International School Ho Chi Minh City's Privacy & Cookie Policies
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International School Ho Chi Minh City PRIVACY NOTICE FOR STUDENTS AND ALUMNI
INTRODUCTION
- In this privacy notice, references to “we”, “us”, “our”, “the school” or “School” refer to International Education Corporation, the owner of International School Ho Chi Minh City (“ISHCMC”) and International School Ho Chi Minh City – American Academy (ISHCMC AA).
- This privacy notice applies to students and alumni of both ISHCMC and ISHCMC AA.
1) BACKGROUND
1.1. International Education Corporation belongs to Cognita, a UK-based group of independent schools. We comply with all Vietnam’s regulations on Personal Data Protection (“PD Regulations”).
1.2. PD Regulations recognize your rights to your personal data held by the school, as well as the needs of the school to collect, use, retain, access, transmit and disclose your personal data for enrolling you at school.
2) WHAT PERSONAL DATA MIGHT THE SCHOOL HOLD ABOUT YOU
2.1. Data that the school collects when your parents enrolled you at the school. Examples include full name, date of birth, gender, nationality, photograph (headshot), and your ID information.
2.2. Data that is generated while you study at the school:
2.2.1. Student academic records (school reports, attendance logs, transcripts, exam results, diploma).
2.2.2. Book borrowing records.
2.2.3. Conduct and behavioral notes.
2.2.4. Child protection documents.
2.2.5. Counseling documents generated when a student needs counseling support.
2.2.6. Headshot image taken annually by School.
2.2.7. Photo, video that are taken, recorded in a school event, an outdoor education trip, or capture in the school CCTV system. CCTV footage will not be disclosed other than where we are required to do so to fulfill any legal obligations (for example, where we are under an obligation to share CCTV footage with the police).
2.2.8. Student health care dossier (this might include accident or injury reports, visitation note, prescription note).
2.2.9. Digital content generated by you while studying, using the school-provided account such as emails, classroom assignments, save files, technical data when using school devices or school Wi-Fi (e.g. account log, internet usage information).
2.3. Data that we collect, and process based on your consent: this might include hobbies, acquired tertiary education, occupation information that the school collects from you in an alumni form, in which we will ask for your explicit consent for such data processing.
2.4. Sensitive data
Data about health information (excluding information about blood type), child protection documents, image of Vietnam’s identification card, and data about special education need are categorized as sensitive data under PD Regulations and Cognita Personal Data Protection Policy.
Kindly refer to the Privacy Notice for Parents, Guardians, and Helpers for full details about what data the school holds about you.
Data about health information (excluding information about blood type), child protection documents, image of Vietnam’s identification card, and data about special education need are categorized as sensitive data under PD Regulations and Cognita Personal Data Protection Policy.
Kindly refer to the Privacy Notice for Parents, Guardians, and Helpers for full details about what data the school holds about you.
3) WHY WE COLLECT YOUR DATA, WHAT WE DO WITH THEM
We collect and process your data so that we could:
3.1. provide an educational service appropriate with School values and policies to which your parents have provided the acceptance and support by signing the Parent Agreement,
3.2. ensure that you are kept safe at school, and
3.3. comply with relevant legal requirements.
For details, kindly refer to the Privacy Notice for Parents, Guardians, and Helpers.
4) TRANSMISSION OF PERSONAL DATA OUTSIDE VIETNAM
4.1. The data that we process about you may be transferred to, and stored at, a destination outside Vietnam. We try to limit this where possible, but it may be necessary where, for example, one of our suppliers has a data center outside Vietnam. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice and that the appropriate legal safeguards are in place prior to the transfer, for example conducting a personal data impact assessment before sharing data with any supplier, ensuring that any contracts between us and the recipient of the information have standard data protection clauses.
4.2. Similarly, we share your personal data within the Cognita group, which may involve transferring your personal data outside of Vietnam. All members of the Cognita group are part of an agreement which uses specific standard contractual terms approved for use in the UK to give the transferred personal data the same protection as it has in the UK.
5) YOUR RIGHTS & RESPONSIBILITIES
5.1. Under PD Regulations, you have the following rights:
5.1.1. Right to know. You have the right to be informed about how, why, and where we process your data.
5.1.2. Right to view, have a copy of data. You can request to view or request for a copy of personal information held by the school about you.
5.1.3. You also have the right to correction, the right not to be subject to automated decision making or profiling, the right to restriction, the right to object, and the right to complain.
For details, kindly refer to the Privacy Notice for Parents, Guardians, and Helpers.
5.2. Under PD Regulations, you are responsible for:
5.2.1. Respecting and protecting the personal data of others, especially when you want to take a picture or film a video on school premise.
5.2.2. Keeping the school informed if you’re from 18 years old and older, and any of the collected personal information about you changes during your studying at school. It is important that the information we hold about you is accurate and current.
6) HOW LONG WE KEEP YOUR PERSONAL DATA
6.1. We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data is processed.
6.2. We follow a Personal Data Retention policy which determines how long we keep specific types of personal information for. For details, kindly contact our Data Protection Officer as in section 7 below.
7) CONTACT US
7.1. Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at Data.ComplianceVN@cognita.com.
7.2. If you’re under 18 years old, please ask your parents or guardians to contact school on your behalf.
7.3. To request for your academic record, please follow the current school’s policies and procedures.
8) CHANGES TO OUR PRIVACY NOTICE
8.1. Any changes we make to this privacy notice in the future will be posted on our website. Please check back frequently to see any updates or changes to our privacy notice.
