Personal data privacy policy

The Data controller of the personal data is the organisation (or the organisation(s)) that manage the educational institution (referred to as “the Institution”). You can access information about the identity of the organisation (or organisations managing the educational institution) in the “Legal Notice” section of the Institution’s website.

The data subjects concerned by the processing of their personal data are those defined below :

• Alumni : a Student or Trainee who has completed or not yet completed a course of study at Institution, whether or not he or she has graduated​​​​​​​.
• Applicant : any natural person who has started to complete or has already completed an application file (digitally or on paper) or who has informed the Institution of his or her wish to apply for a course.
• Company contact : any natural person within a company who monitors the Student/Trainee as part of his/her internship or work-study program (tutor, internship supervisor, etc.)
• Student : any natural person registered with the Institution and following a course during the academic year.
• Trainee : any natural person registered with the Institution and following a work-study program during the current academic year.
• Internet user : any natural person consulting this website (hereinafter referred to as the “Website”).
• Contributor : any natural person in charge of a pedagogical service in the Institution (independent contractor or employee of the Institution).
• Partner : any natural person or legal entity having concluded a partnership contract with the Institution.
• Data subject : any identified or identifiable natural person within the meaning of Article 4 of the GDPR, and in particular Trainees, Applicants, Company contacts, Students, Prospects and Third-party payer.
• Staff : any natural persons, whether or not employed by the Institution.
• Service provider : any natural or legal person who has entered into a service contract with the Institution.
• Prospect : any natural person interested or who may be interested in a training course, or an event offered by the Institution, or who has expressed an interest in a training course, whether or not it is a diploma course, offered by the Institution.
• Sponsor : any natural person who sends a letter of recommendation to the Institution on behalf of a Student or Trainee.
• Legal representative : any legal entity or legal person who is in charge of representing a Student/Trainee.
• Third party payer : any natural or legal person who is responsible for financing the training of a Student / Trainee, in particular concerning the payment of tuition fees, or as a guarantor.

Unless otherwise required by the context, the definitions of the data subjects concerned above in the singular include the plural.

The Institution processes the personal data of the Data subject in the context of the Purposes of the processing as detailed in paragraph 4 of the Policy.

The categories of data below are mentioned for information purposes and are processed according to the application file completed by the Student / Trainee or according to the information communicated by the company that has registered its employees for a course offered by the Institution.

The categories of personal data processed are the following :

STUDENTS / TRAINEES :

Connection data : IP address, username and password, connection logs, web pages visited, browser used, operating system, history of websites visited, history of downloads, language used, verification of compliance with deadlines on assignments requested from Students/Trainees, monitoring of Student/Trainee connection time.
Identification data : civil status (title, surname, first names, date and place of birth, nationality), copy of the national identity card, passport, or any other official identification document (including residence permits), landline and/or mobile telephone number, personal e-mail address, identifier or identification number allocated by the Institution, Pôle Emploi identification number, signature, social security number (only for Trainees).
Images and sounds : image recordings (CCTV, verification of the Student's / Trainee's presence in the context of distance learning courses), Photography, Sound recordings.
Personal data : family status (single, married, cohabiting), postal address, e-mail address, household composition (number of children), housing record.
Professional / academic data : National student identifier (INE), e-mail address provided by the Institution, professional and Institution/university experience (CV), training courses (transcripts of previous years' marks), copies of diplomas, reports of interviews for entry into training, results of placement tests, results of admission tests, languages spoken (LV1, possibly LV2), attendance sheets, disciplinary procedures, function within the company as well as e-mail address and professional telephone number in the event of an internship or work-linked training, home Institution, previous class, options followed during the current year and the previous year, year of entry into the Institution, position (repeating or not), grades obtained during the current training, information on any internships or work-study programs (internship/work-study agreement), non-attendances and lateness, teachers' comments on the level and progress or shortcomings of the Students/Trainees, grades obtained in competitive examinations or admission tests.
Economic and financial information : data relating to means of payment (cheque, bank details), data relating to the payment of invoices (schedule, outstanding amounts, reminders, balances), last tax assessment, copy of employment contract, student bank loan certificate, supporting document for scholarship student, bank loan.
Health data : medical documents justifying a situation of disability.

LEGAL REPRESENTATIVE :

Identification data : title, surname, first name, postal address, e-mail address, telephone number, signature.
Economic and financial information : last tax notice (information processed as part of a scholarship application filled in by a Student); pay slips (for Legal Representatives living abroad - information collected only as part of scholarship applications offered by certain IGS Group Institutions).

COMPANY CONTACTS :

Identification data : surname, first name, business telephone number, business e-mail address.
Professional data : function within the company.

RESPONDENT :

Identification data : title, surname, first name, postal address, e-mail address, telephone number.
Professional data : function.

