Privacy at KYS
Business School
Our mission at the KYS Business
School (“the College”) is to be a “To be a centre of excellence in nurturing
Malaysia’s future business leaders and captains of industry through strategic
international partnerships.”
Our mission will not be
achieved without collecting and processing personal information about our
prospective, current and former students, and about our donors and friends. We understand
that our champions will only relinquish control of their personal information
if they trust us to use it responsibly and treat it with care and respect.
Individuals from Malaysia and
all over the world come to Malaysia to learn with us, and so we collect and
process their personal information. For this reason, we have developed a
privacy framework that recognises the fundamental privacy concepts that
underpin all privacy regimes:
·
Data minimization – we will collect and retain only the personal information we
really need to meet our lawful purposes
·
Transparency – we will always be open with individuals about the personal
information we collect and how we process it
·
Security – we take all reasonable steps to ensure that personal information
is protected against loss or unauthorised processing
·
Use limitation – we use and share personal information only in the ways we say we
will, and only where necessary to meet our lawful purposes
·
Rights focused – we will ensure that people can exercise their important privacy
rights, including to access and correct their information
This privacy statement explains
what information we collect about the individual we deal with and how we
process it. We are the data controller, which means that we determine the
purposes for, and ways in which, we collect and use personal information. We
also use third party data processors.
The personal information we collect and how we process it
·
Students
·
Alumni and friends
·
Donors
·
Website
Accessing and controlling your personal information
·
Getting a copy of your information
·
Correcting or deleting your
information
·
Managing how we use your information
·
Making a complaint
The personal information we collect and how we process it
We collect personal information
in a number of ways, depending on where you are in your journey with us. To
make this privacy statement easier to follow, we have explained the way we
collect, use and share personal information at each phase of the College
journey:
·
Students – data we collect as part of the application and enrolment
processes and during your study or research
·
Alumni and friends – data we collect about our former students and friends of the College,
which includes current and former employees
·
Donors – data we collect about our potential and actual donors
·
Website – data we collect about anyone who visits our websites
Students
We collect and process personal
information about prospective and current students for the primary purposes of
considering applications for admission to the College, enrolling successful
applicants and administering programmes of study.
Our lawful bases for collecting
and processing personal information in these ways are to meet our obligations to students as their tertiary
education provider and to meet our legitimate
interests, including making sure our services
are fit-for-purpose and are delivered in a way that meets Malaysia’s and New
Zealand’s educational standards and keeps our students and staff safe.
The information we collect about students
We may collect personal
information when you provide it to us directly – for example during the
pre-application, application and enrolment processes – from third parties
(usually with your consent) – for example where we need to verify previous
study at other institutions – or when you generate personal information by
using our services.
If you choose not to provide
any of the personal information requested, it may not be possible for the College
to consider you for admission, enrol you, or properly deliver the services you
have requested from us.
The personal information we
collect about you as a student will include:
·
biographical details (including name,
former name, alias, gender and date of birth)
·
contact details (including address,
telephone, email, and emergency and alternative contact details)
·
education record and academic history
·
citizenship or residency information
·
country of origin and ethnicity
·
COVID-19 vaccination and test
information
·
interactions and communications with
us and our systems
·
information about your study,
including your academic achievement and any other assignments you complete
·
feedback on courses you provide to us
as part of a survey
·
information about your suspension
from any other Malaysia tertiary education provider
·
photograph (for student ID cards),
and
·
other information that you decide to
share with us
In addition, depending on your
programme of study or involvement with specific services that we offer, we may
also collect:
·
information about your areas of study
interest
·
passport and visa details
·
information about your English
language proficiency
·
health and disability information
(including where you use student health, counselling, disability,
accommodation, or recreation services, or where you have applied for a field
trip, student exchange or study abroad programme).
·
financial information (including
information about payment for study, such as credit/debit card or bank account
details)
·
criminal convictions (if necessary
for certain programmes or work placements) , and
·
information provided through
reference checking processes for accommodation or other benefits
We may also collect personal
information about you as you use our services and participate in campus
life.