International School Ho Chi Minh City PRIVACY NOTICE FOR PARENTS, GUARDIANS, AND HELPERS
- In this privacy notice, references to “we”, “us”, “our”, “the school” or “School” refer to International Education Corporation, the owner of International School Ho Chi Minh City (“ISHCMC”) and International School Ho Chi Minh City – American Academy (ISHCMC AA).
- This privacy notice applies to parents, guardians and helpers of both ISHCMC and ISHCMC AA.
1) BACKGROUND
1.1. International Education Corporation belongs to Cognita, a UK-based group of independent schools. We comply with all Vietnam’s regulations on Personal Data Protection (“PD Regulations”).
1.2. PD Regulations recognize your rights to your personal data held by School, as well as our needs to collect, use, retain, access, transmit and disclose your personal data for enrolling your child at School.
2) WHAT PERSONAL DATA WE COLLECT
You may give us personal data about you or your child when you: (a) use, visit, or interact with our website (such as filling out forms or registering on our website); (b) visit School; (c) correspond with us by phone, email, or post; or (d) send information to us directly, when you pay fees, give us medical records or information about your child’s health, complete school admission forms, sign the parent agreement or provide information as requested by us and/or which is necessary from time to time.
2.1. Personal data of parents/ guardians/ helpers:
2.1.1. Data that we collect from you where appropriate:
a) Full name, contact details (home address, email address, phone number).
b) Relationship with the child. We may also collect supporting documents such as the child’s birth certificate, a guardianship form, or a court order.
c) Employment information (company name, company tax number, company address, email address, phone number).
d) Bank account details (bank account number, account holder name).
2.1.2. Information about your activities on School website: see Cookie Policy on School website.
2.1.3. We install 24/7 CCTV cameras on our premises so your image might be captured in the CCTV footage while you are on campus.
2.1.4. Purchase and payment history of tuition fee, after-school activities, or at any items in the school shops such as canteen, uniform shops, other catering vendors.
2.2. Personal data of student:
2.2.1. Data that we might collect from you:
a) Full name, date of birth, gender, nationality, photograph (headshot).
b) ID information: passport, Vietnamese National identification card, birth certificate.
c) Educational history and other academic information of your child (example: past year group, past grade, past school reports, letter of recommendation).
d) Medical information or other relevant information of your child (example: height, weight, allergies, immunization history, health history).
e) Educational development or other relevant information of your child (example: special learning needs, English as an additional language needs).
2.2.2. Data of your child that might be generated while the child is studying at the school:
a) Student academic records (school reports, attendance logs, transcripts, exam results, diploma).
b) Book borrowing records.
c) Conduct and behavioral notes.
d) Child protection documents.
e) Counseling documents generated when a student needs counseling support.
f) We take headshot photo of all students annually to update the child’s image on school system.
g) Photo, video that are taken, recorded in a school event, an outdoor education trip, or captured in the school CCTV system. CCTV footage will not be disclosed other than where we are required to do so to fulfill any legal obligations (for example, where we are under an obligation to share CCTV footage with the police).
h) Student health care dossier (this might include accident or injury reports, visitation note, prescription note).
i) Digital content generated by your child while studying, using the school-provided account such as emails, classroom assignments, save files, technical data when using school devices or school WiFi (e.g. account log, internet usage information).
2.3. Data that we collect, and process based on your consent: as described in the Parent Agreement or a consent form that we will ask for your explicit consent.
2.4. Sensitive data
Data about health information (excluding information about blood type), child protection documents, data about special education need, image of the Vietnamese National identification card, data about your payment history of tuition fee, after-school activities, or any payment to items sold at the school shops (canteen vendor, caterer vendor, uniform shop) are categorized as sensitive data under PD Regulations and Cognita Personal Data Protection Policy.
Data about health information (excluding information about blood type), child protection documents, data about special education need, image of the Vietnamese National identification card, data about your payment history of tuition fee, after-school activities, or any payment to items sold at the school shops (canteen vendor, caterer vendor, uniform shop) are categorized as sensitive data under PD Regulations and Cognita Personal Data Protection Policy.
3) WHY WE COLLECT YOUR DATA, WHAT WE DO WITH THEM
The school collects and processes personal data about you and your child for the following main purposes: (1) to provide an educational service appropriate with School values and policies to which you have provided your acceptance and support by signing the Parent Agreement, (2) to ensure smooth and effective communication with you and ensure the safety of your child at school, and (3) to comply with relevant legal requirements.
3.1. Purpose 1 – Delivery of appropriate educational service
3.1.1. Determining eligibility for enrollment at the school.
3.1.2. Assessing, monitoring, reporting on student progress.
3.1.3. Teaching, giving assignment, providing practice sessions via learning application or digital tools employed by School from time to time.
3.1.4. Educational analytics purpose: we might use educational technology and artificial intelligence systems to help our teachers understand your child's learning journey more deeply. These tools assist our staff in analyzing academic data to:
- Spot trends: identify areas where your child is excelling or may need extra support.
- Create personal studying plans: suggest tailored learning goals and activities based on your child's unique progress.
- Support teachers: provide insights and assistance that help teachers plan lessons more effectively.
We ensure that all final decisions regarding your child’s grades, reports, learning plans, and teaching materials are made by qualified educators, not by a computer. For details, kindly contact our Data Protection Officer as in section 7 below.
