Privacy Policy

1. Who we are

Silva, Sadler & Vickers Lda, Sítio do Ferrel, Espiche, 8600-110 luz, Lagos, tax number 501219307, operating as Barlavento International School, is the controller of the personal data described in this policy.

We process personal data in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation, and with Law 58/2019 of 8 August, which gives effect to it in Portugal.

The person responsible for data protection at the school is Sílvia de Oliveira Catarino, Director. Write to privacy@barlaventointernationalschool.pt with any question about this policy or to exercise the rights in section 14.

2. The principles we apply

We process personal data lawfully, fairly and transparently. We collect it for stated purposes and do not use it for anything incompatible with those purposes. We collect only what we need. We keep it accurate and correct it when it is not. We keep it only for as long as we need it. We protect it, and we are accountable for doing so.

3. Who this covers

Students and former students. Parents and guardians, and the emergency contacts they nominate. Applicants for a place and their families. Staff, candidates, interns and volunteers. Suppliers and their staff. Visitors to the school and to our website.

4. What we collect

Identification and contact details, date of birth, nationality and languages spoken, home address, previous schooling, academic records, attendance and behaviour records, medical and dietary information, learning support needs, emergency contacts, images and recordings, and correspondence with the school.

For staff, candidates, interns and volunteers we also hold qualifications and employment history, contractual and payroll data, and, where the law requires it for work involving contact with children, a criminal record certificate.

5. Where the data comes from

Most of it comes from you, or from the parent or guardian who enrols a student. We also receive data from previous schools, from health professionals where this is necessary to care for a student, and from public authorities where the law requires it.

If you give us information about another person, including an emergency contact or a second parent or guardian, please make sure that person knows. We will provide them with a copy of this policy when we first contact them, or on request.

6. Why do we use it, and on what basis

Purpose	Legal basis
Admissions and enrolment	Steps prior to entering a contract, Art. 6(1)(b)
Teaching, assessment and student records	Performance of the contract and legal obligation, Art. 6(1)(b) and (c)
Health, safety and safeguarding	Legal obligation and vital interests, Art. 6(1)(c) and (d); Art. 9(2)(c) and (g)
Communication with families, school life and events	Performance of the contract and legitimate interests, Art. 6(1)(b) and (f). You may object at any time
Images used within the school community	Legitimate interests, Art. 6(1)(f). You may object at any time
Images and video used publicly	Consent, Art. 6(1)(a), and consent under Art. 79 of the Portuguese Civil Code
Fees, accounting, employment and administration	Performance of the contract and legal obligation
Security of the school premises	Legitimate interests, Art. 6(1)(f)
Complaints, claims and legal proceedings	Legitimate interests, Art. 6(1)(f); Art. 9(2)(f)
Website analytics	Consent, Art. 6(1)(a)

7. Sensitive information

Educating and caring for children requires us to hold information about health, allergies, dietary needs, learning support and safeguarding. It is available only to the staff who need it in order to keep a student safe and supported, and it is not shared outside the school except where the law requires it, where it is necessary to protect someone's life or safety, or with explicit consent.

Where a concern about a child's safety has to be reported to the authorities, we may not be able to tell the family beforehand, if doing so would place the child at risk.

8. Photographs and videos

In materials available only to the school community, such as the yearbook, internal newsletters and password-protected areas, students may be identified by name. You may object to this at any time.

For the website, social media, press and promotional materials, we use images of students only where written consent is held on file, and we do not name a student without separate agreement. Consent is asked for separately from enrolment, refusing has no consequence for a student's place or for the services we provide, and it may be withdrawn at any time. Anyone may ask for content connected to them to be removed, and we will act on that request. We will remove material under our control, although we cannot recall what has already been printed or shared by others.

The school is not responsible for what members of its community publish on their own websites, social media or messaging groups, including images taken at school events.

9. Video surveillance

We use cameras covering the exterior of the school premises, for the safety of the people on site and the security of the building.

Access to the recordings is restricted to the people authorised by the school, and they are not viewed except where there is a specific reason to do so, such as an incident or a security concern. Recordings are kept only for as long as is necessary for that purpose.

You may ask for access to images of yourself, and parents may ask for images of their children, by writing to privacy@barlaventointernationalschool.pt. Where a recording also shows other people, we will provide it in a way that protects their privacy.

10. Who do we share it with

Public authorities, where the law or a child's welfare requires it, in particular the Ministry of Education and DGEstE, the tax authority, social security, the Commission for the Protection of Children and Young People, the courts and the security forces. Health professionals and emergency services. Other schools, where a student transfers or continues their education elsewhere. Providers of school transport, catering, trips and insurance. Professional advisers, including lawyers, accountants and auditors.

We do not give a family's contact details to other families. Where contact details are shared to organise activities outside school hours, that happens only with consent.

11. Organisations that process data for us

The main organisations processing personal data on our behalf are, Google Ireland Limited (cloud, email and productivity), (school management system) and Descomunal, Lda. (communication and admissions systems). A full and current list is available on request at privacy@barlaventointernationalschool.pt.

