I. COLLECTION OF PERSONAL DATA
“Personal data” is any data or information that personally identifies a person or that, together with any other available data, makes any person identifiable to another.
Some of the SOEPL’s Services do not require any personal data from you. However, in many cases, the SOEPL may require personal data directly from you when accessing and/or using the Services. It is voluntary and up to you whether to provide the personal data requested by us. We will indicate whether the information we have requested is required. However, if you do choose not to give us certain information, you may be unable to access or use certain features or areas of our websites and Services or we may be unable to provide certain Services to you.
The type of personal data you will be asked to provide depends on the type of Service you use. Personal data may include, without limitation, your name, address, email address, phone numbers, exam/assessment results, language proficiency, date of birth, education records, and free and reduced-cost registration eligibility status. In some cases, the SOEPL may collect financial information, such as bank details and credit card information, as well as travel information (including passport or contact information for next of kin).
The SOEPL may also collect sensitive personal data such as gender, race/ethnic origin, information related to criminal convictions, medical or other information regarding disabilities or other conditions requiring assessment accommodations. Sensitive personal data will not be collected unless it is for a legitimate purpose and unless you have given express and unambiguous consent.
Special Considerations for Children or Students who are Minors
The SOEPL has special concerns about the privacy of all SOEPL students or children who access our website, but in particular those who are minors, i.e. under the age of majority (in many jurisdictions, this age is 18). Because the age of majority and consent can vary depending on a student user’s country of residence, the SOEPL has adopted this age (18) as a uniform requirement. In other words, consent from both the student and parent or legal guardian may be required in order for users under 18 years of age to use some of the SOEPL’s Services.
Special Considerations for Personal Data Provided by SOEPL Teachers, Coordinators, School Administrators and Other Third Parties
For some Services, SOEPL coordinators, teachers and school administrators may submit personal data about SOEPL students to the SOEPL’s Services (e.g. registration for SOEPL competition (s)). For such Services, the SOEPL does not have a direct relationship with the individuals (e.g. students) whose personal data may be processed in connection with providing the Services. In these circumstances, the SOEPL coordinators, teachers, and/or school administrators are responsible for ensuring that any such sharing or transfer of personal data to the SOEPL is done accordance with applicable local law and without violating any privacy or data protection rights of any individuals, including, without limitation, providing appropriate notice to the individuals and obtaining any required consents. SOEPL acknowledges that personal data and information provided to it by employees or agents of schools for certain Services may be protected under local applicable laws.
As a parent, you should consult your school’s policy for more information about the ability of SOEPL coordinators, teachers and school administrators to provide personal data or consent on behalf of parents and students.
II. PURPOSES FOR PROCESSING AND USE OF PERSONAL DATA
Your personal data may be collected, processed and/or stored by the SOEPL for the following purposes:
- To register you for SOEPL examinations and assessments;
- To provide assessment accommodations and/or inclusive education arrangements;
- To recruit SOEPL educators and examiners;
- To assist with and respond to queries and requests submitted through the SOEPL Answers online service;
- To register you for SOEPL event(s) (such as workshops or conferences) that you have chosen and process any required payments; to provide you with information relating to the particular SOEPL event(s) for which you have registered; to share with SOEPL educators if necessary for the assignment;
- To make travel arrangements on your behalf (via travel services providers and on-line booking tools) and process expense claims and other requests for payment.
- To conduct SOEPL run, SOEPL -sponsored or SOEPL supported research, including independent research or journalistic work, for legitimate purposes related to SOEPL programmes, exam results, services and student outcomes, whether using personal data, individual-level data, aggregated data, anonymous data, or pseudonymized data;
- To conduct surveys about the Services and related activities to get feedback about the Services and related activities;
- To promote and market the SOEPL and the Services (including SOEPL events or topics that the SOEPL believes would be of interest to you), 1) if you expressly agree and opt-in to receive SOEPL promotional and marketing materials or 2) unless you expressly opt-out of receiving such materials, as may be required under local law.;
- To conduct internal SOEPL reporting on Services and analysis of its Services and activities;
- To identify you when you apply for a password, access password-protected websites or areas of a website, post information to a website or when you send information to the SOEPL in any form;
- To create your account, password and profile for a Service;
- To fulfill contractual duties toward you, for example, for billing and shipping purposes when processing purchase orders or requests for documents;
- To enforce contractual claims against (including those that might arise out of your breach of the terms and conditions);
- To conduct statistical analysis of the SOEPL websites’ user structure, SOEPL programmes, assessment results and other Services; and
- To carry out personality assessments as part of the selection process, some of which may be automated.
