ST PETER’S TRUST BOARD PRIVACY POLICY
November 2021
Version 1.0
1. PURPOSE:
1.1 In its role as a good employer the St Peter’s Trust Board is required to ensure that a safe environment at St Peter’s, Cambridge is provided through personnel practices that maintain standards of integrity and conduct. As such the purpose of this policy is to promote and protect individual privacy.
2. SCOPE:
2.1 This is an all-encompassing policy that applies to all staff, students, parents/guardians, volunteers, alumni, house assistants, student teachers, donors, contractors, visitors and other people associated with St Peter’s, Cambridge, both on-site and externally representing St Peter’s, Cambridge.
2.2 This policy applies to any individual associated with St Peter’s, Cambridge who may be required to collect, access, use or disclose personal information, who may manage projects or systems that impact on personal information management, or who are responsible for making policy decisions about the way St Peter’s, Cambridge manages personal information.
2.3 St Peter’s Cambridge, includes the campus located at 1716 Cambridge Road, Leamington, Cambridge 3283, OWL Farm, Swim School, Swimming Club, Golf Academy and any other associated locations. It also includes any website or online platforms that are operated by St Peter’s, Cambridge.
3. DEFINITIONS:
3.1 Personal information: Any information, whether electronic or hard copy, about an individual whether or not the information directly identifies the individual, and includes but is not limited to contact, demographic, health and academic information, CCTV footage, staff performance information, emails and other correspondence, and opinions about the individual.
4 POLICY:
4.1 St Peter’s, Cambridge collects and processes personal information about students, parents, caregivers, alumni, donors, staff members, contractors, house assistants, student teachers, volunteers and individuals who visit its websites and campus. St Peter’s, Cambridge is required to comply with the Privacy Act 2020 and its associated regulations but it also intends to lead by example and make certain that its privacy practices meet the expectations of its global community.
4.2 St Peter’s, Cambridge recognises that the individuals concerned will only surrender their personal information if they trust St Peter’s to use the information responsibly and treat it with care and respect.
4.3 Procedures within the school must comply with the 13 privacy principles contained in Part 3 of the Privacy Act 2020 which have specific requirements in terms of:
- Purpose of collection of personal information
- Source of personal information – directly from the person where possible
- Collection of information from subject
- Manner of collection of personal information
- Storage and security of personal information
- Access to personal information
- Correction of personal information
- Accuracy of personal information to be checked before use or disclosure
- School is not to keep personal information for longer than necessary
- Limits on use of personal information
- Limit on disclosure of personal information
- Disclosure of personal information outside New Zealand.
- Taking reasonable steps to protect unique identifiers
5. RESPONSIBILITY:
5.1 All school community members are responsible for compliance with this Privacy Policy.
5.2 We will not transfer your information to an overseas-based service provider or organisation unless we are satisfied that the service provider has obligations to protect your information in a way that is comparable to the protections afforded by New Zealand privacy law or you expressly consent to the transfer.
5.3 The Principal of St Peter’s, Cambridge has appointed a Privacy Officer. The Officer’s role is to promote and protect individual privacy with regard to:
- The collection, use, storage and disclosure of information relating to individuals
- Access by each individual to information relating to that individual, held by the school
- Assisting with the management of privacy breaches and other privacy issues by St Peter’s, Cambridge members
- Liaising with third parties in respect of privacy matters, including the Privacy Commissioner or other relevant regulators and individuals concerned
- Managing privacy complaints from individuals concerned
5.4 The school’s Privacy Officer is contactable as follows: privacyofficer@stpeter.school.nz
6. COLLECTION AND PROCESSING
6.1 St Peter’s, Cambridge must collect only necessary personal information for a lawful purpose connected with the function or an activity in relation to the school.
6.2 Personal information should be collected from individuals directly, unless an exception can be relied upon to collect it from a third party in accordance with the Privacy Act 2020.
6.3 Data may be shared with third-party contractors/suppliers to the extent necessary for them to administer or work on behalf, or to work on special projects with us.
6.4 The safety of our students at St Peter’s is paramount. We ensure that all personal information that is collected from students is done so in a fair manner and does not intrude to an unreasonable extent upon the personal affairs of the individual concerned.Note: Exceptions are listed in Principle 2 of the Privacy Act 2020. The usual basis on which we collect information from a third party is with the authorisation of the individual.
6.5 The purposes for which personal information is collected and used by St Peter’s, Cambridge may include but are not limited to:
- Demographic details
- Contact details
- Employment data
- Identification documents
- Interactions and communications with us and our systems;
- Your location (including whether you are accessing our systems from on or off-campus and your location on campus);
- Device ID (when you use a device to connect to our systems);
- Your image (including, through campus surveillance footage and for student/staff ID cards);
- Medical information
- Education records and academic/research history
- Business operational data
- Operational farm data
6.6 If you are a prospective staff member applying for a position with us, or a contractor engaged (or seeking to be engaged) to provide services to us, the information we collect about you will include the categories of information described above that are necessary for us to consider and decide upon your application for employment, or to decide and manage your terms of engagement with us.
