This document explains how The Frederick Gunn School collects and handles information it gathers from candidate families, students, alumni and others who interact with FGS or its website. While we are committed to protecting the privacy of the entire Gunnery community regardless of where they find themselves, this document will also explain our GDPR (European Union General Data Protection Regulation) compliance for those individuals in Europe who may be covered by GDPR. We recognize that GDPR is a new regulation and there are many questions about if and how it may be enforced outside of the EU. By doing our best to comply, we do not mean to state that FGS is submitting to the jurisdiction of judicial or regulatory authorities outside of the United States, and we reserve all of the legal rights that are available to us here.
FGS is committed to protecting the privacy and information of our constituents. We try to collect the minimum amount of information necessary - whether for the admission’s process, matriculation and being a current student, or for our alumni office to keep you connected to FGS after graduation.
This document is addressed to the parents/guardians of candidates and students as well as alumni. It is expected that information shared with FGS during the admissions process or during a student’s enrollment is given with the consent of a parent or guardian.
When you apply to a school, you are putting a lot of trust in that school. FGS wishes to be clear and up-front about the type of data we collect, how it is stored and used, and what if any your rights and options you may have under the GDPR, with respect to your personal data.
Please note, this page may be updated at any time to reflect policy and legal changes.
What Personal Data We Collect; How and When We Collect It
There are 3 main phases of a person’s interaction with FGS: during the admissions process, during matriculation (and throughout a student’s enrollment at FGS), and as alumni.
During the admissions phase, personal data will be collected and stored about the candidate and family for the purposes of evaluating the candidate and properly placing them if accepted. Additionally, The Gunnery will use the information for communicating with the family during the admissions process.
Types of data collected: Biographical information (including name, address, phone number, email, (this information is also gathered about the parents/guardians) as well as gender, date of birth, citizenship, etc.). Further, we collect information about academic, athletic, and extra-curricular records and interests (including responses to prompts), and possibly financial information (to process financial aid requests). This data will be collected via our website (the Inquiry form) as well as our application (done via SAO – the Common Application). Additional information may be collected by the admissions office via various interviews, calls and emails.
FGS, as part of the admissions process, may gather or receive information from other sources such as testing (including, medical/educational, standardized tests, etc.). The types of data we collect in these cases may be specific to the individual. We receive and process such data pursuant to your agreements with such third-party service providers, and in furtherance of your agreements with us concerning your candidacy and matriculation and pursuant to our legitimate interests in assessing your application. For information on the privacy practices of such third parties, please consult your agreements with them and their own privacy policies.
FGS staff who receive and process this personal data may include: Admissions office, Head’s office, alumni office, business office, academic office, Dean of Students office, the Center for Academic support, Health Services, and the Admissions Committee (which consists of Admissions officers, faculty and administrators who review applications).
This data collection is required if one wants to apply to or be enrolled at FGS. Without this data, FGS cannot process a student’s application or enroll them. To the extent that any requested personal data is not necessary for the performance of FGS agreements and policies, such requests will be separately identified and the appropriate consent obtained.
Applicant data is kept permanently.
Matriculation (these will be embedded in the contract):
Once enrolled, FGS continues to collect and process personal data for the purposes of caring for and educating the student. Further, students and families will be communicated with regularly so they are aware of what is happening on campus. In the event of an emergency, families will also be contacted.
During the enrolled phase, personal data will be collected, created and stored (about the student and family) for the purposes of tracking student progress at FGS. Additionally, FGS will use the information for communicating with the family.
Type of data collected: name, address, phone number, email, (this information is also gathered about the parents/guardians) as well as gender and date of birth. Further, we collect information about academic, athletic, and extra-curricular records and interests, and possibly financial information. Information about performance (classes, co-curricular activities, etc.) is also collected and maintained.
FGS may get information from other sources such as various types of testing (for example, medical, aptitude, standardized tests, etc.). The types of data we collect in these cases may be specific to the individual.
FGS may gather or receive information from other sources such as testing (including, medical/educational, standardized tests, etc.). The types of data we collect in these cases may be specific to the individual. We receive and process such data pursuant to your agreements with such third-party service providers, and in furtherance of your agreements with us concerning your matriculation. For information on the privacy practices of such third parties, please consult your agreements with them and their own privacy policies.
Staff of FGS who receive and process this personal data include: alumni office, Head’s office, business office, academic office, Dean of Students office, faculty, and advisors.
This data collection is required if one wants to be enrolled at FGS. To the extent that any requested personal data is not necessary for the performance of FGS agreements and policies, such requests will be separately identified and the appropriate consent obtained.
Student records (transcripts, test scores, rosters, and attendance) are kept permanently.
Alumni and Friends:
FGS is a community, and membership to that community does not end at graduation. FGS, through the alumni office, makes an effort to keep our alumni, friends and parents (past and present) connected to the school. We understand that different people will desire different levels of connections and there are options for how you will be contacted:
The data we collect from constituents is used to allow us to communicate with you for various reasons, including:
Newsletters and bulletins with information on what is happening on campus and with other alumni.