We require every organisation that processes personal data on our behalf to work under a written contract meeting Article 28 of the GDPR, to process the data only on our documented instructions, not to use it for its own purposes, and to notify us of any personal data breach without undue delay.

We only use providers established outside the European Economic Area, or storing data outside it, where the transfer takes place under an adequacy decision of the European Commission or under the standard contractual clauses it has approved.

12. How long do we keep it

Record	Period
Enrolment and academic results, as needed to issue certificates and confirm a student's education	Kept for as long as the school operates, so that former students can obtain certificates at any time and, if the school ceases to operate, transferred to the competent education authority
Other student records, including reports, correspondence and day to day notes	Duration of enrolment and 5 years after leaving
Applications that do not result in enrolment	12 months from the decision
Medical, dietary and support information	Duration of enrolment
Images used with consent	Until consent is withdrawn, and in any case no longer than 5 years
Images kept in the school's historical archive, including yearbooks	Kept as part of the school's record of its own history
Staff files	Duration of employment and and 5 years after, or longer where the law requires
Accounting and tax records	10 years
Website and analytics data	3 years
Video surveillance recordings	Kept only for as long as necessary for the purpose, and no longer than the period allowed by law

13. How we protect it

Access to personal data is limited to the people who need it for their work, and those permissions are reviewed. Accounts with access to personal data require two-factor authentication. Files are shared only with named people, never through open links. Connections to our website and school systems are encrypted. Paper records containing personal data are kept in restricted storage and access to them is controlled. Everyone working at the school is bound by confidentiality and is required to complete data protection training. These measures are reviewed periodically and after any incident.

14. Personal data breaches

A personal data breach is any incident leading to accidental or unlawful destruction, loss, alteration, or unauthorised disclosure of or access to personal data.

When one occurs, we contain it, establish what happened and what data is involved, record it in an internal register and assess the risk to the people affected. Where the breach is likely to result in a risk to people's rights and freedoms, we notify the Comissão Nacional de Proteção de Dados within 72 hours of becoming aware of it. Where it is likely to result in a high risk, we also inform the people affected directly and without undue delay. Every breach is recorded, whether or not it is notified.

15. Your rights, and how to opt out

You may ask for access to your data, its correction or erasure, restriction of or objection to its use, and a portable copy. You may withdraw any consent you have given, at any time, without affecting the lawfulness of what we did before you withdrew it.

Where we rely on our legitimate interests, you have the right to object at any time, and we will stop unless we have compelling grounds that override your interests. This applies to school news and events, and to the internal use of images.

You can opt out of optional communications at any time, by using the unsubscribe option where one is provided or by writing to us, and we act on the request immediately. Opting out of optional communication does not affect the messages we must send you about your child's education.

Write to privacy@barlaventointernationalschool.pt. We answer as quickly as we can and in any case within one month of receiving the request. If a request is particularly complex, or if we receive several at once, we may extend that period by up to two further months and will tell you, and explain why, within the first month.

Students hold these rights over their own data, exercised by the student, by the holder of parental responsibility, or by both, depending on age and maturity. Where consent is needed for an online service, in Portugal a child may give it from the age of 13; below that age it is given by the holder of parental responsibility. For everything else we do with a student's data, consent is given by the holder of parental responsibility, taking the student's own view into account as they grow older.

Some rights are limited where we are required by law to keep data, or where we need it to educate and safeguard a student. Where we refuse a request, we explain why.

15. Automated decisions

We do not take decisions about students, applicants or staff based solely on automated processing. Where a system we use produces an alert or an indicator, a member of staff reviews it before any decision is taken.

16. Complaints

Please contact us first at privacy@barlaventointernationalschool.pt. You may also complain at any time, and without needing our agreement, to the Comissão Nacional de Proteção de Dados, Av. D. Carlos I, n.º 134, 1.º, 1200-651 Lisboa, geral@cnpd.pt, +351 213 928 400.

17. Cookies

A cookie is a small text file placed on your device when you visit a website.

Strictly necessary cookies allow the site to work and to deliver what you have asked for. They do not require consent. Functionality cookies remember your preferences. Analytics cookies tell us how the site is used so that we can improve it. Both are placed only after you have given consent through the panel shown on your first visit.

You may accept, refuse, or choose by category. Refusing is as easy as accepting, and you can change or withdraw your choice at any time by clicking the widget at the bottom left of the homepage. Refusing does not prevent you from using the site, although some features may not work.

A list of the cookies we use, with the purpose, provider and duration of each, is available at said widget. We use Google Analytics to measure traffic.

18. Changes to this policy

We review this policy at least once a year and whenever we materially change how we use personal data. Each version is numbered and dated, and previous versions are kept on file. Where a change is material, we will tell families and staff in advance through the usual channels.

Version 2.0. Approved on 09/10/2026. Next review: 09/10/2028.