the United Arab Emirates;
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"Students"
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refers to individuals under 18 years old enrolled at the School;
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"Prospective Students"
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refers to Prospective Students who will potentially be enrolled at the School;
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"Guardian"
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Or “Legal Guardian” or “Parents” or “Representatives” refers to the individual legally responsible for the Student(s) or Prospective Student(s);
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"Data Protection Officer"
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any natural or legal person appointed by the School, who undertakes the tasks of verifying compliance of its entity with the controls, requirements, procedures, and rules for processing Personal Data, and ensuring the integrity of its systems and procedures in order to achieve compliance with the provisions of the FDL;
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"Online Platform"
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means any website and/or online platform operated by SABIS® or by companies’ members of the SABIS® Group of companies;
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"The School"
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THE INTERNATIONAL SCHOOL OF CHOUEIFAT L.L.C
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"Personal Data Breach"
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a breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed. The School will report Personal Data breaches to the supervisory authority, once established, where the breach is likely to adversely affect the Personal Data or privacy of the Data Subject.
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"Contract"
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Agreement signed between the School and the Guardians whereby the School provides educational services to the Students.
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2. INFORMATION ABOUT US
For the purposes described in this Privacy Notice, the School shall be taken as the legal person responsible for determining the purpose and means of the Personal Data that is submitted by Students, Prospective Students, and Guardians, and may be identified and contacted through the channels below:
3. PROCESSING PERSONAL DATA
As part of its educational activities, the School will collect and process the Personal Data identified below, with the following purposes and legal basis:
Identification Data: Types of data that enable the identification of the Data Subject who has any legal bond with the School – Students, Prospective Students, and Guardians – consisting, for example, of their full name, date of birth, nationality, place of birth, profession, home address, E-mail address, postal code, and telephone and/or cell phone number(s).
Purpose: The Personal Data is collected in order to enable the proper identification of Students, Prospective Students, and Guardians that either have established or will establish a contractual relationship with the School.
Legal Basis: The processing of Identification Data by the School will be carried out in order to allow the School to perform the tasks and services described in the Contract to which the Data Subject is a party, pursuant to Article 4.9 of Federal Decree Law No. (45) of 2021.
ATTENTION: The absence of consent for the processing of Personal Data of Students and/or Prospective Students registered with the School, particularly regarding authorization for the processing of Identification Data, would impede the rendering of educational services by the School as this information is essential for the performance of the Contract.
Financial Data: Personal Data that allows the School to perform bank collection or compensation for the educational services provided or for the registration of Students or Prospective Students, consisting, for example, of bank details, payment information, and credit card details of the Guardian.
Purpose: Financial data is collected to enable the School to properly and securely charge for its services.
Legal Basis: Financial data will be processed due to the need for the School to execute, or be allowed to execute, the Contract in which the Data Subject takes part, according to Article 4-9 of Federal Decree Law No. (45) of 2021.
Data Concerning Health: Personal Data relating to certain health conditions of Students and Prospective Students.
Purpose: Data concerning the health of Students and Prospective Students is collected to enable the School to render appropriate medical treatment when and if necessary, either during or before the execution of the educational services contract, as a preparatory measure by the School for the timely provision of services.
Legal Basis: This type of Personal Data will always be processed in the best interest of Students and Prospective Students, with the specific consent of at least one of their Parents and/or Guardians, pursuant to the purposes listed above.
Student's Performance Data: means Data related to the Student's pedagogical performance, consisting, for example, of disciplinary and educational observations, evaluations, tests, reports of grades, and absences.
Purpose: Performance Data is collected to allow Students, their Guardians, and the School to be aware of the Student's pedagogical performance. Amongst the intended purposes are (i) supporting Student learning; (ii) monitoring Student learning performance; (iii) verifying the quality of educational services provided by the School to Students; and (iv) compliance with legal and regulatory obligations, which determine, for example, the measurement of Student grade averages and attendance.
Legal Basis: Performance Data will be handled with the consent of at least one of the Student's (Prospective Student’s) parents and/or Guardians, always in their best interest, and within the parameters informed above.