3.1.5. Monitoring students’ use of Information and Communication Technology to ensure compliance with the school’s policies.
3.1.6. Disclosing information to the exam boards (for example, International Baccalaureate Organisation) to successfully administer exams for your child during their study at school.
3.1.7. Administering our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
3.1.8. Ensuring that data in the School academic reports are accurate and up to date.
3.1.9. Providing you and your child with the school’s yearbook containing selective photos of student’s activities throughout the school year.
3.1.10. To achieve the above purposes, we rely on software applications to process data. These include the school’s management information system, virtual learning environments (including the setting of tasks and homework), revision tools, booking systems (including but not limited to booking a parent-teacher meeting, booking an event, registering for an after-school activity), text and email messaging communications, assessments of pupils’ progress, our group-wide billing system and co-ordination of school trips. We also rely on third parties that deliver physical services such as caterers, photographers, trip providers, and transport providers. All third parties processing your and your child’s personal data (also known as “data processors”) are carefully chosen and vetted by us to ensure that, among other things, your data is kept secure. For details about data processors, kindly contact our Data Protection Officer as in section 7 below. We might also need to disclose information to the members of the Cognita group of companies for data analytics purposes so that we can improve our educational service at a group level.
3.2. Purpose 2 - Effective communication and security of the student
3.2.1. Responding to your questions and feedback.
3.2.2. Keeping you up to date with school news and upcoming events and offer opportunities and information that we believe may be of interest to you.
3.2.3. Sharing with you the student’s learning moments via the official communication channel or the systems employed by School at the time.
3.2.4. Billing and for finance management.
3.2.5. Providing academic references, educational history, or safeguarding history to a third-party School as per your request when your child(ren) transfers to such third-party School.
3.2.6. Conducting surveys of parents and students either by the school or a third party on behalf of the school to assess the performance of the school.
3.2.7. Safeguarding and promoting the welfare of students, parents, and staff. For example, we store the headshot image of students, parents and staff among the school community in School systems so that we can provide suitable care for each student or that we can immediately identify a stranger entering school campus.
3.2.8. Ensuring the health and safety of students and staff. To achieve this purpose, we may:
- keep a list of your child’s allergies or medical requirements within the classroom or staffroom in case of emergency. It is necessary for the school to have a list readily available to our staff so that we can look after your child promptly in the event of a medical emergency; and
- rely on software applications and other technology to process medical information (such as allergies, accidents, and injuries) about you and your children. For details about the applications that we use, please contact our Data Privacy Officer, see section 7 below.
3.3. Purpose 3 - Legal Compliance
3.3.1. Maintaining a proper student database as required by the law in the school management information systems and in the national database of Education and Training.
3.3.2. Submitting documents to the relevant Vietnam authorities for relevant approvals or for student that passes for enrollment at the school.
3.3.3. Submitting relevant reports or disclosing personal data about you and your child to the Vietnam authorities as required by the laws from time to time.
3.3.4. Ensuring all relevant legal obligations of the school, parents, students, and staff are complied with.
All other matters relating to your child’s enrollment and education at School or operation of School that we deem necessary or reasonable. We shall notify you of such other matters when they arise.
4) TRANSMISSION OF PERSONAL DATA OUTSIDE VIETNAM
4.1. The data that we process about you and your child may be transferred or stored outside Vietnam. We try to limit this where possible, but it may be necessary where, for example, one of our suppliers has a data center outside Vietnam. We will take all steps reasonably necessary to ensure that your and your child’s data is treated securely and in accordance with this privacy notice and that the appropriate legal safeguards are in place prior to the transfer, for example conducting a personal data impact assessment before sharing data with any supplier, ensuring that any contracts between us and the recipient of the information have standard data protection clauses.
4.2. Similarly, we share your personal data within the Cognita group, which may involve transferring your personal data outside Vietnam. All members of the Cognita group are part of an agreement which uses specific standard contractual terms approved for use in the UK to give the transferred personal data the same protection as it has in the UK.
5) YOUR RIGHTS & RESPONSIBILITIES
5.1. Under PD Regulations, you and your child have the following rights:
5.1.1. Right to know. You have the right to be informed about how, why, and where we process your and your child’s personal data.
5.1.2. Right to view, have a copy of data. You can request to view or request for a copy of personal information held by the school about you and your child.
- For information security purpose, please send your request in writing to the Data Privacy Officer (see section 7), using your email address which has been registered with the school.
- To request for your child’s academic record, please follow the current school’s policies and procedures.
- The school will verify your identity before we can fulfill your request and may charge a fee for such request.
5.1.3. Right to correction. You have the right to ask us to correct any inaccurate personal information we have about you or your child.
5.1.4. Right not to be Subject to Automated Decision Making or Profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the individual or similarly significantly affects the individual.
5.1.5. Right to delete your data: You have the right to request that we delete your and your child’s personal data where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (see paragraph 5.1.7 for more details); (d) the personal data has been unlawfully processed; and (e) we are required to erase the personal data in order to comply with PD Regulations.
5.1.6. Right to restriction: You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (see paragraph 5.1.7 for more details).
5.1.7. Right to object: You have the right to raise an objection to any of our processing in Section 3.1 and 3.2. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.
5.1.8. Right to consent: For the data that we collect, and process based on your explicit consent (example, take and use your child’s photo in the school’s marketing materials), you have the right to give, refuse, or withdraw your consent at any time.