THIRD PARTY PAYER :

Identification data : title, surname, first name, postal address, e-mail address, telephone number, proof of identity (copy of national identity card or passport), signature.
Economic and financial information : means of payment, bank details (in the case of payment by direct debit).

ALUMNI :

Identification data : title, name, name at the time of training, first names, personal email address, date of birth, postal address, email address, telephone number.
Professional / educational data : function of the person in the company, information on the educational and professional background of the Trainees (diplomas obtained, background filled in by the graduate, class, group, division attended (with year), date of entry into the company, telephone numbers, professional fax numbers, professional email, annual salary (if filled in by the former).

The personal data of the Data Subjects are never sold, marketed, or leased by the Institution to third parties, nor are they further processed in a manner incompatible with the purposes as detailed below, nor beyond the predetermined processing periods.

The information collected about the persons concerned is the subject of computer processing intended for prospecting operations for similar services. Each Data subject is likely to receive information on the various training courses offered by the Institution. Any Data subject concerned may exercise his/her right to object at any time and without reason to any future solicitation sent by the Institution by sending an email to the Data Protection Officer at the email address mentioned on page 1 above.

4.1. Information on the processing of personal data collected on the Website

*The retention in active base corresponds to the retention during which the data is used by the staff of the Institution before being archived for a period in accordance with the rules of prescription applicable in civil, commercial, and fiscal matters and/or before being definitively deleted. When personal data is stored in archives, it is no longer used by the Institution for the purposes of the processing determined but is of administrative interest to the Institution (for example, for the management of a possible dispute) or must be stored to meet a legal obligation. The data may then be consulted on an ad hoc basis by specifically authorised persons.

4.2. Information on the processing of personal data collected via paper forms (application form, registration form for the Institution, open days or discussion forums, participation in webinars, etc.) and in the context of the life of the Student / Trainee within the Institution

* The retention in active base corresponds to the retention during which the data are used by the staff of the Institution before being archived for a period in accordance with the rules of prescription applicable in civil, commercial, and fiscal matters and/or before being definitively deleted. When personal data is stored in archives, it is no longer used by the Institution for the purposes of the processing determined but is of administrative interest to the Institution (for example, for the management of a possible dispute) or must be stored to meet a legal obligation. The data may then be consulted on an ad hoc basis by specifically authorised persons.

The Institution’s staff is the recipient of personal data transmitted (administration department, billing service, communication, information services, management, teaching assistants and teachers and/or tutors) as well as the emergency services responsible for taking in charge the student in the event of a medical emergency (ambulance, fire brigade, etc.).
Health data is collected in order to adapt the Student’s/Trainee’s possible disability situation, especially for exams taking place at the end of the courses/program. The Institution’s administrative department and any duly authorized person are the recipient of health data, in particular the doctor who intervenes in the interest of the Person concerned and/or possibly the emergency services in the event of a medical emergency (ambulance, fire brigade etc.). In order to follow up the file, the Institution may request supporting documents during the year, depending on the nature of the disability and the declared state of health.
Information may be transmitted to some of data processors Service providers so that the Institution can provide to the Student/Trainee the service(s) offered. These service providers act on instructions of the Institution, and the Institution ensures that the data transmitted is processed only in connection with the provision and services offered, unless the Student/Trainee has directly signed up for the services of a Provider or has given his or her consent to the Provider’s use of his/her data for the Provider’s own purposes.
When data is transmitted to Service provider/Partners, for the purposes of the services offered by the Institution in the context of training, or if you have given your consent, the Institution will inform you by any means.
Some data may also be sent to the various organisations below (hereinafter "Organisations") :