How we use your information
In order to meet the primary
purposes set out above, we will use your personal information in the ways set
out below. We will generally only use personal information in these ways. Where
we need to use information in a way we have not anticipated here, we will only
do so if required or permitted by law.
We will use your personal
information to:
·
correspond with you
·
inform you about your courses and
other aspects of admission, enrolment and study
·
inform you of the availability of
scholarships
·
inform you about opportunities to
engage with and support the College
·
facilitate and enable programmes relevant
to your enrolment (such as cross institutional study, student placements, internships,
and industry experience)
·
facilitate and allow you to
participate in activities relevant to your enrolment that support your academic
achievement
·
facilitate and enable community
engagement, work-integrated learning activities and student-to-student learning
·
facilitate and enable international
experiences and perspectives through study abroad
·
facilitate and enable scholarship
programmes for which you may be eligible
·
provide associated services such as
security, parking, information technology and (where used by
you) residential or sport and recreation services
·
on programme completion, place your
details on the College's alumni database so that you may be kept informed of
alumni news, events and activities
·
assist you in the event of an
emergency
·
conduct benchmarking, analyses,
quality assurance and planning in respect of the products and services we offer
·
support our academic integrity and
discipline processes, and the overall integrity of the tertiary education
system
·
maintain relationships with schools
·
after your enrolment with College
ceases, contact you for the purpose of seeking your feedback in relation to
benchmarking, analyses, quality assurance and planning activities
Data analytics and automated processing
We analyse data, including
personal information, to drive and improve many of our processes and services.
We also use automated processing tools to assist us to make better decisions on
some services (often driven by data analytics), and to manage some course
administration processes.
How we share your information
We may need to share
information to deliver the services you have requested from us, to meet our
legitimate interests, or to comply with contractual, government or regulatory
requests or reporting requirements. Where we need to share information with an
agency we have not anticipated here, we will only do so if required or
permitted by law.
We may share your information
with:
·
government agencies, such as the
Ministry of Higher Education, the Malaysia Inland Revenue, the Ministry
of Internal Affairs (including Immigration Malaysia) and the Ministry of
Foreign Affairs.
·
other tertiary education providers,
with which the College has entered into a joint venture or other contractual
arrangement, such as a conjoint study arrangement, including where
required to enable other providers to meet their legislative obligations
·
other tertiary education providers
where we believe that you may have engaged in dishonest activity, such as
providing false or falsified admission documents
·
scholarship providers
·
agencies involved in quality
assurance and planning for higher education, such as the Malaysia Qualifications
Agency for Malaysia Universities
·
external agencies, such as former
employers, secondary schools, other tertiary education providers, and tertiary
admission centres to verify your qualifications or experience
·
contracted service providers which
the College uses to perform services on its behalf (such as application, recruitment
and course administration, banking, mailing services, advertising agencies,
logistics and IT service providers), within and outside Malaysia
·
affiliated agencies, such as clubs or
associations, in order to meet the purposes set out above
·
other students (for example, where we
share lecture recordings with the other students who attended the lecture)
·
on your graduation, with the public
via our online graduate database (which lists your name and degree details), to
support the integrity of the tertiary education system
·
if requested after your graduation,
with your former secondary school, as part of our efforts to maintain
relationships with schools
·
the College's legal advisers or other
professional advisers and consultants engaged by the College, and
·
in the event of an emergency, police,
medical or hospital personnel, civil emergency services, your legal
representative or nominated emergency contact person, or any other person
assessed as necessary to respond to the emergency
Your name, date of birth, and
residency will be included in the College Student Index, and will be used in an
Authorised Information Matching programme.
If we need to share your
information with a third party that is overseas, such as another tertiary
education provider, we will ensure that this complies with principles of Personal Data Protection Act 2010 (“PDPA”). If
the third party is not located in a country that has comparable privacy laws to
ours, we will require them to agree to protect your information to Malaysia
standards.
