Modified 15 August 2022
International Schools Services (“ISS”) is a non-profit education services organization that primarily serves the international school community. We provide recruitment, supply, accounting, educational, training and management services to that community.
This policy explains how we collect personal information, the treatment of personal information that we collect when you are on our websites, and when you use our services, and use and disclosure of that information. This policy also applies to ISS’ treatment of any personal information.
This policy is provided to:
- Protect the security and confidentiality of protected information;
- Protect against anticipated threats or hazards to the security or integrity of such information; and
- Protect against unauthorized access to or use of Protected Information that could result in substantial harm or inconvenience to any customer.
This policy also provides for mechanisms to:
- Identify and assess the risks that may threaten protected information maintained by ISS;
- Designate employees responsible for coordinating the program;
- Design and implement a safeguards program;
- Manage the selection of appropriate service providers;
- Adjust the plan to reflect changes in technology, the sensitivity of protected information, and internal or external threats to information security; and
- Reference related policies, standards, and guidelines.
Identification and Assessment of Risks to Employee and Customer Information: ISS recognizes that it has both internal and external risks. These risks include, but are not limited to:
- Unauthorized access of protected information by someone other than the owner of the covered data and information;
- Compromised system security as a result of system access by an unauthorized person;
- Interception of data during transmission;
- Loss of data integrity;
- Physical loss of data in a disaster;
- Errors introduced into the system;
- Corruption of data or systems;
- Unauthorized access of covered data and information by employees;
- Unauthorized requests for covered data and information;
- Unauthorized access through hardcopy files or reports; and
- Unauthorized transfer of covered data and information through third parties.
ISS recognizes that this may not be a complete list of the risks associated with the protection of protected information. Since technology growth is not static, new risks are created regularly. Accordingly, ISS will actively monitor for new risks. ISS believes the current safeguards in place are reasonable and, in light of current risk assessments are sufficient to provide security and confidentiality to protected information maintained by ISS.
Personal Information Collection: Data input is voluntary and is associated with accounts that are accessible only after a user accepts our terms and conditions or signs up for ISS’ services. It is ISS’ usual practice to collect this personal information directly from you through the use of ISS websites in response to our printed and online advertisements. ISS websites include any site or subsite in the ISS.EDU domain, including, but not limited to, www.iss.edu and iss.edu. In addition, ISS may receive personal information about you through the use of third party vendors utilized by you for ISS services, including, but not limited to, www.cvent.com and www.instructure.com.
Express Consent: You acknowledge that if you submit an application or contract our services, your application or request for services will constitute your express consent to our use of your personal information in accordance with this policy as amended from time to time, including the receipt of communications in connection with such services in accordance with all applicable laws.
Information Types: Personal information that we collect, and hold is information that is reasonably necessary for the proper performance of our services and technology platforms. We collect the following types of information based on the entity, individual or service:
- Contact details, including organization contact and title information, as applicable;
- Communications with ISS;
- Billing and invoicing details.
- Training and education details and history;
- Historical notes, and notes typical of customer service; and
- Event registration and attendance.
In addition, for ISS recruiting services, we also collect the following types of information:
- Communication between Schools and Recruiters with Candidates or ISS;
- Communications between Candidates and Recruiters;
- Candidate Family details, including occupation of partner, ages of children, schooling requirements of children, housing requirements;
- Letters of recommendation;
- Candidate work history and relevant personal details, including interests, preferences, and any criminal records;
- Candidate offer and placement information;
- Record of comments provided for Candidates; and
- Rankings of Candidates by Referees.
Sensitive information is a special category of personal information. Sensitive Information is information or opinion about you, including but not limited to:
- membership of a professional or trade association, or membership of a trade union;
- health information;
- political opinions;
- philosophical views, membership of a political association;
- religious beliefs or affiliations;
- sexual preferences or practices.
ISS does not collect sensitive information. Any unsolicited sensitive information that an individual shares, as part of a text held or otherwise, will not be used by ISS for any discriminatory purpose.
In connection with ISS’ recruiting services, ISS does not use sensitive information to influence how we present Candidates to prospective employers. ISS does encourage all parties to use a non-discriminatory hiring process that does not use race, gender, age, or sexual orientation to influence their hiring decisions.
