Privacy Statement
1. Introduction
This “FÍSBookClub.ie” website (the “Site”) is owned and operated by the Institute of Art, Design, and Technology, Dun Laoghaire, Ireland (“IADT”). IADT is committed to protecting the privacy of users of the Site and complying with its obligations under the Irish Data Protection Acts 1988 and 2003 (the “Acts”). We are aware that as a user of this Site you (and your guardians, in the case of use of this Site by minors) careabout the security and privacy of your information. The purpose of this Privacy Statement is to outline how we deal with any personal data you provide to us while visiting this Site. You should not use this Site (or allow children under your control or supervision to use this Site) if you are not happy with this Statement.
FÍSBookClub.ie is an initiative (the “Initiative”) that is designed, created and co-ordinated by IADT. The Initiative encourages school-children to create a video book-review based on their independent reading. The Initiative works primarily through schools, for whom the relevant teachers will access the Site on behalf of their class. By visiting this Site, you are accepting the terms of this Statement. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of those other websites.
If you wish to discuss this Statement with IADT or any other matters relating to our privacy policy generally, please email:info@fis.ieor contact us at the details below:

General Mailing address

FÍS Office Media Cube BStatusSuilding, IADT Campus, Kill Avenue, Dun Laoghaire, Co. Dublin, Ireland. Phone number +353 1 2394990
2. What information do we collect?
We retain two types of information:

(a) “Non-Personal Data” and Cookies

You can browse parts of the Site without telling us who you are or revealing any personal information about yourself. Like most Sites, we gather statistical and other analytical information collected on an aggregate and anonymous basis from all visitors to our Site. This “Non-Personal Data” comprises information that cannot be used to identify or contact you, such as your IP (Internet Protocol) address, domain name, browser type, operating system, and information such as the Site that referred you to us, the files you downloaded, the pages you visit, and the dates/times of those visits, and other anonymous statistical data involving the use of our Site. This Site uses cookies to hold personally identifying information for the purposes outlined in Section 3.

(b) “Personal Data”

“Personal Data” is data that identifies you or can be used to identify or contact you. Personal Data is collected only with your knowledge and permission, and is retained on behalf of IADT in a secure manner. Typically, teachers will register on behalf of their school/class via www.scoilnet.ie, which is a Department of Education and Skills portal for Irish education, providing resources in a digital database covering all subject areas of the primary school curriculum. Scoilnet identifies bonafide teachers via their teaching council id and associated school roll number. Teachers then access www.fisbookclub.ie Site using the log-in details provided to them by Scoilnet. We do not collect any additional personally identifiable information from teachers during our registration process other than what is necessary for such process. We will collect a teacher’s e-mail address for the purpose of sending the teacher email related to membership of the Site only, such as a lost or forgotten password, or occasionally to communicate information to teachers/schools that we reasonably consider may be useful in connection with the Site, such as newsletters or information pertaining to a contest he or she may have entered.

Children are given a pupil log-in by their class teacher. Children can only log in when their teacher turns on ‘Pupil Log In’ and logs in using the pupil log in specific to their class in any given year. We only use Personal Data for the specific purpose indicated at the time you input such information. In addition, we never divulge such information to third parties without your consent.

Amongst some of the specific categories of Personal Data that we may retain for the purpose of the Initiative are the following: (i) Videos: During the upload process, the teacher/child will include Personal Data (childs name and age) in the title, description or content of the video. When a child uploads they will be asked to enter their name and age only. Their name will only be visible to their teacher and the site administrator. The collection of data regarding children’s ages is purely for statistically reporting purposes and no child will be identifiable in the statistical reports. (ii) Emails: To personalise communications to a teacher regarding a specific contest or submitted video(s), we may use the child’s name in conjunction with the teachers email address for the purposes of the teacher tracking the submitted video(s) from his/her class or individual pupils and for the purposes of entering a child for a competition.
3. Purposes for which we hold your information
3.1 Non-Personal Data and Cookies:
Non-Personal Data is used in an aggregate form to analyse trends and usage of the Site and to improve the usefulness of the Site. This Site uses cookies to hold personally identifying information. By communicating with our Site when you sign in, cookies speed up and ease users’ navigation, and saves them from having to retype their username and password each time they access the Site. Cookies allow us to customise the information we provide according to a user’s profile and preferences. Widely used on the Internet, cookies have become an industry standard. Although a cookie cannot, in and of itself, identify a user, it can identify a user’s computer. Your browser is most likely set up to accept cookies automatically. If you would like to disable cookies, you may do so by adjusting the options or preferences in your browser. However, by doing so, you will lose some of the functionality of Site. We use cookies to enable sign-in, membership, and personalisation. We use cookies to keep track of your user session and click-stream data, as well as to tailor content to your interests and/or to personalise our Site.

