LCS will not collect any personally identifiable information about individuals, such as name, ID number, address, telephone number, online identifier (e-mail address), etc. ("personal data") and racial or ethnic data, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data containing health or sex life, sexual orientation, etc.("special category of data"), unless individuals have been informed of the purpose of collecting the data and individuals have given the lawful basis for the data to be processed.

LCS will only process data which is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

LCS may, with your explicit permission, submit your personal information to a third party institution or data processor for the purpose that will be communicated to you in advance.

The school will not sell, rent, or market personal data to third party institutions.

In the course of the application process, we collect the following personal information:

• Personal information (such as name, contact details, language, nationality, country of birth, photos, and passport information)
• Special category characteristics
• Ethnicity
• Relevant medical information
• Special educational needs (SEN) information
• Attendance information from previous schools (sessions attended, number of absences and absence reasons)
• Personal information from other sources (ex. schools) including:​​​​​​​
• Personal information, special category information, assessment/examination results,

We collect personal data for one or more of the following purposes:

• To support admissions (enrollment or re-enrollment) and Business Office (Fee billing) processes
• To monitor and report on student progress
• To inform teacher assessments
• To support student learning activities such as testing, field trips, awards, library needs, yearbook, food services, schedule of classes, university/college applications, transcripts
• To communicate and provide relevant information to students and parents
• To ensure safety and security of students and parents through the use of ID cards and campus surveillance camerasTo provide appropriate medical services to students
• To meet statutory reporting requirements to educational and accreditation authorities
• To provide appropriate learning support, pastoral care, and counseling support services to students
• To assess/review the quality of our provided services through various surveysTo support the withdrawal process
• To improve the education and services we provide to students  

In addition to some of the above data processing, we also collect staff data for the following purposes:

• To process staff employment contracts, retirement benefits, medical insurance, leave requests, payroll, and support staff loan applications
• To process employee statutory obligations (Resident Permit, TIN registration, Non-Citizen ID, Tax Clearance Certificate
• To conduct employee evaluations and procure professional development funding
• To provide all contractual obligations as stated in employee contract and conditions of employment

Apart from using your data to fulfill your contractual obligations, LCS may use the following non-sensitive data: your name, likeness (in the form of photographs, films, or portraits), and voice in the following venues: School intranet/ App (access would be restricted by password and limited to LCS staff, LCS students, and families of students).

1. School intranet/ App (access would be restricted by password and limited to LCS staff, LCS students, and families of students).
2. School ID card.
3. Print version of the LCS yearbook.
4. In class and co-curricular projects.
5. In school buildings.

We will hold your personal information securely in digital format permanently unless you ask us in writing to dispose of the records. A request to dispose of any records held on you will be subject to your rights as a data subject under the GDPR  as detailed in the section “your rights as a data subject” below and also the legitimate interest of LCS. Any hard copy transcripts or contracts retained after a student withdraws are retained for ten(10) years, after which the hard copy documents are securely destroyed.

LCS will seek explicit permission from you before it transfers your personal data to a third party institution or vendors ( such as in the case of withdrawing to another school). Data will only be transferred to a third party institution to fulfill the requirements of a process which the data subject is aware of and consents to. Below are who we share your data (information) with:

• Schools or colleges that you attend after leaving LCS
• Contracted providers of services (such as school photographers, food service providers at LCS, healthcare - Wara Ghana, Nationwide Medical Insurance, etc) where consent has been previously given
• Data processors or third-party providers for internal administrative or communication services (such as SchoolInfoApp, Finalsite, iSAMS, Open Apply, Faria systems, Managebac, Blackbaud, Google, Redstor, Rediker, HubTelsSMS)
• Online educational service providers (information society services) who are GDPR compliant and may collect personal information about your child(ren) for instructional purposes. To make changes to your online educational service providers permission, please complete this form
• Social Media sites, such as Twitter and Facebook, when explicit consent by families are given through the enrolment contract. To make changes to your social media permissions, please complete this form

Protecting your personal information is important to us. We use appropriate technical controls, organizational measures, and safeguards to help prevent unauthorized access, unlawful processing, and accidental loss of your personal information.

