Our Legal Obligations
We are regulated by laws, rules, regulations, and government regulatory authorities. To fulfil our legal and regulatory requirements with these authorities it is necessary to collect, use or disclose your personal data for the following purposes, which include but are not limited to:
1. Compliance with the PDPA and any amendment to the law thereafter;
2. Compliance with laws (e.g. school child safeguarding laws; and other laws to which we are subject both in Thailand and in other countries), including conducting identity verification, criminal background checks, other checks and screenings (including screening against publicly available database of regulatory authorities and / or official sanctions lists), and ongoing monitoring that may be required under any applicable laws;
3. Compliance with regulatory obligations and / or orders of authorised persons (e.g. orders by any court of competent jurisdiction or of governmental, supervisory or regulatory authorities or authorised officers).
Contract made by you with us
We will process personal data with the request and/or agreement made by you with us, for the following purposes, which include but not limited to:
• Process your request prior to entering into an agreement, consider for approval in relation to the provision of our services, and deliver products, including any activities that if we do not proceed, then our operations or our services may be affected or may not be able to provide you with fair and ongoing services.
• Authenticate when entering or executing any transactions.
• Carry out your instructions (e.g. to debit amounts from bank accounts, or respond to your enquiries); provide online training, and other online learning platforms.
• Track or record your transactions.
• Produce transaction reports requested by you or for our internal usage reports.
• Notify you with transaction alerts and notify the due date of the school’s fees and services.
• Proceed with any acts relating to insurance policy or claim for compensation (e.g. proceed with or monitor any claim under your insurance policy, claim against third party).
Our Legitimate Interests
We rely on our legitimate interests by considering our benefits or third party’s benefits with your fundamental rights in personal data in which we will collect, use, or disclose for the following purposes, which include but are not limited to:
• Conduct our school operations (e.g. to audit, to conduct risk management, to monitor, prevent, and investigate misconduct, or other crimes, including but not limited to carrying out the criminal record checks of any persons related to our school).
• Conduct our management relationships (e.g. to serve parents and students, to conduct parent/student surveys, to handle complaints).
• Ensure our standard security services (e.g. to maintain body temperature checks, CCTV footage records, to register, exchange identification cards and/or take photo of visitors before entering our school campus, to monitor network activity logs and security incidents).
• Ensure school provided medical services to students and staff.
• Develop and improve our school communication, services, and systems to enhance our service standards.
• Use your personal data for the greatest benefits in fulfilling your needs, including to conduct research, analyse data and benefits suitable to you by considering the fundamental rights of your personal data.
• Record images and/or voices or videos in relation to meetings, teaching, training, seminars, or marketing activities.
Under the PDPA, the rights belong to the individual to whom the data relates (”Data subject”). However, where consent is required as the lawful basis for processing personal data relating to students, we often rely on parental consent. Unless, given the nature of the process in question, and the student’s age and level of understanding, it is more appropriate to use student consent. Parents / guardians should be aware that in such situations, they may not be consulted, depending on the interests of the child, the parent’s rights at law or under their contract, and considering all the relevant circumstances.
In general, we will assume that student consent is not required (and that other lawful bases are more appropriate, as described above) for ordinary disclosure of their personal data to their parents/ guardians, e.g. for the purposes of keeping parents informed about the student’s activities, progress and behaviour, and in the interest of the student’s welfare, unless in the school’s opinion, there is a good reason to do otherwise.
However, where a student seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, we may be under obligation to maintain confidentiality unless, in our opinion, there is a good reason to do otherwise; for example, where the school believes disclosure will be in the best interests of the student or other students or is required by law.
In certain cases, we may ask for your consent to collect, use or disclose your personal data to maximise your benefits and / or to enable us to provide services to fulfil your needs for the following purposes, which include but is not limited to:
• Collect and use your sensitive personal data as necessary (e.g. to use face recognition or your identification card photo (which contains your sensitive personal data, namely religion and/or blood type) for verification of your identity before continuing a transaction).
• Collect and use your personal data and any other data to conduct research and analyse for the greatest benefits in developing products and services to truly fulfil your needs and/or to contact you for offering products, services, and benefits exclusively suitable to you.
• Send or transfer your personal data overseas, to entities that have adequate personal data protection standards (unless the PDPA specifies that we may proceed without obtaining consent).
• Disclose your personal data and any other data as shown on the school’s website and/or our trusted business partners for the following purposes:
- conducting research and analysing your web application access and other personal data and any other data for the greatest benefits in developing products and services to truly fulfil your needs
- contacting you to offer products, services, and benefits exclusively suitable to our students.
Other Lawful Basis
Apart from the lawful basis mentioned above, we may collect, use, or disclose your personal data based on the following lawful basis:
• Prepare historical documents or archives for the public interest, or for purposes relating to research statistics.
• Prevent or suppress a danger to you or another person’s life, bodily harm, or physical/mental health.
• Necessary to carry out a public task, or for exercising official authority.
• If the personal data we collect from you is required to meet our legal obligations or to enter into an agreement with you, we may not be able to provide (or continue to provide) some or all the school’s products or services to you if you do not provide such personal data when requested.