Parish Episcopal School
General Statement of Information Privacy
Parish Episcopal School (“PARISH”) provides education and related services. In the normal course of these activities, PARISH collects, maintains and discloses information associated with individuals, some of which may be confidential while some may be non-confidential. This General Statement of Information Privacy (this “Statement”) addresses a number of PARISH information handling practices that apply to individually identifiable personal information and outlines other practices that apply to individual information that is not necessarily confidential. These practices include both traditional paper-based information handling activities as well as information collected by PARISH through websites owned, controlled, or operated by PARISH under a number of domains including:
These sites are collectively known as the “PARISH School Sites.” Some individually identifiable personal information handling practices may be subject to additional information privacy provisions as identified in later segments of this Statement. Information that is collected by PARISH in connection with its commercial transactions with individuals and legal entities may be subject to other contractual terms, agreements or regulations.
PARISH also contracts with third parties that may collect individually identifiable confidential and/or non-personal information. The following list of third-party sites, while not exhaustive, complete, or may be modified without notice, are used by PARISH:
- Camp Brain
We do not control the content or privacy practices of third-party sites. Interaction with third-party sites is subject to that website’s policies. We encourage you to review the privacy notices of those third party sites to understand their privacy practices.
Purpose and Format
This Statement has been organized into three sections as follows:
General Rules Regarding the Collection and Sharing of Individually Identifiable Information
1. Conformance with Legal and Professional Standards Regarding Personal information
2. Collection and Sharing of Individual Information that is Not Deemed Confidential
3. Contact “Opt-In” and “Opt-Out”
4. Third-Party Websites
Specific Privacy Supplements to the General Rules
- Student Records including Financial Information Collected for Financial Assistance Programs
- Transaction over the PARISH School Sites or third-party sites
Typical Practices Observed by PARISH in Meeting the General Rules and Specific Privacy Supplements
- Interactions with Individuals under Thirteen Years of Age
- Social Security Numbers and Other Government Issued Personal Identification Numbers
- Information Security and Destruction of Personal information
- Medical Information
- Credit Information
- Other Information Obtained from Third-Parties
- Web Server Login Information that PARISH may Gather
- Cookies and Login Security
Section 1-General Rules Regarding the Collection and Sharing of Individually Identifiable Information
The following are four general rules observed by PARISH regarding the collection, maintenance, use and sharing of individual information collected by PARISH through the PARISH School Sites and other means. In this Statement, all of the individually identifiable information that appears to a reasonable person to be confidential in the context and circumstances in which the information is known or used and which identifies an individual is collectively called, “personal information”.
1. Conformance with Legal and Professional Standards Regarding personal information
PARISH is committed to providing appropriate privacy and security of personal information provided to PARISH in the conduct of its activities. PARISH obtains, uses, stores, shares and disposes of personal information consistent with applicable federal and state laws.
In order to provide effective educational and other related services, PARISH collects, maintains, uses and shares Personal information internally with its divisions and departments, and externally with its subsidiaries and third-parties. Examples of Personal information PARISH obtains about individuals includes:
- Application Information: Personal information PARISH receives voluntarily from students and their parents, such as: application information that may include family financial information used to determine eligibility for financial aid.
- PARISH School Sites Information: Personal information PARISH collects or issues via the PARISH School Sites such as passwords.
- Internal PARISH Educational Records: Personal information PARISH collects or generates internally regarding certain aspects of student academic performance and disciplinary actions.
When circumstances arise for the need to share personal information, PARISH may share the personal information as follows:
- To our affiliates and amongst the PARISH School Sites;
- To fulfil the purpose for which you provide it;
- As authorized or required by court order, government request or investigation, subpoena, or as otherwise permitted or required by law;
- As necessary to protect the rights, property, safety, or interests of PARISH or others;
- As permitted under this General Statement or other formally adopted PARISH privacy statements;
- As required in connection with educational and financial aid programs administered by third-parties and their agents in order to assist those third-parties in the delivery of their programs.