Communicating with you to let you know about receptions, reunions, events or other ‘meet-ups’ with alumni or Gunnery faculty/administrators in the area.
Making you aware of projects and opportunities to support the school (via volunteering, gifts, etc.)
Promoting services we may offer to alumni.
Types of data collected: Biographical information (including name, address, phone number, email, (this information is also gathered about the parents/guardians) as well as gender, date of birth, gifts received, and events attended.
For non-EU residents, we also use a research service which helps us to identify people who might be interested in various projects FGS is engaged in.
FGS staff who receive and process this personal data may include the alumni office, business office, admissions office, communications office, and Head’s office.
In general, we like to keep in contact with our Alumni for life. As such, we do not remove records. Also, due to applicable laws, some types of data (like giving history) cannot be removed.
For any questions regarding the collection or use of Alumni data, please contact firstname.lastname@example.org.
Vendors and your data:
FGS uses cloud-based software for running the school in an efficient manner. Most data, including personal data, is stored in these systems. FGS uses these systems for security, reliability and usability. The data is not sold to these providers, it is owned by FGS and is used only for FGS purposes.
In these cases, the 3rd party is acting as an agent of FGS in furtherance of FGS. Should we want to disclose your data for other reasons not described above (unless required to be disclosed by law or GDPR), we will seek your specific consent to do so.
Please contact BJ Daniels (DanielsB@frederickgunn.org) if you would like to see a list of current vendors.
For Individuals in the European Union
Data Access and Information
As an individual in the EU, you have the right to request confirmation of whether or not FGS is processing personal data about you. If so, you have the right to see or obtain a copy of that data and to learn: for what purpose(s) we are processing that data; the categories of data; the identity of those who receive the data; if we receive personal data about you from other sources, any available information about those sources; and how long we keep the data or, if the period is not determined, the factors that we use to determine that period.
Correction and Completion
You have the right to request correction of personal data that you believe is inaccurate. Where you believe the data is incomplete, you have the right to complete the data, including by supplementing the data with a statement.
Right of Erasure or “To be Forgotten”
You have the right to request that FGS permanently delete your personal data when:
we no longer need your data for the purposes for which it was collected;
we have been processing the particular data based only on your consent, you withdraw your consent, and there is no other legal ground for us to continue processing;
you successfully object to the processing of certain data (see “Objection” below);
the data has been unlawfully processed; or
erasure is required by law.
This right will not apply where continued processing of your data is necessary for:
the exercise of the right of freedom of expression and information;
compliance with applicable law;
performance of a task carried out in the public interest or the exercise of official authority vested in FGS;
for reasons of public health;
certain types of archiving that is in the public interest, scientific or historical research or statistical purposes; or
the establishment, exercise or defense of legal claims.
Although FGS may remove most personal data such as contact information (address, phone number, etc.), we cannot remove certain records about a user’s attendance at FGS and their grades.
Restriction on Processing
You have the right to request that FGS stop or restrict the processing of your personal data where:
you are contesting the accuracy of your personal data, in which case processing could be restricted for the period of time necessary for us to determine the accuracy of the data;
the processing is unlawful and you oppose the erasure of the personal data and request instead that processing be restricted;
we no longer need the personal data for the purposes of the processing in question, but you need the data for the establishment, exercise or defense of legal claims; or
you object to the processing of certain data (see “Objection” below), in which case processing could be restricted for the period of time necessary for us to determine our response to the objection.
If you successfully exercise this right of restriction, we will process the data in question only: where we have your consent to do so; for the establishment, exercise or defense of legal claims; for the protection of the rights of another person; or for reasons of important public interest. In the event that any such restriction is lifted and processing resumes, we will inform you beforehand.
Limited Data Portability
With respect to personal data that we have received directly from you (as opposed to data that we may receive about you from sources other than you), you have a right to request and receive such data in a structured, commonly used and machine-readable format. You also have the right to transmit such data to another entity without interference from us.
Please note that this right of portability applies only in limited circumstances, such as: where we are processing personal data on the basis of your consent or pursuant to our contractual agreements with you, and the processing is carried out by automated means. If you request that we transmit your data directly to another individual or entity, we will comply where it is technically feasible to do so.
You may object to processing of your personal data that is based on FGS determination that such processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, or that such processing is necessary for the purposes of the legitimate interests pursued by FGS.
If we process your personal data for purposes of direct marketing, you may object at any time. Direct communications from FGS that are for marketing, promotional, or solicitation purposes always contain an option for unsubscribing and instructions for how to do so.
How do I exercise these rights?
If you wish to exercise any of the rights described above, please do so by contacting BJ Daniels (DanielsB@frederickgunn.org). We will attend to your request promptly and will respond within a reasonable time. If you are dissatisfied with our handling of your request, we ask that you give us the opportunity to resolve the issue; however, you have a right to lodge a complaint with the supervisory authority where you are located. You may find a directory of supervisory authorities here.