We, at ITC School of Laws (ITC), take our responsibilities under the Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Data Protection Policy is designed to assist you in understanding how we collect, use and/or disclose the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data. If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to write/speak to our Data Protection Officer – Mr Subramaniam Thirumeni Telephone number: +65 6238 0377 Email address: [email protected] “Personal information" means information such as your name; mailing address; email address; telephone number; Photographs; or other such personal information that may be supplied by you or collected about you as required by us. We hope that this Policy helps you to understand how we handle and use any personal data after collection. 1. ITC School of Laws will use your personal data from time to time to send you notice about special information, new programmes, and other similar information. 2. ITC School of Laws will not reveal customer information to any external organization unless required by law. However the school will be sharing certain personal information of its Students during the Convocation Ceremony and for certain other types of publicity with its Collaborative Partners (Advance Tertiary College & School of Professional Education and Executive Development (SPEED) The Hong Kong Polytechnic University). 3. ITC School of Laws does not sell, trade or rent your personal information to others. 4. ITC School of Laws understands and respects the privacy of individuals. Personal information is collected with your consent. The purpose for collecting this information varies depending upon your request and will include: helping us to improve our service to you; processing your application and/or registration and/or enquiry; informing you of upcoming events; updating your records in our databases; monitoring and maintaining a copy of your record of academic achievement (including all information arising from investigations of misconduct); planning the provision of educational courses; monitoring and enhancing the provision of educational courses; purposes incidental to each or all of the above. 5. ITC School of Laws compiles this information into a statistical aggregate and uses this information for internal business and administrative purposes which includes improving our products and service offerings, and enhancing our customer service level. 6. ITC School of Laws will be using certain Cookies on our website purely for Remarketing purposes. Please also be aware that we make every effort to respect your choices, however, there is the possibility that not all cookies will be captured. If this is a concern then we would recommend that you change your cookie settings via your browser; your browser help function will tell you how. 7. While the supply of the information by you is voluntary, if you cannot provide or do not wish to provide the information sought, ITC School of Laws may be unable to meet the purposes for which the information was collected. 8. Although every reasonable effort has been made to ensure that all personal information will be so protected, ITC School of Laws cannot be responsible for any unauthorized willful use or misuse of such information and from risks which are inherent in all internet communications. 9. ITC School of Laws reserves the right to change this Policy with or without notice from time to time. If you have any queries or concerns regarding this Policy, please write to the Data Protection Officer, ITC School of Laws. (email: [email protected]) 10. We will keep your information confidential and generally we will only use your information within ITC. However, we sometimes use third parties to provide services on our behalf, for example independent advertising agencies who advertise for us. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA 1. We will take appropriate measures to keep your personal data accurate, complete and updated. 2. We will also take reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. 3. 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. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control. 4. We will also take reasonable efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymized 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. 5. This Data Protection Policy applies only to ITC websites. Our websites may contain links to other websites not maintained by ITC. Such third party websites are subject to their own data protection and privacy practices and you are encouraged to examine the privacy policies of those websites. UPDATES ON DATA PROTECTION POLICY 1. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time. 2. We may amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at www.itc2u.com 3. For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such a request being made. 4. 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. o We will send the corrected personal data to every other organization to which the personal data was disclosed by ITC 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. o We may also be charging you a reasonable fee for the handling and processing of your requests to access and/or correct your personal data, but you will be notified in advance of such costs. 5. For a request to withdraw consent, we will process your request within a reasonable time from such a request for withdrawal of consent being made. Requests for withdrawal of consent may adversely impact your relationship with ITC. We will notify you in advance of such impacts. ADVISORY GUIDELINES FOR THE EDUCATION SECTOR Developed in consultation with the Ministry of Education (“MOE”) and Council for Private Education (“CPE”), these Guidelines aim to address the unique circumstances faced by the education sector in complying with the PDPA. These Guidelines should be read in conjunction with the document titled “Introduction to the Guidelines” and are subject to the disclaimers set out therein. The full text of this advisory note is available at Advisory Guidelines for the Education Sector (published on 11 Sep 2014)