- As clearly stated by PARISH program materials or other notifications, such as notices on the PARISH School Sites, that the Personal information will be shared and the user indicates the user’s consent by providing the Personal information;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PARISH’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PARISH is among the assets transferred;
- For any other purpose disclosed by us when you provide the information;
- To enforce or apply our terms and other agreements, including for billing and collection purposes; or
- When consent is otherwise given.
2. Collection and Sharing of personal Information that is Not Deemed Confidential
In order to provide effective educational and other related services, various operations within PARISH involve the collection of web use information or other information that may be identifiable to individuals but is not formally private or confidential (“non-confidential personal information”). Examples of non-confidential personal information may include:
- IP addresses
- Participation in PARISH Programs: personal information PARISH collects regarding individual constituent participation in educational activities or other programs offered by PARISH.
- Directory Information: personal information PARISH maintains such as PARISH generated IDs, name, address, telephone number, date of birth, participation in activities offered by PARISH, degrees and awards received, most recent and previous educational institutions attended.
- Parent to Parent Information: personal information PARISH may collect and make available from parent to parent in the form of student directories or the identity of parents who choose to cooperate together in education related activities or services.
- PARISH School Sites Information: personal information such as the IP Address (computer identity) of those who access the PARISH School Sites or the sequencing of Web pages visited as used to improve PARISH services.
- Cookie Enabled Information: personal information that may be obtained via PARISH School Sites cookies (computer use files) which are transferred to a user’s hard drive to enable the PARISH School Sites to deliver personal services.
- When circumstances arise for the need to share personal information gathered from PARISH operations, in addition to being authorized to share non-confidential personal information in accordance with this General Statement as it relates to the sharing of personal information, PARISH may also share non-confidential personal information as otherwise authorized for good cause by PARISH management
3. Contact ‘Opt-In’ and ‘Opt-Out’
In its effort to best provide services, PARISH may seek to better identify the groups that it serves and to contact persons in those groups regarding its services. As such, PARISH uses the PARISH School Sites or other information collection procedures that allow individuals to authorize PARISH to contact those users about its services. These authorizations may at times also involve the use of ‘Opt-Out’ elections that users may select in order to indicate their desire not to be contacted. In some cases, where PARISH is proactively seeking to establish contact, PARISH may use default ‘Opt-In’ provisions that do not require individuals to make an active option selection to receive further contact.
4. Third-Party Websites
Section 2-Specific Privacy Supplements to the General Rules
In addition to the general rules described above, PARISH has adopted more specific privacy provisions regarding the collection and sharing of personal information associated with certain collection activities. Some of those special cases are noted below.
Student Records including Financial Information Collected for Financial Assistance Programs:
PARISH generally seeks to protect the privacy of educational records. PARISH reserves the right to release personal information to qualified third-parties. Parents and students are allowed to:
- inspect, review and obtain copies of their own education record,
- request that others review the student’s education record. Requests should be made in writing to the Division Head or his/her designee.
- obtain copies of PARISH’s policies and procedures concerning parent/student access to education records. Requests should be made at the appropriate campus or educational administrator site office.
Some forms of personal information may, at times, be received by PARISH but fall outside standard PARISH privacy protections if the personal information is received by PARISH inadvertently or outside the regular PARISH personal information collection processes. This may include personal information that is provided to PARISH in the absence of a request by PARISH for the personal information such as when the personal information is included with non-confidential material. This form of inadvertent personal information collection may occur in situations such as when an individual enrolls in a PARISH program and includes a Social Security Number on an application where no field exists to collect that information and where there was no intent on the part of PARISH to collect that information. In such cases, the application forms may not be handled with the presumption that confidential personal information exists on the forms.
Section 3-Typical Practices Observed by PARISH in Meeting the General Rules and Specific Privacy Supplements
Interactions with Individuals under Thirteen Years of Age
PARISH is committed to protecting the privacy and safety of our students. Accordingly, if a user of the PARISH School Sites is under the age of thirteen, such user is requested not to provide PARISH with personal information, and PARISH will not knowingly use any such information in its database or as part of other data collection activities. PARISH cautions users under the age of thirteen and their parents or guardians that the collection of individual Information voluntarily provided by such a user without the knowledge of PARISH via the PARISH School Sites or other electronic or paper methods will be treated by PARISH the same way as information given by an adult. In addition, such information may be subject to public access until PARISH becomes aware that the information provider is under the age of thirteen. These provisions do not apply to the regular school interactions or homework assignments of under thirteen PARISH learners participating in on-going PARISH educational activities.