Alumni and friends
We collect and process personal
information about our alumni (former students and employees) and friends
(anyone, who has a direct interest or relationship with us, or the potential to
develop one) for the primary purpose of connecting you with the College and
other alumni.
Our lawful basis for collecting
and processing personal information in this way is to meet our legitimate interests, including in making sure we
can maintain our community, communicate with our alumni and friends and promote
College services and events. We do not rely on consent to communicate with our alumni
and friends, as we believe this community is integral to the success of the College.
However, you can opt out of
these communications at any time by informing our Student Admission Department.
The information we collect about alumni and friends
We may collect personal
information when you provide it to us directly – for example when you update
your details, connect with us on social media or register to attend events – or
from third parties (usually with your consent) – for example from publicly
available sources or other agencies that support the College.
If you choose not to provide
any of the personal information requested, it may not be possible for the College
to keep you connected with us and other alumni.
The personal information we
collect about you as an alumnus or friend is initially that which you provided
as a student and may include:
·
biographical details (including name,
former name, alias, gender and date of birth)
·
contact details (including location,
address, former addresses, telephone, email, social media and website links,
and contact preferences)
·
education record and academic history
(including your associations with us if you were a student)
·
ethnicity
·
interactions and communications with
us and our systems
·
responses to our electronic
communications (including what you open or click on, any comments you make, and
your location), and
·
events you have been invited to and
whether or not you have responded or attended
In addition, we may also
collect the following information about you:
·
anyone we link to you, including your
spouse, partner or adult children, who are also alumni or friends
·
links with other organizations and
individuals (including alumni, friends or donors)
·
employment and business details
including positions, organisation, professional memberships and qualifications
·
career highlights and other lifetime
achievements
·
outside interests and membership of
groups
·
media articles, and
·
any other information that you have
decided to share with us
How we use your information
In order to meet the purpose
set out above, we will use your personal information in the ways set out below.
We will generally only use personal information in these ways. Where we need to
use information in a way we have not anticipated here, we will only do so if
required or permitted by law.
We will use your personal
information to:
·
correspond with you, including
re-establishing contact when we appear to have lost touch
·
provide you with any services you
have requested from us, including events or sport and recreation services
·
inform you about College courses or
events
·
inform you about, and provide, alumni
and friends benefits
·
inform you about opportunities to
engage with and support the College
·
conduct benchmarking, analyses,
quality assurance, and planning to improve alumni and friend services
·
assist you in the event of an
emergency
·
comply with contractual or
legislative reporting and recordkeeping requirements and our obligations under
the Personal Data Protection Act 2010 (“PDPA”)
We use Facebook Custom
Audiences to target our advertising. This allows us to provide a better online
experience and connect with our alumni and friends in ways that are relevant
and meaningful. If you would like to opt out of this, please contact us.
How we share your information
We may need to share
information to deliver the services you have requested from us, to meet our
legitimate interests, or to comply with government or regulatory requests or
reporting requirements. Where we need to share information with an agency we
have not anticipated here, we will only do so if required or permitted by law.
We may share your information
with:
·
College owned or related entities
·
contracted service providers which
the College uses to perform services on its behalf (such as mailing services,
advertising agencies, logistics and IT service providers), within and
outside Malaysia
·
affiliated agencies, such as clubs or
associations, in order to meet the purposes set out above
·
in the event of an emergency, police,
medical or hospital personnel, civil emergency services, your legal
representative, or any other person assessed as necessary to respond to the
emergency
·
the College's legal advisers or other
professional advisers and consultants engaged by the College, and
·
government agencies, where permitted
or required by law
If we need to share your
information with a third party that is overseas, we will ensure that this
complies with principle of Personal Data Protection Act 2010 (“PDPA”). If the
third party is not located in a country that has comparable privacy laws to
ours, we will require them to agree to protect your information to Malaysia standards.
Website
We collect and process personal
information about users of our websites for the primary purposes of delivering
any services or functionality requested by users and for improving the online
experience for our users.
Our lawful basis for collecting
and processing personal information in this way is to meet our legitimate interests, including making sure we can
properly deliver online services.
