As used in this Policy, means information about an identifiable individual. This includes any information that can be used to identify, contact, or locate a specific individual, or to identify an individual in context. In the context of the School, this refers to information about an identifiable student, employee, parent of a student, volunteer, contractor or alumnus of the School.

This includes, but is not limited to:

• Direct identifiers: such as your full name, email address, postal address, phone number, social security number, online identifiers (like usernames and IP addresses).
• Quasi-identifiers: information that, when combined with other data, could identify you, such as your date of birth, gender, race, ethnicity, location data, and certain online activity.

Other personal information: This may include age, gender, identification numbers, income, personal references, information about health and job performance (including productivity, relationships, and reputation with co-workers, opinions expressed by co-workers, promotion prospects, disciplinary measures), physical descriptions, marital history, immigration status, travel or movement details, and information about an individual’s lifestyle, leisure activities, legal proceedings, academic records, career history, insurance policies, and claims.

Please note:

• Personal Information generally does not include business contact information, such as the title, business address, business telephone number or business email address of faculty and staff when it is collected, used or disclosed by the School solely for the purpose of communicating or facilitating communication with the faculty and staff in relation to their employment.
• With respect to any specific individual, the School may or may not have Personal Information within these enumerated categories.
• We recognize that the definition of PII is evolving and can depend on the context. We are committed to protecting all information that could reasonably be used to identify an individual.

The foundation of this Policy rests upon the principles enshrined in Schedule 1 of PIPEDA, ensuring that our practices align with established privacy standards.

HTS collects various types of personal information, including but not limited to:

• Contact Information: Name, address, phone number, email address.
• Family Information: Parent/guardian names, contact information, emergency contacts.
• Admissions Data: Application forms, transcripts, test scores, references.
• Academic Records: Grades, attendance, assessments, special education needs, individualized education programs (IEPs).
• Financial Information: Tuition payments, billing records, financial aid applications.
• Health Information: Medical records, allergies, immunization records, medication information.
• Employment Information: Resumes, references, background checks, payroll information.
• Images, Audio, and Video Recordings: We collect photos, videos, and audio recordings from various school events and activities. For detailed information on the purpose of this collection and how this media is used, please refer to the HTS Student Media Consent Policy and Form.
• Website Visitor Data: IP address, browser type, pages visited, referring website.
• Event Attendance: Records of participation in school events and extracurricular activities.
• Fundraising and Communication Information: Donation history, communication preferences, survey responses.
• Police Reference Checks: For staff and volunteers, as required by law.
• Student Support Information: To provide comprehensive care and personalized learning experiences for students, the School may collect sensitive personal information, including but not limited to medical notes (psychologist reports), plans of care (allergy management), family history, and student behavior data (physical abilities, learning styles). This data may be used to foster student well-being, facilitate individualized learning plans, and for reporting and dashboard purposes.

Data Minimization

The School is committed to the principle of data minimization and will limit the collection of personal information to that which is strictly necessary for identified purposes related to the operation of the School. These purposes include, but are not limited to, educational instruction, student support services, school administration, compliance with legal obligations, and the maintenance of a safe and enriching learning environment.

HTS uses personal information for the following purposes:

• Providing Educational Services: Teaching, learning, assessment, academic support, special education services.
• Administering School Operations: Admissions, registration, financial aid, communication, record-keeping.
• Supporting Student Well-being: Providing a safe and supportive learning environment, addressing bullying, self-harm, and grief through appropriate interventions.
• Communicating with the School Community: Newsletters, announcements, event information, parent-teacher communication.
• Managing Extracurricular Activities: Organizing and supervising clubs, sports teams, and other activities.
• Managing Employment and Volunteer Relationships: Recruitment, hiring, training, payroll, performance management.
• Ensuring School Security: Monitoring school premises, managing access control, investigating incidents.
• Meeting Legal Obligations: Complying with reporting requirements to the Ontario Ministry of Education and other legal authorities.
• Managing School-Sanctioned Excursions: Ensuring student safety and facilitating logistical arrangements.
• Engaging with Alumni: Tailoring communications, events and opportunities to align with alumni interests.
• Offering Special Programs and Events: Developing and delivering relevant programs and events catered to the interests of the HTS community.

The School may use personal information collected from its current and former faculty, staff, and volunteers and students to create and manage its employment and volunteer relationships, including, for example, to solicit and evaluate applications, to hire and retain individuals, to administer employment-related services such as payroll and benefits, and to monitor performance. 

Only certain individuals within the School are authorized to view and use personal information. Those individuals are permitted to use the information only for the purposes for which the information was collected. The School has implemented policies on the appropriate handling and safeguarding of personal information. It trains its faculty and staff on these policies, and requires their adherence to these policies. 

Some of the personal information collected by the School is stored by outside hosted databases or cloud storage providers. The School selects third-party service providers that commit to maintaining appropriate security measures for personal information and complying with applicable privacy laws. The handling of personal information by these providers is governed by our contractual agreements with them.

Storage and Security:

• Personal information is stored securely in various formats, including paper files, electronic databases, and cloud-based systems.
• Access to personal information is restricted to authorized personnel based on their roles and responsibilities.
• HTS implements appropriate physical, technical, and organizational security measures to protect personal information from unauthorized access, use, disclosure, alteration, or destruction.
• If personal information is stored outside of Canada, HTS ensures that it is done in compliance with applicable data protection laws, including PIPEDA and the General Data Protection Regulation (GDPR).
• We adhere to leading industry cybersecurity guidelines, including NIST, and maintain a comprehensive security policy. We conduct regular internal and external maturity threat analyses and penetration tests to ensure our security practices meet or exceed industry standards.

