1. Introduction

At all locations operating under the Jo.Ha.Ku brand. we take the control of personal data seriously and responsibly and use the data stored by us in accordance with the law. Our privacy policy contains detailed information on how we process personal data.

2. Types of personal data we collect and process

We process personal data about potential, actual and former: students and their parents; employees, suppliers and contractors; sponsors, friends and benefactors; and others who are associated with or visit our locations (including students who take courses with us during the holidays).

The personal data we process takes many forms – it can be factual information, expressions of opinion, images (photographs) or other recorded information that identifies or relates to a living person. In particular, it is about:

• names, addresses, telephone numbers, e-mail addresses and other contact details;

• family data;

• discipline records and other documents related to education, information on special educational needs, recommendations, evaluations;

• images (photos), audio and video recordings;

• financial information (for example, paid services);

• attended courses, meetings or events.

We are a Network of Child Development Centers (hereinafter referred to as the Network), and we need to process personal data of special categories (for example, health data) and information about the criminal records of some individuals (employees). We do this in accordance with applicable law (also taking into account safety or employment measures) or with the express consent of the person concerned.

3. Collection, processing and sharing of personal data

We receive much of the personal data we process directly from the person concerned (or, in the case of students, from their parents). In some cases, we collect data from third parties (for example, a guarantor or referrer, previous schools, the Criminal Records and Employment Bans Service - or a similar service in other countries - or professionals or authorities working with by the relevant person) or from publicly available resources.

The personal data stored by us is processed by the relevant employees within the scope of the purpose for which the data was provided. We take the necessary technical and organizational measures for the security of personal data, including policies for the use of technologies and devices, as well as access to information systems.

In the course of our activities, we share personal data (including special category personal data where necessary) with third parties such as medical staff, professional early development consultants and relevant local and international authorities. Some of our systems are provided by third parties. This is always subject to contractual guarantees that personal data will be stored securely and only in accordance with our specific instructions.

4. Purposes for which we process personal data

We process personal data to support the activities of our network for students aged 1 to 18, and in particular for the following purposes:

Selection and enrollment of students;

Ensuring the education of students, including the preparation of the curriculum and schedule; monitoring of students' performance and their educational needs; compilation of internal progress reports and reports to parents; enrollment of students for testing, provision of recommendations to students;

Providing learning support and related services to students (and parents), including discipline support; management of sports games and teams, organization of network visits; provision of the information and communication system (IT) network and virtual learning environment (and its monitoring) in accordance with our IT policies;

Organization of educational courses and their attendance during school holidays for students studying in such courses;

Ensuring the physical, social and emotional well-being of students by the staff, providing medical services and attentive, caring treatment of students;

Research and development of effective methods and best practices of teaching and learning;

Compliance with legislation and regulations, including preparation of information for inspections, provision of necessary information to relevant ministries and official bodies / organizations;

Operational management, including compiling a student database; administration of invoices, payments and invoices; network property management; security and security management (including the use of video surveillance cameras and monitoring of information and communication systems in accordance with our Acceptable Use Policy); managerial planning and forecasting; research and statistical analysis; administration and enforcement of rules and policies for students and staff; support of archives and other operational purposes;

Personnel management, including recruitment / engagement of contractors (including in accordance with the Service of disclosure of data on criminal records and prohibitions on obtaining positions and with similar procedures); administration of wages, pensions and sick leaves; review and evaluation of staff work; handling any complaints, opportunities or disciplinary procedures; maintaining relevant personnel documentation for current and former employees; providing recommendations;

Promote the network through its own websites, brochures and other publications and communications (including through our social media channels); and

Maintaining relationships with former students, families and the wider community by communicating with current and former students and/or their parents or guardians and organizing events.

The data processing mentioned above is carried out to fulfill our legal obligations (including obligations under the agreement with the parents and the employment contract). These purposes operate within our legitimate interests.

5. Contact support

We keep in touch with former students, current or former parents or other members of our community. We may use contact information to keep them up to date with our activities and invite them to events of interest via email and regular mail. Please let us know your information preferences so we can make sure our messages are relevant to you.

6. How long we keep personal data

We retain personal data only on a lawful basis and only for as long as necessary or required by law. We adhere to the Record Retention Guidelines, which set out the period of time for which different categories of data are retained. If you have any specific questions about the retention period of our data or would like your personal data to be deleted, please contact us by email at johaku.ukraine@gmail.com.

7. Your rights

Under data protection laws, you have various rights to access and understand the personal data we hold about you and, in some cases, to request its deletion or modification or to stop processing it, but with some exceptions and limitations . You always have the right to withdraw consent where given or otherwise object to receiving general communications. However, be aware that the network may have another legitimate reason for processing the data in question, even without your consent. This reason is usually stated in this Privacy Policy or may exist in any form of contract or agreement with an individual (for example, in the form of a Public Offer, an employment contract or an agreement with parents).

If you wish to access or modify your personal data, or wish to have it transferred to another person or entity, or have other objections to the use of your personal data, please contact us by email at johaku.ukraine@gmail.com.

We will respond to any such written requests within the objective time frame and in any case within the time limit set by law. We will be able to respond more quickly to small targeted requests for information. If the request is clearly excessive or similar to previous requests, we may ask you to review the request or charge a proportionate fee, but only where permitted by applicable data protection law.

8. Data on students

Rights under data protection legislation belong to the person to whom the data relates. However, we will often rely on parental consent to process personal data relating to students (where consent is required), except where, given the nature of the processing and the age and consciousness of the student, it is more appropriate to rely on consent student

Parents should be aware that they may not be consulted in such situations depending on the best interests of the child, the parents' rights under the law or under their contract, and all the circumstances.

In general, we assume that students' consent is not required for the routine provision of their personal data to their parents, such as to inform parents about the student's activities, performance and behavior, and in the interests of the student's well-being, unless, in the network's opinion, there is a good reason to do otherwise .

However, if a student raises a concern in confidence with a network employee and expressly refuses to consent to the disclosure of their personal information to parents, we may be required to maintain confidentiality unless, in our opinion, there is a good reason not to do so – for example, if the network believes that disclosure is in the best interests of the student or other students, or is required by law.

Students may request subject access to their personal data provided they are mature enough to understand what they are requesting. Our students usually have this level of maturity. A parent usually has the right to request subject access on behalf of students, but the requested information is considered to belong to the child by law. Students of any age can ask a parent or other representative to make a subject access request on their behalf. 

In addition (if the students are mature enough), parents making such a request may need their consent or permission.

9. Change of details

We try to keep all personal data stored about an individual as up-to-date and accurate as possible. Tell the mayor's office about any material changes to important information we hold about you, such as your contact details.

10. This policy

We will update this Privacy Policy from time to time. We will communicate any material changes affecting the way we process your personal data on our website and directly to you as far as possible.

If you believe that we have not complied with this policy or are acting differently than required by data protection law, you should notify the Information Technology Manager. You can also contact our staff, but we recommend that you take steps to resolve the matter with us before involving them.

11. Date of policy and date of next review

This policy will be reviewed every two years or sooner if necessary.

Effective date: August 2023

Review date: August 2024 and every two years thereafter.

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