Personal Data Protection Notice

Sabah Tshung Tsin Secondary School

 

Sabah Tshung Tsin Secondary School (“STTSS”) respects the Personal Data Protection Act (“PDPA”) 2010, which became enforceable on 15 November 2013, to regulate the processing of personal data of individuals. We are committed to the protection of your personal data and your privacy. In this Personal Data Protection Notice, “we,” “us,” and “our” refer to STTSS, and “you” and “your” include third parties whose personal data you have provided to STTSS.

This Personal Data Protection Notice explains how we collect and handle your personal data, including sensitive personal data, in accordance with the Malaysian Personal Data Protection Act 2010. Please note that STTSS may amend this Personal Data Protection Notice at any time without prior notice and will publish the amended or revised Personal Data Protection Notice on our website or by email.

Note that your sensitive personal data (e.g., your physical or mental health or condition) and your medical data (e.g., patient medical history, diagnostics, allergies) will not be shared or disclosed to any entity unless where you have provided your express written consent.

Please read the following before signing the “Personal Data and Privacy Consent” form indicating your consent to allow STTSS to process your personal data.

  1. Personal data 
  • Type of personal data

Personal data means any data which relates to you or any other third party related to you which was collected or provided to STTSS for the purposes stated in Section 2 below.

We process your personally identifiable data which may include your name, signature, age, gender, student registration number, class, NRIC number, passport number, visa number, date of birth, education, race, religious belief, nationality, ancestry origin, family background, marital status, statutory numbers and statements (income tax and EPF), PTPTN deduction, contact details (addresses, emails, phone numbers), occupation, salary and employment history, graduation certificates, referee’s contact, qualification, immediate family / sibling(s) / children / spouse / guardian / emergency contact data (marital status, name, NRIC number, signature, income tax number, qualification, occupation, employment history, income), medical history or data, allergy, blood type, vaccination record, physical health record, body weight, body measurements,  previous internal / external examination results, academic records, behavioral record, club choice, co-curriculum achievements, testimonials, resume details (personal goals, study plan, personal statement, university transcripts / offer letters), recommendation letters, financial and banking account details, financial status, data regarding your family, relatives or third party that you provide to us, your preferences in relation to activities you enrolled with us, date join STTSS or particular event, data in audio and/or video format (including voice, video recording, closed-circuit television (“CCTV”) and security recording), images (including photographs) and location tracking / GPS data.

  • Source of personal data
  • Student or potential student: STTSS collects your personal data directly from you or indirectly from your parents, guardians and / or previous school management when you, your parents, guardians and / previous school management send us completed enquiry, application and / or registration forms via various means, including online and physical hardcopies at public venues, talks and / or trainings held at STTSS and / or when you, your parents / guardians and / or your primary school management visit our school. Your personal data may also be collected from cookies through the use of our website.
  • Parents or guardians of our student or potential student: STTSS collects your personal data directly from you or indirectly from your child when you send us completed enquiry, application and / or registration forms via various means, including online and physical hardcopies at talks and / or training held at STTSS and / or your previous school and / or when you, your child and / or your previous school management visit our school. Your personal data may also be collected from cookies through the use of our website.
  • Universities or colleges having events, conferences, seminars, talks, fundraising and / or other activities organised by us: STTSS collects your personal data directly from you when you express an interest to be contacted for such events and activities (including contact number and / or NRIC number or during previous events organised by us). Your data may also be collected indirectly (for example, via online directories) or from cookies through the use of our website.
  • Scholarship and / or Financial Assistance donors: STTSS collects your personal data directly from you when you fill out the donation / pledge form via online and / or physical hardcopies. Your data may also be collected from cookies through the use of our website.
  • Vendor, supplier, or service provider: STTSS collects your personal data directly from you or indirectly from your employer or credit reference when tendering for projects or as part of commercial transactions. Your personal data may also be collected from cookies through the use of our website.
  • Employee or potential employee: STTSS collects your personal data directly from you or indirectly from your employer when applying for employment.  Your personal data may also be collected from cookies through the use of our website.
  • Obligatory personal data

All data requested in the relevant forms is obligatory and must be provided by you unless stated otherwise.

Should you fail to provide the obligatory data, we may be unable to process your request and / or provide you with relevant services.