ATTENTION: The absence of consent for the processing of Personal Data of Students and/or Prospective Students registered with the School, particularly regarding authorization for the processing of "Student’s Performance Data", would impede the rendering of educational services by the School as these pieces of information are essential for the performance of the contract.
Photography and Filming: Students and Prospective Students’ images that are used for cadastral or security matters.
Purpose: The images are collected in order to allow the School to properly identify its Students and Prospective Students during or prior to the provision of educational services, as well as to implement appropriate security measures in the school premises, via the CCTV system and others.
Legal Basis: Images of Students and Prospective Students will be treated by the School when at least one of their Parents and/or Guardians grants specific consent to do so.
Direct Marketing: Students, Prospective Students, and their Guardians may be asked to provide Personal Data, such as their name and E-mail address, for the purpose of receiving marketing communications by E-mail.
Purpose: The processing will only be carried out after the Data Subject’s voluntary disclosure, who will be asked to affirmatively opt into E-mail marketing communications.
Legal Basis: Specific consent to do so.
4. COLLECTING PERSONAL DATA
The School shall only collect data for specific purposes and with a proper legal basis for processing. Data obtained for specific purposes will not be processed for purposes different from the ones specified in this Privacy Notice unless the School properly notifies Data Subjects in this regard.
The collection of Personal Data occurs in the following cases:
Data Provided by the Student, Prospective Student, or their Guardian:
- Voluntary completion of registration forms, applications, or vacancy forms by the Student’s Guardian;
- Direct contact by E-mail, telephone, or any other form of electronic correspondence and/or letters;
- The Student, Prospective Student or Guardian voluntarily creates a profile on any of the Online Platforms provided by SABIS®;
- Through filling out electronic or paper forms, evaluations, reports, tests, simulations, notes, and attendance lists, as well as taking part in interviews and meetings, all of which are deemed necessary for the achievement of the educational services contracted and are submitted by the Student, Prospective Student or his/her Guardian to one of the School’s agents.
Internet Trackers:
The Data Subject’s Personal Data is electronically collected for statistical purposes and for the improvement of SABIS®’ website, using cookies (files stored in the Data Subject’s browser), web beacons, pixel tags, and transparent GIFs. The School and its service providers may also use other tracking technologies for website management and user tracking.
Online Platforms:
The School uses various Online Platforms as part of its educational services, which may include providing students access to software and tools not operated by the School. The use of such third-party platforms is subject to the specific and informed consent of the Student’s Guardian, as outlined in the School’s Consent Form, or through a separate consent that the data subject may provide directly when accessing or using one of these third-party platforms. Please note that this Privacy Notice does not apply to online tools or platforms that are not provided by SABIS® or operated on its behalf. The data practices of such non-SABIS® third-party platforms are governed by their own privacy policies, which users are encouraged to review.
Third Parties:
This consists of the collection of Personal Data that is provided and/or shared by authorized third parties or government agencies, including:
- Doctors, therapists, speech therapists, and other health professionals, always with the specific consent of the Student’s Guardian and in his/her best interest;
- Other educational establishments;
- Government bodies and regulatory authorities.
In case of medical emergencies, the Personal Data of Students may be collected without specific consent and its processing will be carried out exclusively for the protection of the Students, according to Article 4.4 of Federal Decree Law No. (45) of 2021.
Personal Data from third parties will be properly analyzed by the School in order to ensure that the information has been collected and is being shared on a legal and/or regulatory basis and is accurate and up to date.
5. PHOTOGRAPHY AND FILMING FOR PERSONAL USE
The School recognizes the need to safeguard the Personal Data and the privacy of its Students, both at school and on social media.
The School may use, post, or publish the Student’s Personal Data, classwork, or other school-related activities (for example, papers, artwork, films, stories, poems, writing, painting, drawing, projects, etc.) internally, on its premises, in print or digital format in the classrooms, the corridors, the digital boards, the school-based publications such as yearbooks, newsletters, posters, decorative material, reports, etc., or in the media galleries of the SABIS® web-based and mobile applications which can be only accessed and viewed by the School’s Students and Guardians, such as the SABIS® Digital Platform (SDP), SABIS® Parent, SABIS® Student, among others.
