InfoMentor is the data processor of the InfoMentor information system. All processing of personal information in the interest of the data controller is made in accordance to processing contracts which sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. InfoMentor, as a data processor hosts the InfoMentor system, which includes the retention of the data which the system stores.
InfoMentor does not record any personal information into the InfoMentor system such as information about students, family members or employees and it does not collect any information from the InfoMentor system for the means of processing information its own benefit.
The data controllers of InfoMentor are in most cases preschools, elementary schools, colleges, or other educational institutions. In the InfoMentor system, it is possible to record various information about students and their family members, such as names, addresses, telephone numbers and various information related to the education and schooling of students. It is also possible to enter necessary information about employees.
Data controllers (Employees of the educational institutions) record personal information into the InfoMentor system and are responsible for the information contained therein. The data controller needs to ensure that records are relevant, fair, transparent, and that data processing is carefully made in accordance to current data privacy laws and regulations.
Administrators of the educational institutions control who has access to the InfoMentor information system. Decisions regarding storing users’ information, retention periods, backup and storage procedures, sending and erasure of personal data concerning the students, parents and employees, resides with the controllers (educational institutions).
InfoMentor does not share or provide any information from the InfoMentor system unless a formal request is made from the data controller or there are clear legal grounds in place.
The deletion of data in the InfoMentor system is only performed when there is a formal request from the data controller. When there are no longer any substantive or valid reason for the retention of data, the data controller should inform InfoMentor of which electronic data should be discarded. When data is discarded, it is not possible to recover. Erasure of personal data is subject to defined operating procedures which InfoMentor has specified.
As InfoMentor has the responsibility of operating and servicing of the InfoMentor system, there are instances where it may be necessary for InfoMentor’s employees to access the system while assisting users or repairing the system. There are strict operating procedures in place at InfoMentor regarding which employees can perform such services and they are only ever conducted when a formal request is available from the data controller.
All in-system actions of InfoMentor’s employees are logged and traceable back to individuals. All employees of the company are bound by confidentiality. See chapter 5 for further information of technical and organizational security measures.