- The SOEPL processes your personal data with your consent, where such consent is required by applicable law and you agreed to the use at the time it was collected (or if we subsequently obtain your consent). You may withdraw your consent at any time (for example, for us to send you marketing communications) by contacting the IB at firstname.lastname@example.org. The SOEPL also processes your personal data where this is necessary for the performance of a contract with you or where it is necessary for the SOEPL’s legitimate interests of operating, protecting and improving the Services.
Accuracy of Personal Data – Self Reported
By using the Services, you agree to provide accurate, complete and up-to-date personal data. Each user of the Services is solely responsible for the personal data he or she provides and agrees that he or she conforms to all local data protection laws where required by applicable law.
III. THIRD PARTIES, DISCLOSURE and CROSS-BORDER TRANSFERS
The SOEPL has/may have databases in different countries and your personal data may be used and processed by SOEPL staff, affiliates or contractors in any of the countries in which they are located, including without limitation, India. They are obligated to treat your personal data in accordance with SOEPL’s internal global data protection policy.
In addition, as part of operating the Services, the SOEPL may transfer your personal data to third-parties who provide business-related services to the SOEPL (such as providers of cloud hosting solutions; event management services; client relationship management services; travel booking services; expense and payment processing services; registry service providers; assessment service providers, such as examiners, moderators, eMarking service providers; and on-line course providers). In addition, your personal data and information may be transferred to synchronize and update between and among these systems in order to provide the Services more efficiently and effectively. Accordingly, your personal data may be transferred to, and further processed by and among, these third-party service providers in connection with their performance of such functions. However, these third parties may not use it for other purposes and have contractual arrangements with the SOEPL that address the privacy and security of such information.
These parties, as well as the SOEPL, may process your personal data outside India, the UK, the USA and the European Economic Area, including, without limitation, Argentina, Australia, Canada, Singapore, and the United States. These countries may have different privacy laws, which, in some cases the India or local Data Protection Authorities, may consider to be less adequate or protective, than the privacy laws in your home country. The SOEPL will ensure, when required by applicable law, that adequate safeguards are in place to protect your personal data where it is transferred to territories outside India. If we share your personal data with third party service providers, we contractually oblige them to comply with applicable data protection laws and to implement adequate safeguards to protect your personal data in accordance with the relevant governing legislation.
Your personal data will not be sold, rented or otherwise made available to third-party marketers or advertisers under any circumstances. SOEPL will not engage in any targeted advertising based on any personal data or information of students acquired because of SOEPL’s Services.
The SOEPL may disclose personal data if it believes, in good faith, that such disclosure is necessary to comply with applicable law, regulatory investigation or inquiries (including economic sanction regulations), to enforce or apply the Terms and Conditions, or to protect the property, rights, or safety of the SOEPL, users of Services, or other third parties.
IV. DATA SECURITY AND STORAGE
To ensure the security and confidentiality of personal data that we collect online, we use strong, industry standard security controls throughout our infrastructure and continually monitor the security status of our systems. In the course of handling your personal data, we implement and maintain reasonable security procedures and practices, including organizational and technical measures that are appropriate to the nature of the personal data and information and protect it from unauthorized access, destruction, use, modification and disclosure. We also take measures reasonably designed to ensure the secure transmission of information from your computer to our servers. Although the SOEPL endeavors to provide a safe environment, please be aware that no security measures are absolute and no data transmission over the Internet can be guaranteed secure.
V. USAGE DATA, INTERNET TAGS and GOOGLE ANALYTICS
Cookies are used to personalize the Services for you and make it easier to use. Cookies remember the language you choose when viewing the SOEPL’s websites and make it easier for you to sign in to and navigate the sites. Cookies also allow the SOEPL to record session information to provide better service to users. This information may be used to help improve the design and performance of the Services site and to help analyze and report on SOEPL site usage.
The SOEPL uses a web analytics tool, Google Analytics, to monitor and evaluate site usage.
VI: RETENTION OF PERSONAL DATA
The SOEPL keeps your personal data for only as long as is necessary for the purposes for which it was collected or as otherwise permitted under applicable law (for example, information relating to a contract with you may be kept for the lifetime of the contract and up to ten years after). After this period, it will be deleted or in some cases anonymised.
You may have the right to object to the processing of your personal data. You may also have the right to complain to aIndian Data Protection Authority if you think we have processed your personal data in a manner which is unlawful or breaches your rights.