• to the Ministry of Higher Education and Research : data from the Students/Trainees transmitted to this body: Data relating to identity and contact details; Data relating to the last Institution of the young person; Data relating to the solutions and support offered to the young person; data from the Legal Representatives : Data relating to identity and contact details;
• to the Board of Education in order to establish statistics : data of the Students/Trainees transmitted to this organisation: Data relating to the identity and the coordinates; Data relating to the last Institution of the young person; Data relating to the solutions and the accompaniment proposed to the young person; data of the Legal Representatives: Data relating to the identity and the coordinates;
• to the Observatoire de la Vie et de l'Insertion Étudiantes (OVIE) in order to carry out surveys and statistics on the living conditions of students : Student data transmitted to this organisation: title, gender, first name, surname, national student identifier (INE), nationality, postal address, diploma obtained, parents' postal address, personal e-mail address, e-mail address provided by the Institution, telephone number, date of birth, registration status (initial training, continuing education or apprenticeship);
• the Centre d'études et de recherches sur les qualifications (CEREQ), a public institution under the dual supervision of the Ministry of Education and the Ministry of Employment, which conducts an original national survey system that makes it possible to study young people's access to employment after their initial training : Student/apprenticeship data transmitted to this organisation: surname, first name, e-mail address, national student identifier (INE), gender, date of birth, postal address, telephone number (landline or mobile), diploma, enrolment regime (initial, continuing or apprenticeship training);
• to France Compétences, a French national public institution, in order to enable the Institution to meet its legal obligations in the context of requests for validation of the Institution's certifications, monitoring and evaluation of the quality of training actions and to obtain regional funding for the training courses offered : Student/Trainees data transmitted to this body: surname, first name and data relating to employment and career path;
• the CNOUS (Centre National des Œuvres Universitaires et Scolaires), the CROUS (Centre Régional des Oeuvres Universitaires et Scolaires): data from the Students/Trainees transmitted to these organisations: data relating to identity and contact details; data relating to the young person's last Institution; data relating to the solutions and support offered to the young person; data from the Legal Representatives : data relating to identity and contact details;
• Organisations linked to continuing education, such as OPCO : data on Students/Trainees transmitted to this organisation: surnames and forenames, telephone numbers, address, date of birth, start and end dates of contracts and the company where the employee works, e-mail address, last diploma obtained, Pôle Emploi identification number, status as a disabled worker;
• To the DREETS (Directions régionales de l’économie, de l’emploi, du travail et des solidarités) due to the Institution’s legal obligations concerning the Trainees employed by a client company : data on the Students/Trainees transmitted to this body: surnames and first names, telephone numbers, address, date of birth, start and end dates of contracts and the company where the employee works, e-mail address, last diploma obtained, Pôle Emploi identification number, status of disabled worker.

These Organisations are solely responsible for the processing of Student/Trainee data when data is transferred directly to organisations by the Institution.
In addition, the necessary data may be communicated to the following recipients depending on the Institution's obligations: to the Commission Nationale de la Certification Professionnelle (the data is pseudonymised) and to the Institution's insurer (only the first and last names and periods of cover are transmitted to the insurer).
The Institution has implemented an Alumni directory, which can be used to send newsletters, invite students to events and compile insertion statistics. The Institution may communicate the directory to the Alumni association with information concerning the Student/Trainee in order to make it accessible (with login and password only) to other Alumni.
In case of payment of the tuition fees by the Student's legal representative, the latter will receive the disciplinary correspondence or the delivery of the possible academic sanctions (reports, essay marking, etc.).

The data may be transferred to the Institution's Partners or Providers, and more generally to sub-processors for the services that the Institution offers to the Data subjects in the context of training.
The Institution implements all the means at its disposal to ensure the protection and confidentiality of the transferred data and ensures in particular that the Partners and/or Providers located outside the European Union ensure a level of protection of the data and the rights of the Data subjects (and in particular their private life) in conditions equivalent to those guaranteed within the European Union by the GDPR if applicable.
In particular, the Institution signs standard contractual clauses validated by the European Commission with its Partners/Service Providers and provides for additional guarantees to ensure that the Partners/Service Providers comply with the data processing and protection requirements set out in the GDPR. For example, the Institution shall ensure that the change in the legislation of the country where the Partners / Providers are located is not likely to have a significant negative impact on the safeguards and rights of data subjects. If so, the Institution requests its Partners / Providers to process personal data exclusively in the territory of a European Union Member State, unless expressly authorised by the Institution and wish a special guarantee given by the Partner / Provider.

The Institution implements appropriate measures to ensure an appropriate level of protection to the risk regarding confidentiality, integrity, availability and resilience of processing systems and services, in particular, to prevent personal data from being falsified, damaged, or disclosed to unauthorised third parties. The personal data of Data Subjects and all information communicated by them are meant for internal use and are kept in conditions that ensure their security and confidentiality according to the different purposes of processing.
The Institution regularly monitors internal procedures and technical and organisational measures to ensure that the processing under its responsibility is carried out in accordance with the requirements of the legislation in force on the protection of personal data and the protection of the rights of the Data Subject.

In accordance with the regulations in force, any Data subject concerned may ask the Institution, through its Data Protection Officer (DPO) whose contact details are below, to exercise :

• a right of access : the right to ask the Institution whether it holds data concerning him/her, and to request communication to verify the content;
• a right to rectification : this involves the rectification of inaccurate or incomplete information about a Data Subject. It prevents an organisation from using or disseminating incorrect information about that Data Subject;
• a right to erasure (if applicable) : the right to ask the Institution to erase personal data concerning the Data Subject;
• a right to restriction of processing (if applicable): the right to ask the Institution to temporarily freeze the use of certain data;
• the right to portability of their personal data (if applicable): the possibility to retrieve part of their data in an open and machine-readable format;
• the right to object to the processing of data (if applicable): the possibility for any Data Subject to object at any time to the use of certain of his/her data by the Institution for a specific purpose. This concerns in particular the right to object to any commercial prospecting or to be contacted by the Institution, by email or by SMS/MMS, for other similar training or services;

A Data Subject also has a right not to be subject to a decision based solely on automated processing, including profiling.
Any person concerned may lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés) for any difficulty relating to the processing of their data: https://www.cnil.fr/fr/plaintes.
For any request concerning personal data, please send an email to the Data Protection Officer at the email address mentioned on page 1 above (dpo[a]groupe-igs.fr).

