Privacy Policy & Personal Data Protection (PDPA)

Last Updated: [Insert Date]

1. Introduction

HeadStart International School ("the School", "we", "us", "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy outlines how we collect, use, disclose, and protect the personal information of our students, parents, staff, and visitors in compliance with Thailand's Personal Data Protection Act B.E. 2562 (2019) ("PDPA").

We recognise that choosing a school involves a significant amount of trust. We value that trust and are dedicated to managing your data with transparency and care.

2. Scope of this Policy

This policy applies to:

• Prospective Families: Individuals inquiring about enrolment or visiting our campuses.
• Current Families: Students and parents/guardians currently enrolled at HeadStart.
• Alumni: Former students and families.
• Visitors: Individuals visiting our Chaofah City or Cherngtalay campuses.
• Website Users: Visitors to headstartphuket.com.

3. Personal Data We Collect

We collect data necessary to provide a safe, world-class education and to ensure the smooth operation of our community. This includes:

• Identity Data: Names, identification numbers (passport/Thai ID), date of birth, gender, and nationality.
• Contact Data: Home addresses, telephone numbers, email addresses, and emergency contact details.
• Sensitive Personal Data:
  • Health Information: Medical history, allergies, dietary requirements (e.g., for halal or vegetarian meals), and vaccination records.
  • Religion: For appropriate dietary provision and cultural observance.
• Educational Data: Academic records, school reports, examination results (e.g., Cambridge IGCSE, A-Levels, BTEC), and behavioral records.
• Financial Data: Bank account details, payment history, and billing information for tuition and fees.
• Visual Data: Photographs and videos of students participating in school activities, sports days, productions, and daily life.
• Technical Data: Cookies and usage data when you visit our website.

4. Purpose of Collection and Legal Basis

We collect and process personal data based on the following legal grounds:

• Contractual Basis: To fulfill the enrolment agreement and provide educational services.
• Legal Obligation: To comply with Ministry of Education regulations, tax laws, and Thai authorities.
• Legitimate Interest: To ensure campus security, improve our facilities, and support student wellbeing.
• Consent: Explicitly obtained for marketing, photography, and specific sensitive data processing.

These purposes include:

1. Educational Delivery: To facilitate enrolment, deliver the English National Curriculum, manage timetables, and track academic progress.
2. Student Wellbeing & Safeguarding: To provide medical care, ensure campus safety, managing dietary needs, and comply with our Child Protection and Safeguarding policies.
3. Communication: To send important updates, newsletters, and reports to parents (e.g., via the Parent Portal or email).
4. Accreditation & Examination: To register students for external examinations (Cambridge, Pearson/EdExcel) and maintain our accreditations (EDT, ISQM).
5. School Administration: To manage billing, school bus transportation, and extracurricular activities (ECAs).
6. Marketing & Community Building: We use photographs and videos of school activities (e.g., "Sports Days," "CAPA Productions") in our Yearbooks, website, and social media to celebrate student achievements and showcase our "School Life" to prospective families.

5. Disclosure of Personal Data

We may share necessary data with trusted third parties to fulfill our educational obligations:

• Educational Authorities: Ministry of Education (MOE), OPEC, and examination boards (Cambridge Assessment International Education, Pearson).
• Associations: FOBISIA and ISAT for competitions and memberships.
• Service Providers:
  • Insurers (for Student Group Accident Insurance).
  • Catering partners (for dietary management).
  • Transport providers (School Bus GPS and management systems).
• Health Providers: Hospitals or clinics in the event of a medical emergency.

We do not sell your personal data to third parties.

6. International Data Transfers

As an international school, we may transfer personal data outside of Thailand. For example, student exam data is sent to examination boards in the UK (e.g., Cambridge Assessment), and some of our educational software uses secure cloud servers located abroad. We ensure that any such transfer is protected by appropriate safeguards and complies with the PDPA.

7. Photography and Media Use

HeadStart is a vibrant community, and we frequently document school life.

• Consent: Upon enrolment, parents are asked to consent to the use of their child's image for school publications (Yearbook, Newsletters) and marketing (Website, Social Media).
• Withdrawal: Parents may withdraw consent for the use of images in marketing materials at any time by contacting the School Office.
• Visitor Restrictions: To protect our students, visitors are strictly prohibited from taking photographs of children or looking into classrooms during school hours, as per our Visitors Code of Conduct.

8. Cookies

Our website uses cookies to improve your user experience and analyze website traffic. For detailed information on the specific cookies we use and how to manage your preferences, please refer to our separate Cookie Policy.

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by Thai law.

• Student Files: Retained for a specific period after the student leaves the school to facilitate future references or university applications.
• Financial Records: Retained in accordance with tax and accounting laws.

10. Data Security

We implement appropriate security measures (physical, electronic, and administrative) to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. This includes secure server storage and restricted access for staff based on their role necessity.

11. Treatment of Minors

Under the PDPA, the processing of personal data for minors (individuals under the age of 20) often requires the consent of a parent or legal guardian. As an educational institution, we strictly adhere to this requirement by obtaining parental consent during the application and enrolment process.

12. Your Rights

Under the PDPA, you have the right to:

• Access: Request a copy of the personal data we hold about you or your child.
• Rectification: Request correction of inaccurate or incomplete data.
• Deletion: Request the erasure of data (under specific circumstances).
• Object/Restrict: Object to or restrict the processing of your data.
• Withdraw Consent: Withdraw consent for data processing where consent was the legal basis (e.g., marketing photos).
• Complaint: Lodge a complaint with the Personal Data Protection Committee (PDPC) if you believe we have not complied with the PDPA.

13. Changes to this Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. Any changes will be posted on this page with an updated revision date. Significant changes may be communicated directly to parents via email or the Parent Portal.

14. Contact Us

If you have questions about this policy or wish to exercise your rights, please contact our Data Protection Officer (DPO) or the School Administration at your respective campus:

HeadStart International School

Chaofah City Campus
39/99 Moo 4, Vichitsongkram Rd., Soi Na Seau 1, T.Vichit, A.Muang, Phuket 83000
Email: [email protected]
Phone: +66-76-612875

Cherngtalay Campus
9/2 Srisoonthorn Road, T.Cherngtalay, A.Thalang, Phuket 83110
Email: [email protected]
Phone: +66-76-510623