5.1.9. For child protection purpose, the school reserves the right to decline a request to view or make a copy of data, to correct data, or to delete data if the school is satisfied on reasonable grounds that such request could have a negative impact on the child’s health and safety, or if any of the exemptions under the PD Regulations are applicable.
5.1.10. Right to complain: while we hope and would prefer that you approach us first about any complaints or queries that you may have, you always have the right to initiate lawsuits or claim damages according to PD Regulations.
5.2. Under PD Regulations, you are responsible for:
5.2.1. Keeping us informed if any of the collected personal data about you and your child changes during the child’s studying at school. It is important that the information we hold about you and your child is accurate and current.
5.2.2. Respecting and protecting the personal data of others, especially when you want to take a picture or film a video of your child on School premise.
6) HOW LONG WE KEEP YOUR PERSONAL DATA
6.1. We will not keep any personal data about you or your child for any longer than is necessary for the purposes for which the personal data is processed.
6.2. We follow a Personal Data Retention policy which determines how long we keep specific types of personal information for. For details, kindly contact our Data Protection Officer as in section 7 below.
7) CONTACT US
7.1. Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at Data.ComplianceVN@cognita.com
8) CHANGES TO OUR PRIVACY NOTICE
8.1. Any changes we make to this privacy notice in the future will be posted on School website and notified to you by e-mail or any official communication channels employed by School at the time.
8.2. Please check back frequently to see any updates or changes to our privacy notice. Your continued use of our services after such updates will constitute an acknowledgement of the change and agreement to abide and be bound by the updated notice.
8.3. This privacy notice replaces the previous Personal Data Collection Statement, document no. V01.082023.en.
International School Ho Chi Minh City PRIVACY NOTICE FOR EMPLOYEE, CANDIDATE, INTERN, CONTRACTOR, VOLUNTEER
In this Privacy Notice:
- “we”, “us”, “our”, “IEC” is a reference to International Education Corporation (“the Company”), who is operating International Ho Chi Minh City School (ISHCMC) and International Ho Chi Minh City School – American Academy (ISHCMC-AA).
- ISHCMC and ISHCMC-AA are both referred to as “School”.
- “our contract” or “the contract” means the latest signed contract between you and IEC.
Definition:
- Employee: an individual employed by IEC under a lawful employment contract.
- Candidate: an individual applying to a vacant job at IEC.
- Intern: an individual employed by IEC under an internship agreement.
- Contractor: an individual employed by IEC under a service agreement, or an individual hired by a 3rd party to work at IEC (on site or remotely or hybrid), under a service agreement between the 3rd party and IEC.
- Volunteer: an individual performing any job at School without getting paid for it.
1) BACKGROUND
1.1. IEC belongs to Cognita, a UK-based group of independent schools. We comply with all Vietnam’s regulations on Personal Data Protection (“PD Regulations”).
1.2. PD Regulations recognize your rights to your personal data held by the company, as well as the needs of IEC to collect, use, retain, access, transmit and disclose your personal data. This Privacy
2) WHAT PERSONAL DATA WE COLLECT
We may request and collect data about you when you: (a) use, visit, or interact with School website; (b) apply for a vacant position at the Company (c) correspond with us during the recruitment process (d) sign the contract with us or provide information as requested by us from time to time.
2.1. Personal data of candidate:
2.1.1. Data that we collect from you where appropriate:
a) Full name, date of birth, gender, nationality, photograph (headshot).
b) Contact details (including home address, email address, and phone number).
c) Salary and benefits of your most recent job.
d) Employment history (including job titles, qualifications, work history, working hours).
e) Civil litigation, criminal history, global sanction and watchlist.
f) Your online activities as part of the background check process (example includes your activities in social media platforms).
g) Credit check (for senior level).
h) Passport details, other information relating to immigration status.
i) Educational records and achievements, training records. The company will conduct an education verification for academic staff.
j) Information about your physical or mental health (including any compulsory vaccination status as required by Vietnam laws from time to time), or disability status.
k) Information of referee contact details (line managers/HR/HOS at previous schools/companies, and other information included in a CV or cover letter.
l) Performance information at your previous jobs.
m) Disciplinary and grievance information at your previous jobs.
2.1.2. Data about your activities on School websites: see the Cookie Policy on the School website.
2.1.3. Data generated when you attend an interview:
a) Interviewing notes.
b) CCTV footage when you arrive at the company to attend the interview in person.
c) Your voice and image might be captured in the video recording when you attend an online interview. If we need to record the interview, we will ask for your permission in advance.
d) We may use Cognita approved technology to assist us in the interviewing process such as artificial intelligence tools to generate the script of the online interview or to summarize the content of the interview. However, all final recruitment decision is made by human.
2.2. Personal data of employee, intern, contractor, volunteer:
2.2.1. All data that might be collected as specified in 2.1.1.
2.2.2. Data that may be collected when you sign the contract with the company:
a) ID information: National ID card issued by Vietnam’s competent authority (image, number, issuing date), passport (image, number, expiry date), Vietnam’s electronic identification number (VNeID number) of foreigner.
b) Bank account number, tax number issued by Vietnamese competent authority.
c) Dependent information (relationship between you and the dependent, the dependent’s full name, date of birth, ID information).
d) Marital status.
e) Information about your race or ethnic origin if it is shown in your passport.
f) Emergency contact information (name and phone number).
g) Health declaration.
h) Health check-up certificate issued by a recognized medical institution by VN law. This certificate might be requested on a regular basis as part of the process to obtain Work Permit or any other license required by VN laws from time to time.