Social Security Numbers and Other Government Issued Personal Identification Numbers
It is PARISH’s general practice to avoid the collection of Social Security Numbers (“SSNs”) and other government issued personal identification numbers unless those numbers are required for compliance with state and federal law and/or are needed for effective service delivery. For example, SSNs are required for various forms of financial aid assistance assessments. Persons interacting with PARISH should avoid providing SSNs and other government issued personal identifiers in general correspondence or email, but should instead provide such identification only via the specific forms for doing so in accordance with applications or PARISH School Sites forms specifically created by PARISH for collecting such information.
Information Security and Destruction of Personal Information
The security of personal information is a priority at PARISH. PARISH employs industry-standard information security practices consistent with the standards and practices adopted by other educational institutions, and by businesses which provide similar services. PARISH protects personal information by maintaining physical, electronic and procedural safeguards designed to secure your personal information from accidental loss and from unauthorized use, access, alteration, and disclosure. PARISH trains its employees in the proper handling of Personal information. When PARISH uses third-parties for services, PARISH requires these third-parties to protect the confidentiality of any personal information they receive. PARISH also disposes of personal information in accordance with applicable state and federal laws.
PARISH collects medical information regarding its students and may collect medical information at times for others such as PARISH employees. PARISH policies regarding the handling and safekeeping of medical information are intended to be consistent with applicable legal requirements for K-12 academic environments and with respect to employees generally.
Other Information Obtained from Third-Parties
In addition to credit reports and medical information, PARISH may obtain personal information from third-parties. PARISH maintains and shares personal information received from third-parties in the same way it maintains and shares personal information received directly from individuals.
Web Server Login Information that PARISH May Gather
PARISH School Sites may generate logs that may contain information about computers or devices used by users to access the PARISH School Sites or which contain information about general activity on the PARISH School Sites, such as the following:
- Internet address of computer or device
- Type of browser used
- The operating system of the computer or device
- Web pages requested
- Referring Web pages
- Time spend on the PARISH School Sites
PARISH School Sites administrators may produce summary reports from these logs and share that information with PARISH personnel and/or third-party vendors responsible for PARISH School Sites content management. PARISH School Sites content managers typically use this information, in aggregate, to understand what pages are popular, how users are navigating to and within sites, and when PARISH School Sites are used most frequently. PARISH generally avoids the inclusion in server logs of personally identifiable information that could identify particular users. The previously stated General Rules Regarding the Collecting and Sharing of Personally Identifiable Information and other segments of Specific Privacy Supplements to the General Rules provide further information on when individual information may be shared.
Cookies and Login Security
Cookies are small pieces of data stored by a web browser on a user’s computer. Cookies are often used to retain information about preferences and pages a user has visited. For example, when a user visits some sites on the Web, one might see a “Welcome Back” message. The first time one visits a PARISH School Sites, a cookie may be stored on the user’s computer; and when the user returns, the cookie is read again. One can refuse to accept cookies, one can disable cookies, and one can remove cookies from one’s hard drive.
PARISH School Sites may use transient or transactional cookies that facilitate the continuity of interactions during a particular visit. PARISH does not typically use permanent cookies and will not use other invasive tracking programs that monitor and track PARISH School Sites viewing habits unless:
- the use of permanent cookies adds value to the user otherwise not available;
- there is a comprehensive online statement at the particular PARISH School Sites where such permanent cookies or other invasive monitoring and tracking programs are utilized that discloses:
- all types of information collected at that site;
- PARISH’s use of that information; and
- how the collection and use of this information adds value to the user; and
there is a link to this Statement from that particular PARISH School Sites where such permanent cookies or other monitoring and tracking programs are utilized.
If an individual, including a PARISH School Sites user, has questions about this Statement please send an email to: firstname.lastname@example.org
In the email, the individual should include the individual’s name, and Personal information a description of the question or concern.