Privacy Policy

INTRODUCTION
Founded in 1829, Upper Canada College (UCC) is one of Canada’s foremost boys’ schools. UCC’s  Preparatory School enrolls 410 students from Senior Kindergarten to Year 7, while the Upper School has 760 students from Years 8 to 12. The College’s boarding program welcomes more than 85 students from across Canada and the world. Graduates of UCC — an International Baccalaureate World School — are highly regarded by universities worldwide. Our global network of alumni includes leaders and innovators in politics, finance, arts, athletics, media and beyond.
 
UCC’s commitment to respecting private data use is in accordance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) legislation and the Canadian Anti-Spam Legislation (CASL) standards, and the following privacy policy provides information on how the College collects and processes personal data.
 
For further information, please contact Kathleen Peak, Executive Director, Information and Innovation, at kpeak@ucc.on.ca or (416) 488-1125 ext. 3331.

TYPES OF PERSONAL DATA UCC PROCESSES
UCC keeps and uses personal information from the point of inquiry to the College through enrolment to a student concluding his time at the College. This includes day and boarding students as well as participants in other programs associated with the College, such as Summer Camps and the Summer Life program. UCC keeps data on students and their parents or guardians, staff, vendors, donors, contractors, volunteers and friends of the College, and other individuals connected to the school. The personal data kept is listed below, although not all types of data are kept for each individual. The personal data stored about individuals depends on their roles and the business and operational needs of the College.
 
The personal data kept by the College Includes:
  • Name, date of birth, addresses, telephone numbers, e-mail addresses, marital status, custody status, and other contact/family details
  • Information needed to support individuals within the College such as health card number and social insurance number
  • Admission references, examination reports and any other data required to support the admissions process
  • Academic, disciplinary and other education-related records, information about special educational needs, references, examination reports, grades and evaluations, and any data needed to support the educational success of our students
  • Education and employment data
  • Images and audio and video recordings
  • Financial information, if received
  • Courses, meetings, and events attended
As a College, there is a need to keep and process special categories of data such as health and financial information. UCC does so in accordance with regulations applicable to this specific data.

COLLECTING, HANDLING AND SHARING PERSONAL DATA
Most of the data collected comes directly from the individual or family concerned. There are occasions where the data collected is from third parties (e.g. previous school, references) or from publicly available information. Personal data is protected by internal data policies and is accessed only by appropriate staff to perform necessary business tasks. This data is guarded by user privilege sets as well as backup processes and procedures. Personal data is only shared externally when needed for the business purposes of the College (e.g. Toronto Public Health and the Ontario University Application Centre). UCC does not otherwise share or sell personal data to other individuals or organizations without expressed permission.
 
UCC works with third-party vendors to minimize private student data usage. We ensure that the companies comply with the expectations of the College with regard to privacy practices, data storage and backup, data residency, and retention. This is true for all students from JK to Year 12.
 
As part of our secure parent portal (Bluenet), family contact information is shared within the UCC parent community.  To request to have this contact data removed from the directory, please send a written notice to Prep or Upper School Administration.

PROCESSING PERSONAL DATA
Personal data is kept and processed to support the academic and business operations of the College.  We process personal data to support daily operation which includes:
  • Selection and admission of pupils
  • Data required for the Ontario Student Record (OSR)
  • Academic, operational and support data kept beyond the OSR requirement for students and parents at the College
  • Compliance with PIPEDA and CASL
  • Employee administration including recruitment of employees  administration of payroll, pensions and sick leave, review and appraisal of  employee performance, conduct of any grievance, capability or disciplinary procedures; and the maintenance of appropriate human resources records for current and former staff; and providing references
  • Promotion of the College through the UCC website and social media channels, prospectus and other publications and communications (Maintaining relationships with alumni and the school community by communicating with students and families and organising events.
The above process is carried out to fulfil UCC’s legal obligations (including those under parent and employee contracts).  

ADVANCEMENT AND KEEPING IN TOUCH
UCC is a Blackbaud organization leveraging Blackbaud’s Education Management Systems, Financial Edge (FE) and Raiser’s Edge (RE) systems, together with a number of other systems and tools. The College’s technology infrastructure is generally supported on the technical side by the Department of Information and Innovation. The College is supported by a Data Governance Committee which ensures that all departments follow policies and procedures regarding the use of data at the College. The College's Advancement department plays an important role on this Committee.
 
Configuration, management and operation of RE is largely the responsibility of the Office of Advancement. The Executive Director, Advancement Operations is an RE specialist and is the lead on database issues, training, and user profile implementation. Prospect research for the College is currently conducted by individual fundraisers with the Assistant Vice Principal of Advancement responsible for prospect assignments. 
 
Of particular note is the CASL process and procedure found at this link.

HOW LONG IS PERSONAL ACADEMIC DATA KEPT?
Student academic data is kept as required by the Ontario Student Record (OSR) record keeping policies as outlined by the Ontario Ministry of Education. Student transcripts and supplementary OSR information, for those who graduated from the College, are kept for 55 years. This information is available by request through the Registrar’s Office if the student graduated from the College. and the OSR was not moved for other reasons (e.g. usually enrolling in another school). 
 
Non-academic personal data of students is deleted from software systems under certain circumstances, including when the student(s) no longer use the system, when the College is no longer in a contract with the software vendor, or when the student is no longer enrolled at the College. This is done to ensure the protection of student's personal information and to comply with data retention policies.
 
YOUR RIGHTS
You have rights under various data protection legislation and standards to access and understand the personal data UCC holds about you. These rights include the ability to request for data erasures or data correction or to request UCC stop processing your data. UCC may be bound by legal obligations or business limitations that may prevent data requests from being fulfilled, and in some cases to ask for it to be erased or amended or for UCC to stop processing it, but subject to certain exemptions and limitations.
  
You have the right to withdraw consent, where given, at any time, or otherwise object to receiving generic or fundraising communications. Please be aware however that the College may have lawful reasons to process the personal data in question even without your consent. That reason will usually have been asserted under this privacy policy, or may exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership to one of our societies).
 
If you would like to access or amend your personal data please contact the appropriate school office or the office of Advancement directly.

CHANGE OF DETAILS
UCC tries to ensure that all personal data held and processed by the College is as up-to-date and accurate as possible. Please log into Bluenet to check your contact card in the profile area. Any changes should be sent to the appropriate school office.

THIS POLICY
UCC’s privacy policy should be read in conjunction with other College policies and terms and conditions which make reference to personal data including, but not limited to, UCC's family handbooks and academic program guide.
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