Personal Data Protection Statement

Applicable to non-UK and non-EU Data Subjects only.

Please read Guide to the UK General Data Protection Regulation (UK GDPR) and The Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada

The Equantz Technology Inc. (“Equantz” or “SESDS” or School”) respects the privacy of individuals and recognizes the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect, process and disclose your personal data. We are also committed to adhering to the provisions and principles of the Personal Data Protection Act 2018 of Information Commissioner’s Office in UK and Office of the Information and Privacy Commissioner, BC , Canada. As such, this Personal Data Protection Statement is to assist you in understanding how we collect, use and/or disclose your personal data.

We will collect, use and disclose your personal data in accordance with the Personal Data Protection Act 2018 (“Act”). The Act establishes a data protection law that comprises various rules governing the collection, use, disclosure and care of personal data. It recognizes both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organizations to collect, use or disclose personal data for legitimate and reasonable purposes.

“‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

The Act takes into account the following concepts:

Consent – Organizations may collect, use or disclose personal data only with the individual’s knowledge and consent (with some exceptions);

Purpose – Organizations may collect, use or disclose personal data in an appropriate manner for the circumstances, and only if they have informed the individual of purposes for the collection, use or disclosure; and

Reasonableness – Organizations may collect, use or disclose personal data only for purposes that would be considered appropriate to a reasonable person in the given circumstances.

In projecting the three main concepts above, the Act contains nine main obligations which organizations are expected to comply with if they undertake activities related to the collection, use and/or disclosure of personal data.

While we will not be going into the details of these obligations in this Personal Data Protection Statement, you can be rest assured that we are constantly mindful of them in our collection, use and disclosure of personal data. Should you wish to know more about these obligations, an excellent summary can be found in the Guide to the UK General Data Protection Regulation (UK GDPR) and The Personal Information Protection and Electronic Documents Act (PIPEDA) 

PURPOSE FOR THE COLLECTION, USE & DISCLOSURE OF PERSONAL DATA

In general, subject to applicable exceptions permitted in the Act, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed, as well as obtain consent for the collection, use and/or disclosure of your personal data for the intended purposes.

Depending on your relationship with us, the personal data which we collect from you may be used and/or disclosed for the following purposes:

For Participants Generally

Most of you will have consented to SESDS using your personal data in the manner set out in the online matriculation form used when you first matriculated into SESDS; or when you use specific services and facilities offered by the School; or when participants are notified by the School administration of new rules and policies applicable to the participant body and are deemed to have consented to the same. The information below serves only to supplement and clarify this matter, without limiting the scope of your earlier consent:

Evaluating suitability for selection or employment, enrolling or employing, providing educational courses and training, including sending materials on course / study / assignment / lecture materials, information on time tables and examination details via various means, including postal mail, electronic mail, SMS or MMS, fax and/or voice calls;

Administering and/or managing relationships with SESDS (including responding to enquiries, the mailing of correspondence, statements or notices which could involve the disclosure of certain personal data to bring about delivery of the same);

Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by SESDS, including the obtaining of references and/or other information from prior educational institutions and employers;

Processing application(s) for scholarships and/or financial aid, and research support, and administering and managing scholarship/financial aid/grant and other support programs, which may include use of personal data for development and fund-raising activities and disclosure of personal data to donors, grantors, external evaluators and/or external organizations for purposes of assessment, periodic reports, event invitations, surveys and/or publicity of SESDS related programs;

Investigative, security and verification purposes, including, without limitation, possible fraud, misconduct, harassment, unlawful action or omission, and utilizing electronic access and video systems to maintain campus security of persons or property, control access and investigate suspicious or inappropriate activities;

Responding to requests for information from government or public agencies, ministries, statutory boards or other similar authorities or non-government agencies authorized to carry out specific Government services or duties;

Carrying out market-related, evaluative or similar research and analysis for SESDS’s operational strategy and policy planning purposes, including providing data to external parties for School program evaluation and to participants’ former academic institutions and to partner institutions for jointly-administered programs;

Outreach and engagement to garner support and resources for SESDS, its community and affiliated institutions;

Supporting SESDS functions including, but not restricted to, the teaching and personal and professional development of participants, research and administration of SESDS;

