PERSONAL DATA PROTECTION NOTICE
Soka International Academy Malaysia Sdn Bhd (“the School”, “SISM”, “we”, “us”, or “our”) recognise our responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Malaysian Personal Data Protection Act 2010 (“PDPA”). This Personal Data Protection Notice (“Notice”) sets out the basis which the SISM may collect, use, disclose or otherwise process your personal data in accordance with the PDPA. Personal data will be collected and processed including personal data of children under 18 years old only for lawful and relevant purposes. We will use your personal data and/or your child’s personal data which we may from time to time collect in accordance with this Notice. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. As used in this Policy:
“applicant/employee/enquirer” means an individual who have applied to be employed in a contract of service (whether on a part-time, temporary or full-time basis) with us and all references to “employment” shall apply equally to internships and traineeships (as may be applicable); and
“customer/parent” means an individual who (a) has contacted us through any means to find out more about the school, or (b) is the parent of the school student; and
“student/child” means an individual who is receiving or has received education from the School; and
“personal data” means any information which relates to you and/or your child and which was collected or provided to SISM for the purposes stated in Section (5) below.
2. Depending on the nature of your interaction with the School, we collect your personal data upon and throughout the course of your relationship with us including:-
- Your personal details, including, but not limited to, your name, address, phone numbers, identity card number, passport number, the particulars of your travel document(s) and the details relating to other person(s) who may be identified from the data;
- Your employment details;
- Photographs, pictures, images, portraits and any other visual content in any media or form (including any electronic and digital format) (“Photographs”) of you;
- Films, tapes, video, closed circuit television (“CCTV”) or security recordings, and any other pictorial recordings in any media or form (including any electronic and digital format) (“Videos”) of you;
- Class work (written, visual or in any other form) created, conceived and produced for academic or non-academic purposes (“Class Work”) by you;
- Your health records, religious beliefs;
- The contents of all information obtained from the website, forms and/or documents collected by us;
- Your financial information such as credit card numbers, debit card numbers or bank account information; and
In addition to the above, if you are using any of our mobile or web applications, personal data may also include approximate location permission (non-continuous), phone permission, precise location permission (non-continuous) and storage permission.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless:
It is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after
- (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and
- (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes.
5. We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) notifying you of our events, initiatives and promotions, school activities and other associated communications, including sending you marketing information about our services;
(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(h) any other purposes for which you have provided the information;
(i) to operate our premises in a manner which is physically safe, secure and befitting of health and safety requirements;
(j) for the School’s internal records management and statistical analysis;
(k) to provide you with customer and/or student support;
(l) Internal record keeping throughout your employment; and
(m) any other incidental, ancillary or in furtherance to the above mentioned purposes related to or in connection with the above.
6. Disclosure or transfer of personal data (within or outside of Malaysia)
6.1 Your personal data provided to us may be disclosed to the following classes of third parties (within or outside of Malaysia) as required under the law or pursuant to relevant contractual relationship (for example, where we appoint third party service providers) or for the purposes or directly related to the purposes stated in Section 5 above. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you;
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Section 5 above for us;
(c) government departments or agencies, statutory authorities and industry regulators;
(d) any person to whom we are compelled or required to do so under law or in response to a competent or government agency; and
(e) law enforcement agencies.
6.2 If and when necessary, your personal data may be disclosed to the following third parties:
- i. External Professional advisors and auditors;
- ii. Governmental departments and authorities;
- iii. Universities and schools;
- iv. Travel agents or companies;
- v. Insurance agents or companies; and/or
- vi. Payroll providers.
6.3 In the event that your personal data is transferred to a location outside of Malaysia, arising from the use of cloud computing services that may be necessary in the conduct of our business to be stored on servers including but not limited to cloud servers or for any other purpose, we shall ensure that confidentiality safeguards have been put in place to ensure your rights to personal data protection remain unaffected.
WITHDRAWING YOUR CONSENT
7. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email at the contact details provided below.
8. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
9. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Section 7 above.
10. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
11. If you wish to make (a) a request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request via email at the contact details provided below.
12. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
PROTECTION OF PERSONAL DATA
13. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
14. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
15. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing us via email at the contact details provided below.
RETENTION OF PERSONAL DATA
16. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
17. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.
18.1 Links to other sites
Links to other sites may be provided on our website for your convenience and information. These sites may have their own privacy statement and we do not control, recommend or endorse these sites and we will not be held responsible for these sites or their contents. As such, we encourage you to read the privacy policies of these sites.
18.2 Location enabled products or applications
Location enabled products or applications transmit your location information to us. We will not use the information sent or provided by you for any other purposes other than to provide the services you requested. Location enabled features are opt-in and you have control over your participation and can turn these services off at any time or uninstall them. Some mobile applications will utilise Google Analytics (or a similar tool) to help us better serve you through improved products, services and revisions to the mobile applications. The information collected will not allow us to identify you. It may, however, let us know anonymously, the services and products most searched by you within the application as well as device type used and your country of origin.
In processing your information, cookies, which is a text file placed into the memory of your computer, may be used. We are able to use these cookies to identify you. We may be able to collect the following information during your visit to our website and / or the fully qualified domain name from which you accessed our site, or alternatively, through your internet protocol (“IP”) address:
• the date and time in which you accessed our website;
• the URL of any webpage from which you accessed our website; and
• the web browser which you are using and the pages which you have accessed.
Some websites may require you to provide a limited amount of information in order to obtain the services you requested (i.e. name, email address, contact number). This personal data will only be used for its intended purpose only, i.e. to respond to your message or deliver the requested service.
19. You may contact us if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, by emailing email@example.com.
EFFECT OF NOTICE AND CHANGES TO NOTICE
20. This Notice applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
21. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued participation in our SISM’s activities and use of our services constitutes your acknowledgement and acceptance of such changes.
22. In the event of any conflict between this English language Personal Data Protection Notice and its corresponding Bahasa Malaysia version of Personal Data Protection Notice, the terms in this English language Notice shall prevail.