2.2.3. Data that may be generated while you work at the Company:
a) Health information: results of your annual health check as required by the law (unless consented by you, the Company only receives information about the ranking of your health situation). When you decide to visit the School medical office, we might also have data about your health if you share it with the medical team, data about your visit and/or medication request.
b) Financial information: your salary, benefits, compensation package at the Company, tax refund information, personal income tax information.
c) CCTV footage and other information obtained through electronic means such as swipe card records.
d) Your image and voice captured via class photos or videos, events or daily activities with students, or via online meeting’s recording.
e) Purchase and payment history of any items in the school shops such as canteen, uniform shops, other catering vendors.
f) Information about your use of our information and communications systems.
g) Your testimonials and quotes about the company which may identify you.
2.2.4. Data that we collect and process based on your consent: described in any consent form that we will ask for your explicit consent when we collect your data (if any).
2.3. Sensitive data
Health information (excluding information about blood type), data about criminal convictions/ offences, data about your race and ethnic origin, the image of your ID card/ citizen ID card/ people identification card, financial information including the history of any payment to items sold at the school shops (canteen vendor, caterer vendor, uniform shop) are categorized as sensitive data under PD Regulations and Cognita Personal Data Protection Policy.
Health information (excluding information about blood type), data about criminal convictions/ offences, data about your race and ethnic origin, the image of your ID card/ citizen ID card/ people identification card, financial information including the history of any payment to items sold at the school shops (canteen vendor, caterer vendor, uniform shop) are categorized as sensitive data under PD Regulations and Cognita Personal Data Protection Policy.
3) WHY WE COLLECT YOUR DATA, WHAT WE DO WITH THEM
IEC collects and processes personal data about you for the following main purposes: (1) to enter into and perform the contract, (2) to ensure security and promote the school community welfare, and (3) to comply with relevant legal requirements.
3.1. Purpose 1 – To enter into and to perform the contract
3.1.1. To contact you and your reference during the recruitment process.
3.1.2. To make a decision about your recruitment or appointment.
3.1.3. To determine the terms on which you work with us.
3.1.4. To check if you are legally entitled to work in Vietnam.
3.1.5. To verify your educational background and ensure the role that you are or will be assigned at the Company is suitable for you and the possibility for Work permit application.
3.1.6. To ascertain your fitness to work and to provide appropriate adjustments.
3.1.7. To ensure that you can do the work as required in our contract.
3.1.8. To monitor your utilization of the company asset (including but not limited to tangible and intangible assets, company email, company-subscribed applications, company network, …).
3.1.9. To pay salary, and/or provide you with the benefits as set out in the labor contract or elsewhere.
3.1.10. To make decisions about salary reviews and compensations.
3.1.11. To manage performance related issues (reviews, determining performance requirements).
3.1.12. To gather evidence for possible grievance or disciplinary hearings.
3.1.13. To make decisions about your continued employment or engagement.
3.1.14. To make arrangements for the termination of our contract.
3.1.15. To assess your education, training and development requirements.
3.1.16. To deal with legal disputes involving you, including accidents at work.
3.1.17. To manage your presence at work, your leave and your sickness absence.
3.1.18. To prevent fraud.
3.1.19. To send out surveys to you by email as part of our Voice of the Employee campaign which is our employee survey tool.
3.1.20. To monitor any transaction when you make purchase at any of the school shops (canteen vendor, food vendor, uniform shop, …).
3.1.21. To ensure compliance with all Cognita’s policies and other terms and conditions of the contract.
3.2. Purpose 2 – To ensure security and promote the school community well-being
3.2.1. To keep our sites safe (for example through the use of CCTV).
3.2.2. To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
3.2.3. To send you invites to wellbeing initiatives and to include you in wellbeing activities.
3.2.4. To update parents about their child’s learning, we share with parents’ photos, videos of students during their learning time (which might include your image and voice) via various platforms employed by school. We will obtain your explicit consent before using these images for marketing purpose.
3.2.5. Data Processors: To achieve the purposes described in 3.1 and 3.2, we rely on software applications and other technology to process your personal data. These include management information system, productivity software, collaborative software, virtual learning platforms, any other Software as a Service application that enables the performance of our contract, or that provides you with a service (library application, food purchase and payment application, …). Additionally, we liaise with third parties such external lawyers, insurance broker, social insurance authority, tax authority to seek legal advice, or to process any benefit claim (insurance, tax refund, social insurance benefit, …). We might also employ and share your data with third parties for the purpose of organizing training, workshop, or development programs for you. For details about data processors, kindly contact our Data Protection Officer as in section 7 below.
3.2.6. Intra-group data sharing: we share your data with other members of the Cognita group of companies for the purpose of processing your requirement for internal transfer or improving effective human resources management.
3.3. Purpose 3 - Legal Compliance
3.3.1. To pay personal income tax and all mandatory contributions as required by law.
3.3.2. To keep proper records as required by laws, including but not limited to employee database, accounting record of payment, tax record, evidence of fair recruitment processes.
3.3.3. To file reports to state competent authorities as required by laws.
3.3.4. To comply with information requests from State competent authorities from time to time.
3.3.5. To ensure compliance with all relevant legal obligations.
3.3.6. All other matters relating to your employment at the company that IEC deems necessary or reasonable. The company shall notify you of such other matters when they arise.