Processing and administering applications for overseas exchange programs, summer school, overseas internships and other overseas activities and administering such programs including disclosure of information to overseas universities / institutions, employment and training organizations;

Processing, administering and conferring awards of prizes, medals, scholarships, classes of honors and other marks of distinction, and participant or graduation status, and publication or releasing of information on the same;

Engaging alumni including but not limited to notification on SESDS and alumni-related initiatives and activities, invitation to SESDS and alumni-related events, updating of alumni information, invitation to participate in alumni surveys and sending of communication collaterals;

Processing applications and enrolment activities related to health, life and travel insurance and service provision as well as School-related concession cards, and campus accommodation and administering matters related to use of these services;

Processing applications for and administering local and overseas career related activities, events, programmes, internships, employment opportunities, and career coaching, and sharing information with companies (whether local or overseas) for purposes of recruitment, internships, industrial attachment, job placement and research support;

Facilitating participation in participant life and alumni development opportunities which may include social, cultural, athletic, and educational activities, events, volunteering and training programs, participant membership and leadership positions in clubs, societies, halls and residences, and orientation/reception activities;

Taking of photographs and/or videos (whether by SESDS staff or third-party photographers and/or videographers) during events or seminars organized by SESDS or its affiliates for publicity purposes;

If consented to in the registration form and/or other methods of consent notification, providing marketing, advertising and promotional information via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;

Any other purpose arising in respect of the environment within which an institution of higher learning such as SESDS operates which is reasonable given your relationship with SESDS;

Any other purposes not related to those listed above or in the online matriculation form to which you consented, which SESDS may inform you from time to time, but for which SESDS will seek your separate consent.

For Employees/Staff Generally

In order to comply with its contractual, statutory, and management obligations and responsibilities, the School is required to process personal data relating to its employees. All such data will be processed in accordance with the provisions of the Act and the relevant School’s rules and policies, including those on data protection, as may be amended from time to time. Your relationship with SESDS will, in almost all cases, be governed primarily by an employment or an engagement agreement, and your agreement to be bound by the Employee Handbook and/or Governance and Academic Policies Handbook (which may be revised from time to time), any of which will very often inform you expressly or impliedly the purposes for, and the manner in, which your personal data will be used. The purposes listed below serve only to supplement and clarify the matter, without limiting, superseding or supplanting any express or implied terms in the abovementioned documents:

for managing your employment relationship with SESDS;

for using your bank account details to deposit salaries and other payments;

for monitoring the use of SESDS’s computer network resources;

for posting your photographs on SESDS’s intranet and website, staff pass, newsletters and the like;

for managing staff benefit schemes;

for disclosing your personal data where necessary to external parties for purposes of School administration, and to Government agencies for official purposes and disclosed to external third parties for, or in connection with, the above purposes, or where required by law;

for investigative, security and verification purposes, including, without limitation, possible fraud, misconduct, harassment, unlawful action or omission, and utilizing electronic access and video systems to maintain campus security of persons or property, control access and investigate suspicious or inappropriate activities;

any other purpose arising in respect of the environment within which an institution of higher learning such as SESDS operates which is reasonable given your relationship with SESDS; and

any other purposes not related to those listed above or in your employment contract, which SESDS may inform you of in writing from time to time, but for which SESDS will seek your separate consent.

For The Public and Other Third Parties Generally

SESDS is committed to engaging and embracing its surrounding community, ecosystem as well as society at large. As a result, we often organize a lot of activities in which external stakeholders or the general public are invited to participate. While it is impossible to list all the events in which we hope the public will participate, some events that you as a member of the public can look forward to include community outreach programs, talks, exhibitions, movie screenings, concerts and many others (“Events”). Naturally, in encouraging a vibrant interaction with the public, there will be opportunity, and often a need, to collect, use and/or disclose personal data from members of the public. Some of the reasons/ purposes are as follows:

Investigative, security and verification purposes, including, without limitation, possible fraud, misconduct, harassment, unlawful action or omission, and utilizing electronic access and video systems to maintain campus security of persons or property, control access and investigate suspicious or inappropriate activities

For logistical/ administrative purposes for certain Events (e.g., Food catering)

To keep you updated of future SESDS Events/ products which we feel may interest you

For marketing/ publicity purposes (e.g., Photographs)

For any other purpose arising in respect of the environment within which an institution of higher learning such as SESDS operates which is reasonable given your relationship with SESDS.