Students/Trainees will be informed of Policy updates by any electronic means (email, intranet, DWE…).

10.1. Learn more about cookies and cookie management
The term “cookie” covers all cookies or tracers placed and/or read on equipment (computer, smartphone, tablet), for instance when visiting a website. During the visit to the Website, information regarding the Internet user’s browsing may be recorded on his or her equipment in cookie files placed by the Institution or third parties. The cookie may contain several pieces of data: the server’s name that placed it, a username in the form of a unique number, an expiry date, etc. This information may be stored on the Internet user’s computer in a simple text file that server accesses to read and record information.

10.2. What is the purpose of the cookies that may be stored on a terminal and how to handle it?
Cookies have different functions.

Technical cookies

Technical cookies are used for technical purposes, to make the navigation easier on the Website. Thanks to these technical cookies, it is possible to identify the Internet user in order to help him/her to fill in forms or certain fields, and to help him/her to improve his/her navigation. Technical cookies also make it possible to implement security measures or to take into account some of the Internet user’s choices, such as language.

The only purpose of these cookies is to make the Website operational. These cookies may be placed and read on the Internet user’s terminal without his/her consent. If the Internet user “uninstalls” a technical cookie from his or her equipment, he or she will not be able to benefit from the services offered by the Website.

Cookies for audience measurement, advertising and “social networks”

Audience measurement cookies are used to measure the audience of the various contents and sections of the Website and, in particular, to understand how users arrive on the Website.
Advertising cookies allow the display of targeted advertisements on a web page according to the profile of the Internet user who consults the page and, more particularly, according to the pages that the latter has consulted.

The Website has added social plug-ins to its pages in order to make easier the sharing of the Website’s content on several social platforms. These social plug-ins guide the Internet user towards the Institution’s social networks.

10.3. Choices in cookie management (consent to deposit and withdrawal of consent)
Each Internet User is able, at any time, to express or modify his wishes regarding cookies deposit, and in particular, to know the Partners list and their third cookie-parties, thanks to the means described in paragraph.

Click on the link : CLICK HERE TO CHANGE YOUR COOKIE PREFERENCES.

10.4 Bellow or by clicking on the icon available on the Website.

10.4. Setting cookies directly from the browser and mobile devices
The internet User has the opportunity to delete the cookies places on his/her equipment.
The configuration of each browser is different. It is the Internet user’s responsibility to follow the instructions of his browser’s editor as follows (links available at the date of the “Cookie” page update) :

For Firefox : launch the browser then simultaneously press “Alt + O”; select “Options”; click on the “Privacy and Security” tab then choose the desired options. Find these explanations with the following link: https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites

For Chrome : launch the browser and press “Ctrl + H” simultaneously; click on “Clear Browsing Data», and check the “Cookies and Other Site Data” box. Find these explanations with the following link: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en

For Safari : launch the browser then click on “Safari” at the top left; select “Preferences” then click on “Privacy”; click on “Manage website data”; select one or more websites then click on “Delete” or “Delete all”. Find these explanations with the following link: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

For Opera : launch the browser then click on “Settings” in the toolbar; select “Delete private data”; check the box “Delete all cookies”; click on “Delete”. Find these explanations with the following link: https://help.opera.com/en/latest/web-preferences/#cookies

For Internet explorer : launch the browser then click on “Menu” and then “Internet options”; click on the tab “Privacy” and under “Settings” press “Advanced” in order to get the “Advanced privacy settings”. Tick the box “Override automatic cookie handling”, then select “Deny” in the “Third party cookies” column. Find these explanations with the following link: https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies
To disable ad targeting and set geolocation options for mobile devices.

IOS : go to the privacy setting, and then :

• For targeted advertising: go to the “advertising” option and enable “limited ad tracking”;
• For geolocation: go to “Location Service” option and set which applications can access location data.

Android : regarding targeting advertising, go to the application “Google settings”, press “Ads”, activate the option “disable ads by interest” and “reset ad ID”.

10.5. Cookie retention period
Cookies stored on the Internet user’s terminal, or any other element used to identify the Internet User for statistical or audience purposes will have a reasonable life span relating to the purpose of the processing considered, up to a maximum of thirteen (13) months; this period is not automatically extended when the Internet user visits the Website again.

Beyond that, the raw visiting data associated with a username are either deleted or anonymized.