4) TRANSMISSION OF PERSONAL DATA OUTSIDE VIETNAM
4.1. The data about you that we process may be transferred to, and stored at, a destination outside Vietnam. We try to limit this where possible, but it may be necessary where, for example, one of our suppliers has a data center outside Vietnam. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice and that the appropriate legal safeguards are in place prior to the transfer, for example conducting a personal data impact assessment before sharing data with any supplier, ensuring that any contracts between us and the data processor have standard data protection clauses.
4.2. Similarly, we share your personal data within the Cognita group, which may involve transferring your personal data outside of Vietnam. All members of the Cognita group are part of an agreement which uses specific standard contractual terms approved for use in the UK to give the transferred personal data the same protection as it has in the UK.
5) YOUR RIGHTS & RESPONSIBILITIES
5.1. Under PD Regulations, you have the following rights:
5.1.1. Right to know. You have the right to be informed about how, why, and where we process your personal data.
5.1.2. Right to view, have a copy of data. You can request to view or request for a copy of personal information held by the company about you.
- For information security purpose, please send your request in writing to HumanResources@ishcmc.edu.vn.
- The company will verify your identity before we can fulfil your request and may charge a fee for such request.
5.1.3. Right to correction. You have the right to ask us to correct any inaccurate personal information we have about you.
5.1.4. Right not to be Subject to Automated Decision Making or Profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the individual.
5.1.5. Right to delete your data. You have the right to request that we delete your personal data where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (see paragraph 5.1.7 for more details); (d) the personal data has been unlawfully processed; and (e) we are required to erase the personal data in order to comply with PD Regulations.
5.1.6. Right to restriction: You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in certain circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (see paragraph 5.1.7 for more details).
5.1.7. Right to object: You have the right to raise an objection to any of our processing in Section 3.1 and 3.2. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.
5.1.8. Right to consent: For the data that we collect, and process based on your explicit consent (example, take and use your photo in the school’s marketing materials), you have the right to give, refuse, or withdraw your consent at any time.
5.1.9. For child protection purpose, the school reserves the right to decline a request to view or make a copy of data, to correct data, or to delete data if the school is satisfied on reasonable grounds that such request could have a negative impact on the child’s health and safety, or if any of the exemptions under the PD Regulations are applicable.
5.1.10. Right to complain: while we hope and would prefer that you approach us first about any complaints or queries that you may have, you always have the right to initiate lawsuits or claim damages according to PD Regulations.
5.2 Under PD Regulations, you are responsible for:
5.2.1. Keeping us informed timely if any of the collected personal information about you changes while you work at the company. It is important that the information we hold about you is accurate and current.
5.2.2. Respecting and protecting the personal data of others.
Note 5.2.2: By sharing with us the information about your references, your emergency contact, your dependent, you ensure that you have obtained an appropriate consent from those individuals before disclosing their personal data to the Company.
6) HOW LONG WE KEEP YOUR PERSONAL DATA
6.1. We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data is processed.
6.2. We follow a Personal Data Retention policy which determines how long we keep specific types of personal information for. For details, kindly contact our Data Protection Officer as in section 7 below.
7) CONTACT US
7.1. Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at Data.ComplianceVN@cognita.com.
8) CHANGES TO OUR PRIVACY NOTICE
8.1. Any changes we make to the Privacy Notice in the future will be posted on School website and notified to you via e-mail or any other official communication channel employed at the time.
8.2. This document also replaces the previous Personal Data Collection Consent Statement. Your continued employment at the Company after receiving this notice, or any updates thereof will constitute an acknowledgement of the change and agreement to abide and be bound by the most updated Privacy Notice.
International School Ho Chi Minh City GENERAL PRIVACY NOTICE
1. Introduction
1.1 We are committed to protecting and respecting your privacy. International School Ho Chi Minh City is an independent school which is part of the Cognita global schools' group. In this privacy notice, references to "we", "us", "our" is a reference to International Education Corporation, the owner of International School Ho Chi Minh City (“ISHCMC”) and International School Ho Chi Minh City – American Academy (ISHCMC AA).
1.2 This privacy notice deals with any personal data we process which is not covered in our parent and pupil privacy notices. It sets out the basis on which any personal data we collect from you is handled by us in the course of our relationship with you. For example, this notice applies to you if you are a potential recruit, next of kin, supplier, or potential supplier, alumni, or prospective pupil or parent of a prospective pupil.
1.3 For prospective parents and pupils, please also see our parent and pupil privacy notices. These are also available on our website.
1.4 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.5 For purposes of Vietnam's Personal Data Protection Law (Law 91/2025/QH15) ("PDPL") and its implementing Decree 356/2025/ND-CP, we are deemed to be an organization to which the PDPL applies.
1.6 If you are reading this privacy notice online, we recommend that you print and retain a copy for future reference.
2. Information We Collect About You
Information you give us
2.1 You may give us personal data about you, in a number of ways; these include:
2.1.1 using, visiting or interacting with our website (such as filling out forms or registering on our website);
2.1.2 visiting our offices or schools;
2.1.3 during an interview or meeting;
2.1.4 corresponding with us by phone, e-mail or post;
2.1.5 sending information directly to us, or providing information as requested by us and/or which is necessary from time to time (for example providing your job application form, CV or business card).