Protected Information: Protected information shall include, but is not limited to, any of the following categories of information and data:
- A user name or e-mail address in combination with a password or security question and answer that would permit access to an online account; or
- “Personal information” in combination with any one or more of the following unencrypted data elements:
- social security number;
- driver’s license number or non-driver identification card number;
- account number, credit or debit card number, in combination with a security code, access code, password or other information that would permit access to an individual’s financial account;
- account number, credit or debit card number, if circumstances exist wherein such number could be used to access an individual’s financial account without additional identifying information, security code, access code, or password; or
- biometric information, meaning data generated by electronic measurements of an individual’s unique physical characteristics, such as a fingerprint, voice print, retina or iris image, or other unique physical representation or digital representation of biometric data which are used to authenticate or ascertain the individual’s identity.
“Personal Information” shall mean “any information concerning a natural person which, because of name, number, personal mark, or other identifier, can be used to identify such natural person.”
Collection: The Personal Information that you submit to ISS will be used internally, and for the benefit of other third parties associated with ISS, who might require access to your personal information, as applicable:
- when you complete any application forms or provide any other information in connection with the services you utilize with ISS;
- via any third parties;
- as a result of inquiries that we might make of a professional association or registration body;
- as a result of any complaint or other information from or about you;
- via any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved;
- or when you provide us with any additional information about you or your organization.
Photos and Images: We may also receive Personal Information from trusted third parties. We may ask to see scanned photographic ID, including a passport or other relevant documentation where we need to verify your identity, work rights or qualifications.
Use of Information and Information We Share: ISS may use Personal Information collected differently depending on whether you are an entity or individual and based on the type of service to be provided as follow:
- perform client and business relationship management;
- support the ISS services that we deliver to you;
- facilitate ISS marketing services to you;
- provide support of the function of our technology platforms;
- statutory compliance requirements;
- to administer, protect and improve our website and our systems;
- to better understand the preferences of our website visitors;
- to compile aggregated statistics about our website usage; or
- respond to a request that you sent us.
For recruiting services, we may also use Personal Information to:
- assist Candidates in finding employment;
- assist Schools in finding qualified applicants;
- assist Candidates in being identified by a Recruiter;
- confirm a Referee’s identity and authority to provide references; or
- completing a candidate’s suitability assessment.
Direct Marketing: We may use information you provide us to contact you about our services that we believe may be of benefit to you. You explicitly agree to receive communications from ISS in connection with such services in accordance with all applicable laws. We will never sell your information to any third parties for marketing purposes. We comply with the requirements of anti-spam legislation and will give you the option of unsubscribing to email that is not essential to perform our intended business purpose.
How Personal Information is Stored: Personal information is held in our technology platforms until the time it is no longer needed for any purpose for which it may be used or disclosed. At this point it will be anonymized or destroyed, provided that it is lawful for us to do so. We take a range of measures to protect your Personal Information from:
- misuse, interference and loss;
- and unauthorized access, modification or disclosure.
Information Security: We adopt a number of procedures to protect the information that we hold from unauthorized access, including but not limited to:
- Staff training;
- Password protection policy for all ISS information technology services;
- Restricting access to information on a “need to know” basis;
- Policies and procedures to secure information on ISS infrastructure including mobile devices such as laptops and smart phones; and
- Culling procedures including data deletion/data anonymizing, physical shredding and secure document disposal.
Information Transfer, Data Storage, and Hosting: All ISS privacy data related to the technology services offered is hosted and managed by: International Schools Services. All data will be hosted by ISS/AWS at Amazon AWS. AWS Privacy: https://aws.amazon.com/privacy/.
In addition, ISS may utilize HubSpot, Inc. – https://legal.hubspot.com/privacy-policy – or other similar third-party vendors as may be needed from time-to-time.
Disclosure: Your Personal Information may be disclosed to employees, clients and licensees of ISS and trusted third parties include those in countries that we provide services to, regarding possible work placements or to assist us in providing our services to you, professional associations or registration body that have a legitimate interest in the disclosure of your personal and sensitive information and any person with a lawful entitlement to obtain the information.
We will also send information about you to other companies or people when we:
- have your consent to share the information;
- need to share your information to provide the product or service you have requested;
- need to send the information to companies who work on behalf of ISS to provide a product or service to you (unless we tell you differently, these companies do not have any right to use the Personal Information we provide to them beyond what is necessary to assist us);
- respond to subpoenas, court orders or legal process; or
- find that your actions on our web sites violate the above terms of service, or any of our usage guidelines for specific products or services.
Failure to Provide Personal Information: If you do not give us the information we seek we may be limited in our ability to assist you.
Correction: ISS may take such steps to make appropriate corrections, deletions and additions, in the circumstances that are reasonable to ensure that Personal Information is accurate, up to date and not misleading. If you have created a profile with ISS via our websites, you are able to review and edit your Personal Information at any time by logging into your account and reviewing your profile. You can delete your Personal Information or close your account via the prompts on our website. If you do choose to close your account with ISS, we may retain Personal Information from your account as and where required by law.