The information we collect about website users
When you visit our websites and
use any of our web-based services, the personal information we collect about
you includes:
·
computer's internet (IP) address
·
your domain name
·
the date and time of your visit to
the site
·
the pages you accessed and documents
you downloaded, including on third-party sites that are affiliated with us
·
the site you visited immediately
before you visited our site, that linked you to our site
·
the type of browser and operating
system you are using, and
·
the username entered if accessing a
restricted site
We may use “cookies” to show
you advertisements related to the College as you visit third party sites across
the internet.
We also collect personal
information when you use our wi-fi network.
How we use your information
In order to meet the purposes
set out above, we will use your personal information in the ways set out below.
We will generally only use personal information in these ways. Where we need to
use information in a way we have not anticipated here, we will only do so if
required or permitted by law.
We will use the information we
collect about your use of our websites or web-based services to:
·
provide you with a personalised
online experience without requiring you to remind us of your preferences each
time you return to our websites
·
target our advertising using services
such as Google Adwords and Google Analytics (this is a way for us to connect
with visitors, based on their past interactions with the College’s websites)
·
aggregate your interactions with us
across the devices that you use to access our services, and
·
analyse and optimise College websites
and systems use and perform system administration tasks
We share the personal
information we collect about website users only with the third-party service providers
– such as Google – that provide us with advertising and other online services.
How we store and protect your personal information
We may use third-party service
providers to store your personal information and provide us with services. This
means that we may transfer personal information, or access it from, countries
other than Malaysia.
We recognise that we are
accountable for your personal information wherever it is in the world. Where we
can, we will send personal information only to countries that have adequate
privacy laws in place (such as Malaysia or New Zealand). However, where we
cannot do this, we take reasonable steps to ensure that any third-party service
providers we use can meet our privacy and security expectations.
We retain your personal
information only for as long we need it to perform our contractual obligations
or meet our legitimate interests, or comply with our legal obligations,
including the requirement to retain information in accordance with the Personal
Data Protection Act 2010 (“PDPA”).
Wherever your personal
information is stored, we take reasonable steps to ensure that it is protected
against loss or unauthorised access, modification, use or disclosure.
Accessing and controlling your personal information
You have some important privacy
rights, including the right to know what information we hold about you and the
right to correct it. Sometimes, you can also ask us to delete or stop using
your personal information in a particular way. You can exercise any of these
rights by:
·
calling us on +60 6 253 0640
· emailing us at kysbswebmaster@gmail.com
Please note that we need to
take steps to make sure you are authorised to make requests about personal
information, so we may need to verify your identity or authority before
responding to your request. Once we’ve verified who you are, we’ll try to
respond to your request or query as soon as possible, and no later than 14
working days after we receive it.
Getting a copy of your information
You have the right to request a copy of your personal information.
We’ll be as open as we can with you but sometimes we might need to withhold
personal information, for example where the information is legally privileged,
commercially sensitive or includes personal information about other people. If
we need to withhold information, we’ll tell you why.
Correcting or deleting your information
If you think any of the
personal information we hold about you is wrong, you can ask us to correct it. Where we’ve retained your
personal information for purposes that are not directly related to the
performance of a contract or to our legitimate interests, you may be able
to ask us to delete it, but note that we must retain certain information under the Personal
Data Protection Act 2010 (“PDPA”).
If we can’t correct or delete
your information (for example, where we don’t agree that it’s wrong, or we need
the information for a lawful purpose), we’ll tell you why. You can ask us to
attach your correction request to the information as a statement of correction.
Managing how we use your information
Where we’re processing your
personal information on the basis of consent, you can revoke your consent at any time. Where we’re processing
your personal information on the basis of our legitimate interests (such as
improving our services), including automated processing, you can object to this. If you believe we’re using your
personal information in ways that are unlawful, or if we’re continuing to use
information that you think is inaccurate, you can ask us to restrict this processing.
Making a complaint
If you have any concerns about
the way we’ve collected or processed your personal information, let us know, so
we can try to put the matter right.