In almost all of the above situations, it will be totally up to you as to whether, and to what extent, you wish to provide us with your personal data. For Events where such provision of personal data is a pre-requisite to attendance, you shall be informed in advance so that you may make an informed decision as to whether to attend. SESDS will also endeavor at all times to inform you of the purposes for which personal data collected from you will be used. Should you at any time feel that the manner in which SESDS has acted, or seeks to act, in respect of the collection, use or disclosure of personal data for an Event is inappropriate, please feel free to make your concerns known to the Data Protection Officer, whose contact details can be requested at: info@equantz.com

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We will not disclose your personal data to any third parties without first obtaining your consent permitting us to do so or unless any such disclosure is permitted under any of the statutory exemptions under the Act. In this respect, please note that we may disclose your personal data to third parties in certain circumstances without first seeking your consent, if such disclosure is either required or permitted under the Act, including without limitation, if the disclosure is required by law and/or regulations or if there is an emergency.

REQUEST FOR ACCESS, CORRECTION AND/OR WITHDRAWAL OF PERSONAL DATA

Subject to certain exceptions in the Act, you may request to access and/or correct the personal data currently in our possession or withdraw your consent for the collection, use and disclosure of your personal data in our possession at any time by clicking here.

For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such request being made. You may be charged a reasonable fee for the handling and processing of your requests to access your personal data, but you will be notified in advance of such fees.

For a request to correct personal data, we will process your request, including undertaking necessary verification activities, as soon as practicable after the request has been made. We will send the corrected personal data to every other organization to which the personal data was disclosed by SESDS within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose, or if you so consent, only to specific organizations to which the personal data was disclosed by us within a year before the date the correction was made.

For a request to withdraw consent, we will process your request within a reasonable time from such a request being made, upon informing you of the consequences of your request for withdrawal of consent.

For Participants: If, for any reason whatsoever and at any time during your period of study with SESDS, you are uncomfortable with the manner or extent of collection, use and/or disclosure of your personal data, you are advised to inform your Dean or the Dean of Participants so that a reasonable and mutually acceptable solution to your concerns can be found.

For Employees/Staff: If, for any reason whatsoever and at any time during your period of employment at SESDS, you are uncomfortable with the manner or extent of collection, use and/or disclosure of your personal data, you are advised to inform your immediate supervisor, Head of Department or Dean so that a reasonable and mutually acceptable solution to your concerns can be found.

For the public and other third parties: In some cases, requests for withdrawal may adversely impact your relationship with SESDS as it may hinder SESDS’s ability to continue to interact with you. We will notify you in advance of such impact, if any.

ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

We will take appropriate measures to keep your personal data accurate, complete and updated.

We will also take reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data.

We will also take reasonable efforts to ensure that the personal data in our possession or under our control is destroyed as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

Our websites may contain links to other websites not maintained by SESDS. Such third-party websites are subject to their own data protection and privacy practices and you are encouraged to examine the data protection policies of those websites.

RESPONSIBILITY OF EMPLOYEES (STAFF, FACULTY), PARTICIPANTS AND OTHER STAKEHOLDERS

The Act also imposes certain responsibilities on all those who process personal data at the School, whether you are a member of staff holding, using and sharing personal data in your teaching, research or administration, or a participant accessing and recording personal data in your studies or other activities. These obligations include holding and using data in a secure manner, making sure that data is handled in line with what individuals have been told, having appropriate arrangements in place for the access to (and sharing of) data, and making sure that individuals’ data is accurate and retained for a suitable period. If a data breach occurs (e.g., personal data held by the School is lost, stolen, inadvertently disclosed to an external party, or accidentally published), this should be reported immediately to your seniors and the Data Protection Officer so that we may review the circumstances and liaise as necessary with colleagues internally and the relevant external authorities.

CONTACT US

If you have any questions on Privacy Statement, please contact Data Protection Officer at: info@equantz.com