We also have procedures in place to deal with any suspected data security breach. We will notify you (and any applicable regulator) of a suspected data security breach where we are legally required to do so.

Cookies are small files containing information which may be downloaded to your computer or mobile device when you visit a website. We use cookies and analytical tools to help deliver our online services, identify any service issues, improve our online services, and monitor site traffic and usage.

We use analytical tools such as Google Analytics to monitor and improve our efficacy and performance.

More information about the ways in which Google Analytics collects and processes personal data can be found here: https://www.google.com/policies/privacy/partners.

More information about cookies, including how to block them on all sites or delete them, can be found at https://www.aboutcookies.org.

LCS uses email and other means to communicate for all aspects of the services we provide.

Please be aware that the LCS website may contain links to third-party websites. This Policy applies solely to information collected through this website. If you land on our website from other websites (or move to other sites from our website) you should read their separate privacy notice.

Data Subject Rights
As a data subject, whose personal information LCS holds, you have certain rights. In order to process requests, we ask you to complete a data subject access request form (DSAR). You will be required to provide one valid form of identification for verification purposes. Your rights are as follows:

• The right to be informed: LCS (Controller) is required to furnish you with clear and transparent information about data processing activities. By furnishing you with this privacy notice and any other related communication we may send to you, we are fulfilling this obligation.
   
• The right of access: Once your identity or, if necessary, the authority of your third party requester is proven, LCS will grant your request to access your personal data we hold without any cost. LCS will also provide the following information about your personal data:
  • The purposes of our processingThe categories of personal data concerned in processing
  • The recipients (data processor or third parties) to whom the personal data has been disclosed
  • The retention period or envisioned retention period for that personal data
  • The source of the personal data when personal data has been collected from a third party
  • Note: LCS reserves the right to refuse requests and will  inform you of the reasons for refusal. If your request is likely to require additional time we will inform you. In some cases, expenses incurred from your request will be your obligation to cover. LCS will inform you if there are any such charges .
     
• The right to rectification: You are allowed to exercise your right to update your personal data that LCS holds if you notice any inaccurate or incomplete personal information. While doing so, you may exercise your right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
   
• The right to erasure (the ‘right to be forgotten’): While LCS does not have any overriding legal basis or legitimate reason to continue  processing your personal data, you may request that we delete the personal data that may have been unlawfully or lawfully processed. LCS will take all reasonable steps to ensure erasure.
   
• ​​​​​​​The right to restrict processing: Under the following conditions, you may ask us to stop processing your personal data:
  • The accuracy of the personal data is contested
  • Processing of the personal data is unlawful
  • LCS no longer needs the personal data for processing but the personal data is required for part of a legal process
  • The right to object has been exercised and processing is restricted pending a decision on the status of the processing

In all cases, LCS will still hold the data, but will not process it any further.

• The right to data portability: You may request your set of personal data be transferred to another controller such as another school, college, or processor, provided it is transferred to a commonly used and machine-readable format. This right is only offered if consent was given for the processing of original data. Data may be transferred by automated means and must be the fulfillment of a contractual obligation (such as transferring to a new school).
  ​​​​​​​
• ​​​​​​​The right to object: You have the right to disapprove use of your data if that data processing:
  • is based on legitimate interest;
  • is for the purpose of direct marketing;
  • is for the purposes of scientific or historical research;
  • involves automated decision-making and profiling.

If you would like to contact us for one of the reasons mentioned above or you require further information on LCS’s Data Protection Policy then please contact our Data Protection Officer.

Mr. Peter Ken Bediako
Data Protection Officer (& Network and Systems Administrator)
Email : pkbediako@lincoln.edu.gh
Tel:+233-(0)30 2218 100
Mob:+233-(0)24 4896 494
Lincoln Community School
#126/21 Reindolf Road Abelemkpe, Accra, Ghana.

Local Supervisory Authority
Data Protection Commission (DPC)
www.dataprotection.org.gh
Tel:     +233-(0)30 2222 929
Email : info@dataprotection.org.gh