Access Policy: If you wish to obtain access to your Personal Information you should contact us via this form.
You will need to be in a position to verify your identity.
Control and Persistence of Your Private and Non Private Data: For your convenience, we will retain your information for as long as eight years after the last time that you were an active member of ISS services. ISS will securely dispose of any information that is beyond our retention policy, or that is no longer required. Where required by applicable law, we will notify you when such information has been disposed of.
Pursuant to data privacy laws, you may have the right to have your information removed from our systems, entirely. You may do so by using our data privacy form.
Your Rights: You have the right to withdraw your consent at any time or to access and request that we rectify or remove your Personal Information from our system(s). Local laws may give you additional rights, such as the right to request the information in your file, in a commonly readable format, at any time.
If you need assistance accessing, updating, correcting or removing your Personal Information from our System, or if you no longer desire our services, please complete this form. Please note that we will request proof of identity prior to acting on any request. In certain circumstances (for example where required or permitted by law) we might not be able to provide you with access to some of your Personal Information, but where appropriate, we will notify you of the reasons for this.
Links: Please be aware that this website may contain links to third-party websites. This Policy applies solely to information collected through this website. If you land on our website from other websites (or move to other sites from our website) you should read their separate privacy policies.
More information about the ways in which Google Analytics collects and processes personal data can be found here: https://policies.google.com/technologies/partner-sites.
More information about cookies, including how to block them on all sites or delete them, can be found at https://www.aboutcookies.org.
Design and Implementation of this Policy: ISS Compliance is responsible for coordinating, maintaining and updating this Policy.
1. Employee Management and Training
During employee orientation, each new employee in departments that handle protected information will receive proper training on the importance of confidentiality of protected information. Each new employee will also be trained in the proper use of computer information and passwords. Further, each department responsible for maintaining protected information will provide ongoing updates to its staff. These training efforts should help minimize risk and safeguard covered data and information security.
2. Physical Security
ISS has addressed the physical security of protected information by limiting access to only those employees who have a business reason to know such information. Existing policies establish a procedure for the prompt reporting of the loss or theft of protected information. Offices and storage facilities that maintain Protected Information limit access and are appropriately secured. Protected information in electronic form that is no longer needed is securely erased so that the protected information cannot be read or reconstructed. Paper documents that contain protected information are shredded at time of disposal.
3. Information Systems
Information systems include network and software design, as well as information processing, storage, transmission, retrieval, and disposal. ISS has policies, standards, and guidelines governing the use of electronic resources and firewall and wireless policies. ISS will take reasonable and appropriate steps consistent with current technological developments to make sure that all protected information is secure and to safeguard the integrity of records in storage and transmission. ISS will develop a plan to protect all electronic protected information by encrypting it for transit.
4. Management of System Failures
ISS will maintain effective systems to prevent, detect, and respond to attacks, intrusions and other system failures. Such systems may include maintaining and implementing current anti-virus software; checking with software vendors and others to regularly obtain and install patches to correct software vulnerabilities; maintaining appropriate filtering or firewall technologies; alerting those with access to covered data of threats to security; imaging documents and shredding paper copies; backing up data regularly and storing back-up information off site, as well as other reasonable measures to protect the integrity and safety of information systems.
5. Selection of Appropriate Service Providers
Due to the specialized expertise needed to design, implement, and service new technologies, vendors may be needed to provide resources that ISS determines not to provide on its own. In the process of choosing a service provider that will maintain or regularly access protected information, the evaluation process shall include the ability of the service provider to safeguard protected information. Contracts with service providers may include the following provisions:
- A stipulation that the protected information will be held in strict confidence and accessed only for the explicit business purpose of the contract;
- An assurance from the contract partner that the partner will protect the protected information it receives.
6. Continuing Evaluation and Adjustment
ISS will regularly test and monitor the effectiveness of key controls, systems and procedures of this policy. This policy will be subject to periodic review and adjustment, especially when due to the constantly changing technology and evolving risks. ISS will review the standards set forth in this policy and recommend updates and revisions as necessary. Accordingly, it may be necessary to adjust this policy to reflect changes in technology, the sensitivity of employee/customer data and internal or external threats to information security.
Questions and Complaints: You have a right to complain about our handling of your Personal Information if you believe that we have interfered with your privacy. Complaints can be initiated by this form.
Complaints Procedure: If you are making a complaint about our handling of your Personal Information, it should first be made to us in writing using our web form, or writing to Compliance:
International Schools Services
15 Roszel Rd, Princeton, NJ, 08543