The School may also use, post, or publish the Student's image, by means of photographs, videos, and/or recordings, for the purpose of publicizing the educational services provided on Online Platforms and general media, always in the best interest of the Student.
The School recognizes the need to protect the Personal Data and privacy of its Students, both at school and on social media, and, therefore, will only use the image of Children with the specific consent of their Guardian(s), which will be collected from at least one of the Guardians through a CONSENT FORM (FORM)-DATA PROCESSING AND PHOTOGRAPHY AND FILMING section.
6. CONSENT
The processing of Students’ Personal Data will be strictly limited to the purposes outlined in Clause 3 and will be based on the specific and informed consent of the Student’s Guardian, as provided through the main Consent Form, as well as through any additional forms used to collect relevant data where consent is also explicitly obtained.
7. ACCESS TO PERSONAL DATA
Access to the Personal Data of Students, Prospective Students, and their Guardians will be restricted to professionals and agents assigned to the specific function of developing the process of enrollment, selection, and rendering of educational services proposed by the School.
8. STORING AND PROTECTING PERSONAL DATA
The School takes advanced administrative, technical, organizational, and physical measures to protect the Personal Data under its control. These measures include computer protection mechanisms and secure files and facilities access. In turn, once the purpose of the data processing is fulfilled, the School adopts appropriate measures to securely delete or permanently dissociate the Personal Data, depending on the applicable legislation and the compliance with the minimum data retention principle.
The School will retain Personal Data only for as long as necessary to fulfill the purpose for which it was collected. In the case of application forms, data will be retained solely for the purpose of evaluating and completing the student’s enrollment. If the student is enrolled, the School will retain all required Personal Data to deliver its educational services and to comply with applicable regulatory obligations. After the student’s departure, the School may continue to retain certain data to meet legal and regulatory requirements, and to provide necessary services such as issuing attestations, transcripts, or copies of grades. All data retention will be carried out in accordance with the provisions of Federal Decree Law No. (45) of 2021 concerning the protection of Personal Data.
The School reserves the right to contract third parties – Processors – to carry out the storage of Personal Data under its custody. These agents will have to process the Personal Data of prior written instructions determined by the School and to ensure the confidentiality and security of Personal Data subject to the Data Processing Agreement or other relevant agreements signed between the School and the Processor.
The School utilizes OneDrive and SharePoint storage in Azure Europe to store and back up its data, including Personal Data. A copy of the School's backup is also transferred weekly to SharePoint storage in Azure USA for data availability and disaster recovery purposes. The data (including Personal Data) stored on SharePoint is encrypted and can only be accessed by authorized IT personnel, strictly for disaster recovery purposes. Furthermore, the School’s data stored in Azure Cloud is backed up using the Azure backup tool and remains within the Azure environment. In addition, the School’s data is also backed up locally in the US Data Center and online via the Barracuda Cloud Backup service, which utilizes Azure and Amazon AWS cloud infrastructure in the US.
9. SHARING PERSONAL DATA WITH THIRD PARTIES
The School does not share Personal Data with any third parties, unless in the following situations:
- With regulatory authorities, courts, and government agencies to comply with legal orders, legal or regulatory requirements, and government requests;
- With regulatory authorities, and government agencies to detect and prevent fraud or other criminal activity and to protect the rights of the School or others;
- With company members of the SABIS® group of companies, in accordance with the applicable law; and
- With our service providers, suppliers, agents and contractors, to the extent that they assist us in carrying out the purposes set out in this form and for the execution of contracts and business development at the request of the School.
Regardless of the recipient, the School will only disclose the Data Subject’s Personal Data to third parties on a strictly need-to-know basis and only to the extent required to fulfill the purposes identified in this policy. The School does not sell the Data Subject’s Personal Data.
When Personal Data of Students, Prospective Students and Guardians has to be shared with third parties other than as described above, the School will notify the Data Subject to obtain specific consent for that purpose, subject to exceptions provided in applicable law.