Sharing Information:

• Third-Party Service Providers: To support our operations and enhance the educational experience, HTS collaborates with various third-party service providers. These providers may include e-learning platforms, transportation services, and other essential vendors. In addition, HTS may organize field trips or educational excursions that involve interactions with third-party vendors. While HTS prioritizes data minimization and only shares information necessary for the provision of these services and activities, please be aware that these vendors may have their own data collection practices.
• Jotform: HTS utilizes Jotform, a HIPAA-compliant platform, for secure online forms and data collection. When engaging with third-party vendors through Jotform, it is essential to review their respective privacy policies to understand their data collection and handling practices. HTS cannot guarantee these vendors' adherence to all applicable privacy laws. By submitting information through a Jotform form to a third-party vendor, you acknowledge and consent to their data collection practices as outlined in their privacy policy
• Legal Obligations: HTS may disclose personal information to comply with legal obligations, such as reporting requirements to the Ontario Ministry of Education, or in response to a court order, subpoena, or other legal process.
• Protecting Safety and Security: HTS may disclose information when necessary to protect the safety and security of students, staff, or the school community.
• Consent: Except as required or permitted by law, HTS will not disclose personal information to others outside of the School without the consent of the individual.
• No Sale or Trade: HTS does not rent, sell, or trade personal information.

HTS Vendor Selection and Privacy Due Diligence

Holy Trinity School is committed to partnering with vendors who share our commitment to privacy and data security. We have a rigorous vendor selection process that includes a comprehensive review of their privacy practices, security measures, and compliance with applicable laws and regulations. This process applies to all vendors, including digital tools and services (e.g., educational apps, online learning platforms) and those providing services in physical locations (e.g., field trip destinations, transportation providers).

To ensure transparency, we maintain a list of approved vendors, including links to each vendor's privacy policy and terms and conditions. You can request access to this list by contacting the HTS Privacy Officer at privacy@hts.on.ca. This allows you to make informed decisions about the information you share with these vendors.

While we strive to work with reputable organizations, we cannot guarantee vendors absolute adherence to all applicable laws. We encourage our community members to review vendor privacy policies carefully and contact us with any questions or concerns. You acknowledge and agree that HTS has no control over such practices, and as a result agree to hold HTS harmless for any harm caused to you by a third-party vendor’s acts or omissions. Notwithstanding the foregoing, HTS will fulfil its contractual obligations with respect to monitoring a vendor’s compliance with its obligations to protect personal information under its agreement with HTS.

Individuals have the following rights regarding their personal information:

• Access and Correction: You have the right to access and request correction of your personal information held by HTS.
  • The School makes efforts to ensure that all personal information held in relation to an individual is as up-to-date and accurate as possible. All community members should notify the School of any significant changes to important information, such as contact details. Current families will be asked to verify their demographic information on an annual basis.
• Withdrawal of Consent: You may withdraw your consent to the collection, use, or disclosure of your personal information, subject to certain legal or contractual restrictions.

Complaint Process: If you have concerns about the handling of your personal information, you may file a complaint with the school's designated privacy officer by contacting us by emailing Waqas Khan at privacy@hts.on.ca.

Holy Trinity School (HTS) recognizes the potential of Artificial Intelligence (AI) tools to enhance education and operations. The School is committed to the responsible and ethical selection and use of AI, ensuring alignment with our core values and applicable privacy legislation.

Key privacy considerations when using AI tools at HTS include:

• PIPEDA Compliance: Applying PIPEDA's principles of consent, accountability, purpose limitation, and safeguards to the collection, use, and disclosure of personal information via AI tools.
• Consent and Supervision: Obtaining appropriate consent for AI use involving personal information, with specific requirements for students:
  • Parental/guardian consent is required for students aged 13 and over to use AI tools collecting personal information beyond standard agreements.
  • Students under 13 must have direct adult supervision and/or explicit parental/guardian consent for using generative AI or tools requiring personal input.
• Data Minimization: Limiting the collection of personal information through AI tools to what is reasonably necessary for identified educational or operational purposes.
• Safeguards: Implementing reasonable administrative, technical, and physical safeguards to protect personal information processed by AI tools.
• Vetting and Transparency: Committing to reviewing AI tools for privacy and security implications and striving for transparency regarding their use within the school community.

For comprehensive details on how HTS governs the use of AI, including specific usage guidelines, data protection measures, ethical considerations, and the principles guiding our approach, please refer to our dedicated Holy Trinity School Artificial Intelligence (AI) Policy.

• Cookies and Similar Technologies: Our website may use cookies and other tracking technologies to enhance your browsing experience and collect information about how you use our site. You can control cookies through your browser settings.
• Third-Party Analytics: We use Google Analytics to analyze website traffic. For information on their data practices, please review their privacy policy. 
• Links to Other Websites: Our website may contain links to other websites. We are not responsible for the privacy practices of those websites.

Data Security: We are committed to protecting the security of your personal information submitted through our website. We use industry-standard security measures to protect against unauthorized access, use, or disclosure.

HTS may update this privacy policy from time to time. Updates will be communicated through the school website, newsletters, and other appropriate channels.

This privacy policy will be made readily accessible on the HTS website, including the footer, admissions pages, google drive and any online forms or platforms used by the school. "I Agree" checkboxes will be used to obtain consent where appropriate.

Holy Trinity School is dedicated to maintaining a transparent and trustworthy environment for all members of our community. We are committed to protecting personal information and using it responsibly to support our educational mission.