Data Protection Policy
The Japanese School

Approved by:

The School Management Committee

Last reviewed on:June 2023

Next review due by:June 2024

Data Protection Policy 202306 v1.2.1

Date: June 2023

1

Version Number
1.0
1.1
1.2
1.2.1

Modified By
K. Nishihara
K. Okamoto
K. Okamoto
K. Okamoto

Modifications Made
Initial version
Updated
Review and update
Reviewed

Date Modified
17/12/2021
27/04/2022
04/05/2022
01/06/2023

Draft, Revised, Final, etc.

Data Protection Policy 202306 v1.2.1

2

Definitions
School means The Japanese School Limited, a registered School.
GDPR means the General Data Protection Regulation.
Responsible Person means Secretary.
Register of Systems means a register of all systems or contexts in which personal data isprocessed by the School.

1. Data protection principles
The School is committed to processing data in accordance with its responsibilities under theGDPR.
Article 5 of the GDPR requires that personal data shall be:a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in amanner that is incompatible with those purposes; further processing for archiving
purposes in the public interest, scientific or historical research purposes or statistical
purposes shall not be considered to be incompatible with the initial purposes;c. adequate, relevant and limited to what is necessary in relation to the purposes for which
they are processed;
d. accurate and, where necessary, kept up to date;e. every reasonable step must be taken to ensure that personal data that are inaccurate,
having regard to the purposes for which they are processed, are erased or rectified
without delay;
f. kept in a form which permits identification of data subjects for no longer than isnecessary for the purposes for which the personal data are processed;
g. personal data may be stored for longer periods insofar as the personal data will beprocessed solely for archiving purposes in the public interest, scientific or historicalresearch purposes or statistical purposes subject to implementation of the appropriatetechnical and organisational measures required by the GDPR in order to safeguard therights and freedoms of individuals; andh. processed in a manner that ensures appropriate security of the personal data, including
protection against unauthorised or unlawful processing and against accidental loss,
destruction or damage, using appropriate technical or organisational measures.”2. General provisions
a. This policy applies to all personal data processed by the School.
b. The Responsible Person shall take responsibility for the School’s ongoing compliancewith this policy.
c. This policy shall be reviewed at least annually.
d. The School shall register with the Information Commissioner’s Office as an organisationthat processes personal data.

3. Lawful, fair and transparent processinga. To ensure its processing of data is lawful, fair and transparent, the School shall maintain

Data Protection Policy 202306 v1.2.1

3

a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to
the School shall be dealt with in a timely manner.

4. Lawful purposesa. All data processed by the School must be done on one of the following lawful bases:
consent, contract, legal obligation, vital interests, public task or legitimate interests (seeICO guidance for more information).
b. The School shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in
consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for theindividual to revoke their consent should be clearly available and systems should be inplace to ensure such revocation is reflected accurately in the School’s systems.

5. Data minimisationa. The School shall ensure that personal data are adequate, relevant and limited to what isnecessary in relation to the purposes for which they are processed.

6. Accuracy
a. The School shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put inplace to ensure that personal data is kept up to date.

7. Archiving / removala. To ensure that personal data is kept for no longer than necessary, the School shall put inplace an archiving policy for each area in which personal data is processed and review
this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, andwhy.

8. Security
a. The School shall ensure that personal data is stored securely using modern softwarethat is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate
security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data isirrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.

9. BreachIn the event of a breach of security leading to the accidental or unlawful destruction, loss,
alteration, unauthorised disclosure of, or access to, personal data, the School shall promptly
assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO(more information on the ICO website)

Data Protection Policy 202306 v1.2.14