Accordingly, the School reserves the right to store Personal Data under its custody with Processors who may or may not be located in the United Arabic Emirates. Taking into account article 10 below, and when Personal Data is transferred to other jurisdictions, the recipient of such information will always be countries or international organizations capable of providing an adequate degree of protection compatible with the Federal Decree Law No. (45) of 2021 concerning the protection of Personal Data, unless appropriate safeguards or mechanisms—such as contractual clauses or other legally recognized instruments—are in place to ensure the protection of the Personal Data.
The Consent Form details how the School may share certain personal data with other SABIS® entities, and such sharing is subject to the explicit and separate consent of the data subject’s legal guardian.
10. CROSS-BORDER TRANSFER OF PERSONAL DATA
In connection with the processing operations described in this Form, the School may transfer Data Subject’s Personal Data outside the UAE, including to countries that might not be recognized by the UAE Data Office (to be established by virtue of the FDL) as providing an adequate level of data protection.
In this context, the School ensures that the level of protection Data Subject’s Personal Data is given is not adversely affected by such transfers.
This specifically means that each of the intended transfers is based on one of the following mechanisms at least:
- the existence of an adequacy decision issued by the UAE Data Office for the country that Data Subject’s Personal Data is transferred to; or, alternatively;
- the existence of an exemption related to one of the specific situations exhaustively provided for by the FDL (e.g., where the Data Subject has given his/her consent to such transfer having been informed of the absence of safeguards, where the transfer is necessary for the performance of a contract concluded between the School and the Data Subject, where the transfer is necessary for the conclusion or performance of a contract concluded in the Data Subject’s interest between the School and a third party, or where the transfer is necessary for the establishment, exercise or defence of the School’s legal claims, etc.).
Indeed, and as the School is a member of the SABIS® School Network, Personal Data may be transferred and replicated outside the territory of the UAE to databases located in Microsoft Cloud Services in Ireland and SABIS Educational Systems Inc. (SES INC) in the United States. This allows the School to use SABIS® software, applications, and platforms to operate and provide educational services. Additionally, it enables Students and Legal Guardians/Representatives to access SABIS® application/software/platform hosted in these locations.
SABIS® application/software/platform support students' learning by monitoring and following up on their academic and non-academic performance, including exam results, attendance, discipline records, school calendar, study material, and SABIS® Student Life Organization (SLO) participation. The replicated Personal Data will also be used to run analytics and statistics on students, sections, classes, and the overall School’s academic performance.
11. DATA SUBJECT RIGHTS – COMPLIANCE WITH ART. 13 OF FDL.
According to the FDL, Data Subjects have rights in relation to the processing of their Personal Data, among them:
- The right to limit the personal data they provide to the School, except in cases where specific information is essential for the purposes outlined in this Privacy Notice;
- The right to be informed about the existence of processing of their Personal Data;
- The right of access, rectification, and update of their Personal Data;
- The right to request the erasure of their Personal Data, except in those cases where the Personal Data is essential to the activity provided by the School or when its storage results from a legal, regulatory, contractual obligation;
- The right to have their Personal Data transferred to another controller; consisting, for example, in sending Personal Data of Students to other educational institutes; and
- The right to withdraw their consent to the processing of their Personal Data, when applicable.
If the Data Subjects choose to exercise any of the rights described above, or if they have any questions about how the processing of their Personal Data flows, they may contact the School’s Data Protection Officer through the channels highlighted in Item 2 of this Privacy Notice.
12. DATA SUBJECT DUTIES
The Student’s or Prospective Student’s Guardian (s) is (are) responsible for the accuracy of the information they provide during the registration process with the School.
13. CHANGES TO THIS PRIVACY NOTICE
The School reserves the right to amend or modify this Privacy Notice at any time, considering, but not limited to, legislative, regulatory, and case law updates.
In the event of a change to the terms set forth herein, the School will notify the Students’ Guardians, detailing the changes and, if applicable, requesting an update of consent for the processing of the Student’s Personal Data.
If you have any questions, please contact us through the channels provided in Item 2 of this Privacy Notice.