2.2 The information you give us may include the following information about you:
2.2.1 full name;
2.2.2 photograph;
2.2.3 marital status;
2.2.4 national registration identity card number;
2.2.5 salary;
2.2.6 employment history;
2.2.7 contact details (including home address, e-mail address, and mobile, home and/or work phone number);
2.2.8 financial information (for example payee details);
2.2.9 passport details, nationality and other information relating to immigration status;
2.2.10 previous educational records and achievements;
2.2.11 information received via safeguarding forms when visiting a site;
2.2.12 information about your physical or mental health, or disability status, to ensure your health and safety at our sites and to assess your fitness to work and to provide appropriate adjustments;
2.2.13 information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting;
2.2.14 references (as an applicant or potential supplier).
Technical information we collect about you when you visit our website
2.3 With regard to each of your visits to our website we may automatically collect the following information:
2.3.1 technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
2.3.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our number.
2.4 Our website may contain links to and from the websites of our partner networks, advertisers, suppliers and affiliates. If you follow a link to any of these websites, please note that these websites are not covered by this notice and may have their own privacy notices. We do not accept any responsibility or liability for these notices.
Information we receive from other sources
2.5 We may be working closely with third parties (including, for example, recruitment agents, previous employers, medical practitioners, education authorities, business partners, payment and delivery services) and may receive information about you from them.
2.6 We may also use CCTV footage of the school's premises (which may include footage of individuals on the school's grounds) to ensure our sites are safe.
3. Cookies
3.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy which is made available on our website.
4. Contact Us / Third-Party Software Platforms
4.1 Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at DPO@Cognita.com or International School Ho Chi Minh City, addressed at 28 Vo Truong Toan, An Phu, District 2, Ho Chi Minh City, Vietnam.
4.2 We use third party software platforms including, but not limited to, Teams, Seesaw, Tapestry and Google Classroom, to facilitate our VLP; please also read the privacy notices, and applicable terms and conditions, provided by any such third parties.
5. Uses Made of the Information
Information you give to us
5.1 We will use the information you give to us to pursue the following legitimate interests (as applicable to our relationship with you):
5.1.1 promote the objects and interest of our schools, ensure the most efficient management of the schools and ensure that the schools' legal obligations are adhered to;
5.1.2 to store this information on our management information system/s;
5.1.3 to enforce our terms of use with you or any other contract we may have with you;
5.1.4 for the purposes of recruitment;
5.1.5 to enable us to receive your services;
5.1.6 where you have attended one of our schools, to keep you up to date with key school news and upcoming events;
5.1.7 for business improvement purposes.
5.2 In order to pursue the legitimate interests referred to in paragraphs 5.1.1 and 5.1.6, we rely on software applications and other technology to process personal data about you. These include the school's management information system and our HR and finance systems. The third parties we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your information is kept secure. For further information on the kind of technology we use, please contact our Data Protection Officer (see paragraph 4).
5.3 We will also use the information you give to us as is necessary to carry out our obligations arising from the contract (or potential contract) between you and us and to provide you with the information and services that you request from us or receive the services we request from you. For example, we may be recruiting you for a role at Cognita or engaging you to supply us with services and will use personal data where necessary to recruit you or receive your services.
5.4 In addition, we may be required by law to do the following (which is not an exhaustive list):
5.4.1 keep an accounting record of payment;
5.4.2 keep records as may be prescribed by our administration and governance arrangements;
5.4.3 keep a record to evidence fair recruitment processes.
5.5 Inevitably, there will be an overlap between what we do that is necessary to (a) perform our contract with you, (b) carry out our legal obligations and (c) pursue a legitimate interest although we have tried our best to demarcate these as set out above. If you have any questions about these please contact our Data Protection Officer (see paragraph 4).
Information we collect about you from our website
5.6 We will use this information for the following legitimate interests:
5.6.1 to contact you if you have made an enquiry to one of our schools via our online enquiry form and/or to inform you about available places in the future;
5.6.2 to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
5.6.3 to improve our website to ensure that content is presented in the most effective manner, and your online experience is as effective and appropriate as possible, for you and for your computer;
5.6.4 as part of our efforts to keep our website safe and secure.
Information we receive from other sources
5.7 We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for one of the purposes set out above (depending on the types of information we receive). For example, we may receive a reference from a previous employer relating to you, which may impact a recruitment decision.
When we disclose information
5.8 In order to pursue one of the legitimate interests set out above, we may share your personal information with:
5.8.1 Asia Regional Head Office;
5.8.2 A member of the Cognita group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
5.8.3 local authorities, education authorities (for example, the Department of Education and Training, and the Ministry of Education and Training), Labour-Invalids-Social Affairs authorities or the police where we have reason to believe there are safeguarding concerns in respect of a child;
5.8.4 business partners, professional advisors, suppliers and sub-contractors for the performance of any contract we enter into with them or you, provided that those apply privacy standards equivalent to the level of protection hereunder.
5.9 We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce our contract (between us and you) and other agreements.
Where we need to get your consent
5.10 We will not market services to you or use your personal information for sending advertisements, product/service introductions and other commercial information (other than in accordance with paragraph 5.1.6 above) and not share, disclose or transfer your personal information to third parties without seeking of your prior consent and you have the right to choose to either permit or not permit our use of your personal information in such cases. With your consent, your contact details will be shared with third-party advertising partners at the point of form submission only, for advertising measurement and performance optimisation. Where shared, your contact details are transmitted in a non-readable format. This information is used solely to measure the effectiveness of our advertising and will not be used to send you marketing communications or to target you with advertising. You can withdraw your consent at any time by contacting DPO@Cognita.com.
5.11 We may let you know the intended purpose for the collection, use or disclosure of your and/or your child's personal data and a reasonable opportunity to opt-out of said collection, use or disclosure.