3.2 Personal Data:
a) Users will be able to voluntarily provide to the Site online book-reviews (or other content), which may include Personal Data, in order to effectively participate in the Initiative. IADT uses this Personal Data only for the specific purpose of promoting the Initiative.

(b) The Initiative is intended to facilitate the sharing of online book-reviews amongst school-children in different schools and in different jurisdictions. As such, there is likely to be cross-jurisdictional transfers of Personal Data. The child’s name will not be visible to site users other than their own class teacher and the administrator of the site.

(c) IADT is registered with the Data Protection Commissioner in Ireland as a “Data Controller”. However, IADT will not be a data controller for the purpose of the Personal Data volunteered by users of the Site.

(d) Each school participating in the Initiative will be a data controller for the purpose of the Personal Data being provided by children in those schools, and are solely responsible for ensuring that the provision of such Personal Data and the transfer thereof accords with data protection legislation in each relevant jurisdiction.

(e) IADT will act as a “mere conduit” (as such term is defined in Regulation 16 of the European Communities (Directive 2000/31/EC) Regulations, 2003) for the purpose of the transfer of Personal Data between users.

(f) By signing the Prescribed Consent (as such term is defined in the Terms and Conditions attaching to the Site and available at www.fisbookclub.ie/consentform, the guardians of children participating in the Initiative confirm their consent, on behalf of their children, to the collection and transfer of Personal Data as described in this Statement.

(g) The IADT never divulge Personal Data to third parties otherwise than in accordance with this Statement without your consent.
4. Disclosure of Information to Third Parties
4.1 We will not sell any Personal Data volunteered on the Site to any third party. We will not disclose your Personal Data to third parties unless you have consented to this disclosure or unless disclosure is required by agents or contractors of IADT in the course of providing services (in such circumstances, the third party is bound by similar data protection requirements).

4.2 We will disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
5. Statement in the Context of Use by Children

5.1 IADT acknowledges that persons under 13 years of age will be contributing content, including Personal Data, to the Initiative, and that such persons need special safeguards and privacy protection to protect their rights. To this end, IADT, through its terms of engagement with participating schools, requires the legal guardian for each participating minor to have consented, on behalf of their child, to their child’s participation in the Initiative.

5.2 Guardians have the right to request access to their child’s Personal Data or request deletion of the child’s Personal Data. A guardian may exercise these rights by contacting their child’s school or teacher directly, who shall in turn contact IADT. At any time a guardian can instruct a school or teacher not to permit their child to contribute any further Personal Data to the Initiative and can request that any Personal Data previously collected be deleted from the Initiative.

5.3 A guardian can access, change, or delete his or her child’s Personal Data by liasing with the relevant school/teacher who shall facilitate such a request. A guardian can contact IADT directly to arrange for access to, change or deletion of Personal Data of his or her child by sending an e-mail to info@fisbookclub.ie.
6. Security

6.1 IADT takes its security responsibilities very seriously, including by employing appropriate physical and technical security measures, conducting staff training and generating awareness, and regular reviews of these responsibilities. IADT will take all reasonable precautions to prevent the loss, misuse or alteration of Personal Data volunteered through the Site. You should note however, that Internet transmissions are never completely private or secure. You accept that any information or message you send to the Site may be intercepted or read by others. You hereby acknowledge and accept that IADT have no responsibility and shall accept no liability whatsoever for loss, injury or damage occasioned by the interception by third parties of your transmissions, nor does IADT offer any guarantees, warranties or indemnities as to the security or otherwise of any information which you volunteer.

6.2 Teacher(s), Children and Parent(s)/Guardian(s) are site ‘Users’. Registered members (teachers) of the site and their pupils can contribute, share and review online video book reviews from all members of www.fisbookclub.ie. However, Parent(s)/Guardian(s) have limited access and can only visit the video book reviews submitted by members of their own child’s class using a Parent/Guardian provided by their own child’s teacher at the teachers discretion.
7. Rights of Access

7.1 If you, or your child, has provided Personal Data to us and you:

a) would like copies of that information;

(b) would like us to correct any factual inaccuracies in that information; or

(c) would like that information deleted from our records,

then please contact us by sending an e-mail to info@fisbokclub.ie.

7.2 IADT will use reasonable efforts to supply, correct or delete information about you.

8. Changes to the Website Statement

8.1 This Privacy Statement may be the subject of change and the use of information that IADT gather shall be subject to the privacy notice in effect. It shall be your responsibility to check the Site frequently to see recent changes.

FÍSBookClub.ie, FÍS Office, IADT, Kill Avenue, Dun Laoghaire, Co Dublin, Ireland. E-mail info@fisbookclub.ie. Phone + 353 1 2394990.

IADT
PDST
Dept of Education