7. COLLECTION AND PROCESSING
7.1 St Peter’s, Cambridge takes all reasonable steps to protect personal information against loss, manipulation, misuse and unauthorised access.
7.2 St Peter’s, Cambridge retains personal information for as long as is necessary for our Purposes and Legitimate Interests and for us to comply with our legal obligations and perform our contracts with individuals. St Peter’s is required under New Zealand law to retain information in accordance with the Public Records Act 2005.
8. SECURITY
8.1 Many staff members of St Peter’s, Cambridge are required, by the nature of their roles:
- to be able to access personal student and staff information on a Student Management System;
- and/or the HR databases and/or any of the school’s information systems;
- and/or to work with, or be aware of, personal student and staff information in a wide range of contexts e.g. administration relating to student assessment or staff appointments.
8.2 Access to personal information, which is to be granted in accordance with the established approval processes for each system and/or data set, should only be granted if required by a staff member’s role.
8.3 Certain staff members undertaking specific roles in the school involving reporting to external agencies are authorised to release particular information relating to students and staff to the relevant agencies.
8.4 A student or staff member may authorise a staff member to release their personal information to a particular individual or agency; such authorisation must be provided in writing.
8.5 The provision of staff members' names as referees by students and former students is considered to be authorisation for the release of information relating to the academic performance of those students and former students, in terms of this policy.
9. MARKETING USE
9.1 We will use your information to communicate with you and carry out our marketing activities. Generally, these communications would be by email, text message, post or telephone. We do not pass on your information to other organisations for their own communications and marketing purposes.
10. GOVERNMENT AGENCIES
10.1 St Peter’s, Cambridge may make information available to official government agencies in accordance with principles 10 & 11 of the New Zealand Privacy Act 2020.
11. DISCLOSURE
11.1 Apart from where you have consented or disclosure is necessary to achieve the purpose for which it was submitted, personal information may be disclosed in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities. Also, we may disclose personal information when we believe in good faith that the law requires disclosure.
12. OUR SCHOOL WEBSITES
12.1 St Peter’s, Cambridge owns the following websites:
12.2 When you visit our websites, we do collect some non-personal information, such as the IP address from which you accessed this website, the date and time you are visiting, the pages you accessed, the type of browser and operating system you use, and terms you use to search for content on our site. This information cannot be used to personally identify you. We use it for the purposes of system administration, auditing use of the site and improving it for different customer profiles, and for our internal reporting. If you choose to provide us with personal information such as your email address, for example by filling out an electronic query, we will use the information only for the purposes that you authorise it to be used for.
12.3 We use cookies to collect and analyse information on our sites performance and to enable the site to function. We also share information about your use of our site with our social media and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.
12.4 Cookies are small text files that can be used by websites to make a user's experience more efficient. The law in New Zealand states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission. Our website uses different types of cookies. Some cookies are placed by third party services that appear on our pages. You can at any time change or withdraw your consent.
12.5 We respect your right to privacy and your right to view and update the personal information we hold about you. We are committed to protecting your privacy when you visit our website.
13 CAMPUS SURVEILLENCE
13.1 St Peter’s, Cambridge has monitoring capabilities at multiple locations throughout the campus. Signage advising of the surveillance monitoring system gives notice of areas covered by such equipment. The surveillance cameras are movement activated and will record any movement in the areas covered by individual cameras 24 hours per day.
13.2 We will store your personal information we collect from you in accordance with our obligations under the New Zealand Privacy Act and will take reasonable steps to ensure the security of your personal information.
13.3 We usually retain surveillance footage for a period of 21 days. We may retain surveillance footage for longer if required by law, or if we think doing so is appropriate to help us with any of the purposes outlined above.
13.4 For further information regarding this please see our St Peter’s, Cambridge Surveillance and Monitoring Policy.
14 REPORTING A PRIVACY BREACH
14.1 A privacy breach occurs when there is unauthorised or accidental access to someone’s personal information or disclosure, alteration, loss or destruction of personal information. It can also include situations where the school is stopped either temporarily or permanently from accessing personal information.
14.2 Personal information is any information about an identifiable individual, such as their name, address, or photo. The information does not need to name someone specifically, as long as they are identifiable in other ways.
14.3 If you become aware of a privacy breach, immediately notify:
14.4 The school’s Privacy Officer (privacyofficer@stpeter.school.nz)
14.5 Even minor privacy breaches must be notified. If there is a privacy breach, further information will be provided on actions required.
15. YOUR RIGHTS
15.1 You have the right to ask for a copy of any personal information we hold about you, and to ask for it to be corrected if you think it is wrong (and you are unable to update it yourself through a relevant online service). If you would like to do this, please email the privacy officer, privacyofficer@stpeter.school.nz. You may need to provide specific details about the nature of your relationship with St Peter’s and the information you are seeking so that we can easily locate it for you.
15.2 You also have the right to make a complaint to the Office of the Privacy Commissioner if you think we have breached, or may have breached, your privacy. You can contact the Office of the Privacy Commissioner at www.privacy.org.nz.
Chairperson: 
Date: November 2021
Next Review Date: November 2022