6. Transmission of Personal Information Outside Vietnam
6.1 The data that we process about you may be transferred to, and stored at, a destination outside Vietnam. We try to limit this where possible, but it may be necessary where, for example, one of our suppliers has a data center outside Vietnam. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
6.2 With your consent, your contact details will be shared with third-party advertising partners at the point of form submission only, for advertising measurement and performance optimisation. Where shared, your contact details are transmitted in a non-readable format. This information is used solely to measure the effectiveness of our advertising and will not be used to send you marketing communications or to target you with advertising. These partners currently include:
- Google LLC (United States / Singapore) - for analytics, advertising measurement, and attribution data processing.
- Meta Platforms, Inc. (United States / Ireland) - for advertising measurement services.
6.3 In accordance with Vietnam's Personal Data Protection Law (Law 91/2025/QH15, Article 20) and Decree 356/2025/ND-CP, these cross-border transfers are conducted under appropriate safeguards. Data transferred internationally is:
- Limited to what is necessary for the stated purpose (advertising measurement)
- Shared in a non-readable format (for contact details such as email addresses and phone numbers)
- Subject to the recipient's data protection commitments and privacy policies
- Only transferred after you have granted the relevant consent via the marketing consent on our enquiry forms
6.4 You may request information about the safeguards applied to cross-border transfers of your personal data by contacting our Data Protection Officer (see paragraph 4).
7. Your Rights
7.1 Under Vietnam's Personal Data Protection Law, you have the following rights:
7.1.1 Right to correction and deletion. You have the right to have inaccurate personal data about you rectified and deleted.
7.1.2 Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 7.1.4 for more details).
7.1.3 Right to request transfer. In certain circumstances, you have the right to receive personal data from us in a structured, commonly used and machine-readable format and the right to transmit it to a third party organization.
7.1.4 Right to object. You have the right to raise an objection to any of our processing in paragraphs 5.1 and 5.2. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.
7.1.5 Right to object to marketing or disclosure to third parties. If you do not want us to process your personal data for the purposes as mentioned in paragraph 5.10, please tell us and we will ensure that we no longer do this.
7.1.6 Right to request access and check. You have the right to access and check personal data we hold about you.
7.1.7 To exercise any of your rights above, please contact us via our Data Protection Officer or the address in paragraph 4 above.
7.2 For enquiries from students under 15 years of age, parental or legal guardian consent is required before any personal data is collected or processed through our website.
8. How Long We Keep Personal Information
8.1 We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data are processed.
8.2 We follow a data retention policy which determines how long we keep specific types of personal information for. For further information about the criteria we use to determine what periods we keep specific information, please contact our Data Protection Officer (see paragraph 4).
9. Use of Our Website
9.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
10. Changes to Our Privacy Notice
10.1 Any changes we make to this privacy notice in the future will be posted on our website and, where possible and appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
International School Ho Chi Minh City COOKIE POLICY
1. WHAT IS A COOKIE?
1.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer's hard drive. To find out more about cookies, visit www.aboutcookies.org.
2. ABOUT OUR USE OF COOKIES
2.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.
When you first visit our website, you will be asked to consent to our use of cookies via our cookie consent tool. Only strictly necessary cookies will be placed without your consent. All other cookies - including analytics, preference, and marketing cookies - require your explicit opt-in consent before they are activated. You can change your cookie preferences at any time using the cookie consent links below.
2.2 When you visit our website, we may automatically collect the following information:
2.2.1 technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
2.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our number.
3. COOKIES WE USE AND WHY
3.1 Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
3.2 Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
3.3 Google Advertising cookies. Google Analytics' Display Advertiser features are enabled for the Google Analytics property this website is tagged with. This means that Google Analytics will drop additional cookies on your browser and collect data using Google's advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation. For more information about Google's Advertising Cookies and how you can control advertising cookies visit Google Advertising Privacy FAQ and Google's advertising cookies.
3.4 Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences.
3.5 Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising around the web more relevant to you. We may also share this information with third parties for this purpose.
3.6 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
4. WE HAVE NO CONTROL OVER THIRD PARTY COOKIES
4.1 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
4.2 Our website may also contain links to and from the websites of our partner networks, advertisers, suppliers and affiliates. If you follow a link to any of these websites, please note that these websites have their own cookie notices and privacy notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal data to these websites.
5. HOW DO I CHANGE MY COOKIE SETTINGS?
5.1 Generally, browsers allow some control of most cookies through the browser settings. To find information relating to the browser you are using, please visit the browser developer's website, below are links to some of the most common browsers:
6. WHAT HAPPENS IF YOU BLOCK COOKIES?
6.1 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site and your user experience may be seriously downgraded whilst browsing the site.
7. EXPIRY OF COOKIES
7.1 When we send a cookie, we instruct your browser to keep that cookie for a certain period of time, for example, we may instruct your browser to keep the cookie for the period you are on the website; this is known as a “session cookie”. You can override the cookie expiration periods set by us, or any other website, by changing your cookie settings. If you do not change your settings, then, all cookies set by us will expire after 6 months.
You can view the specific expiration period for each cookie in our cookie consent table.
Default expiration settings will vary for third-party cookies; you can find out more about these by following the links in section 3.5.
8. CONTACT US
8.1 If you have any questions regarding this Cookie Notice please contact servicedesk@cognita.co.uk.
These notices were last updated on October 2026.