  1. Purposes of collecting and further processing (including disclosing) your personal data
  • Student or potential student: Your personal data is collected and further processed by STTSS as required or permitted by law for various academic, educational, and administrative purposes, including the following:
  • to process your application for admission and financial assistance, and thereafter to ensure continuous provision of academic, financial, and educational services to you (including recording the details of studies), and determining your academic achievements and financial challenges;
  • to provide ancillary services such as visa application and insurance coverage throughout your tenure of study with us;
  • to assist you in further studies placements or attachments with third parties (where such placements or attachments are required and / or requested by you in order to further your studies or advance your career);
  • to administer and communicate with you in relation to our tuition fees and other relevant payments;
  • to manage your use of our facilities and management of our events such as library, student hostel, computing facilities, graduations, and alumni;
  • to operate our campus in a manner that is physically safe, secure, and befitting of health and safety requirements;
  • to process your request for any services related to educational and / or co-curricular activities;
  • to conduct and support analysis of student patterns, choices, and interaction with other students / staff;
  • to create and deliver personalized educational and / or co-curriculum that are unique to you in order to enhance your student experience;
  • to provide you with a more seamless student experience;
  • to support research and innovation of our educational and / or co-curricular activities;
  • to store and carry out data analytics processes;
  • to improve our deliverance of educational and / or co-curricular knowledge;
  • to comply with STTSS legal and regulatory obligations in the conduct of its operation;
  • to contact you regarding upcoming events, competitions, training, talks, seminars, and further studies materials that we feel may interest you*;
  • to send you season greetings, special occasion messages, or other similar communications;
  • to allow third parties to contact you for further studies and / or career opportunities, marketing or promotional campaigns conducted by any third-party entities;
  • to ensure that the content from our website is presented in the most effective manner for you and for your computer and/or device, and
  • for STTSS internal records management.

In particular, religious beliefs are processed for reporting purposes to the Ministry of Education and any other relevant authorities. Medical details are processed to assist you in your study course at STTSS.

  • Parents / guardians of our student or potential student: Your personal data is collected and further processed by STTSS as required or permitted by law and for various academic, educational, and administrative purposes, including the following:
  • to process the student’s application for admission;
  • to process your application for financial assistance;
  • to contact you in the event of an emergency or accident;
  • to inform you about the progress of the students, our tuition fees, and other relevant payments;
  • to provide ancillary services to the students such as visa application and insurance coverage;
  • to process your request for any educational and / or co-curricular services;
  • to conduct and support internal marketing analysis and analysis of parents’ /guardians’ patterns, choices, and engagement with STTSS;
  • to be collected and stored in a central repository that is accessible by STTSS Management;
  • to provide you with a more seamless student experience;
  • to support research and innovation of our educational and / or co-curricular activities;
  • to store and carry out data analytics processes;
  • to improve our deliverance of educational and / or co-curricular knowledge;
  • to comply with STTSS legal and regulatory obligations in the conduct of its operation;
  • to contact you regarding upcoming events, competitions, training, talks, seminars, and further studies materials that we feel may interest you*;
  • to send you season greetings, special occasion messages, or other similar communications;
  • to allow third parties to contact you for further studies and / or career opportunities, marketing or promotional campaigns conducted by any third-party entities;
  • to ensure that the content from our website is presented in the most effective manner for you and for your computer and/or device; and
  • for STTSS internal records management.
  • Event organiser or potential event organiser for services, events, conferences, seminars, and other marketing or promotional activities organised by us: Your personal data is collected and further processed by STTSS as required or permitted by law for the following commercial purposes:
  • to provide you with information, courses, or services that you request from us and any incidental purposes thereto;
  • to contact you regarding services related to educational and / or co-curricular activities;
  • to conduct and support analysis of student patterns, choices, and interaction with other students / staff;
  • to be collected and stored in a central repository that is accessible by STTSS Management;
  • to create and personalized delivery of courses and services that enhance your student experience;
  • to provide you with a more seamless student experience;
  • to support research and innovation of our educational and / or co-curricular activities;
  • to store and carry out data analytics processes;
  • to improve our deliverance of educational and / or co-curricular knowledge;
  • to contact you regarding upcoming events, competitions, training, talks, seminars, and further studies materials that we feel may interest you*;
  • to send you season greetings, special occasion messages, or other similar communications;
  • to allow third parties to contact you for further studies and / or career opportunities, marketing or promotional campaigns conducted by any third-party entities;
  • to notify you about changes to our curriculum, services, and / or fees;
  • to ensure that the content from our website is presented in the most effective manner for you and for your computer and/or device; and
  • to comply with STTSS legal and regulatory obligations in the conduct of its operation; and
  • for STTSS internal records management.
  • Scholarship and / or Financial Assistance donors: Your personal data is collected and further processed by STTSS as required or permitted by law and for STTSS internal records management.
  • Vendor, supplier or service provider: Your personal data is collected and further processed by STTSS as required or permitted by law and to give effect to your requested commercial transaction, including the following:
  • to administer and give effect to the commercial transaction;
  • to process any payments related to the commercial transaction;
  • for internal investigations, audit, or security purposes;
  • to comply with STTSS legal and regulatory obligations in the conduct of its operation;
  • to contact you regarding upcoming events, competitions, training, talks, seminars, and further studies materials that we feel may interest you*;
  • to ensure that the content from our website is presented in the most effective manner for you and for your computer and/or device; and
  • for STTSS internal records management.
  • Employee or potential employee: Your personal data is collected and further processed by STTSS for the purpose of administrating your employment or potential employment which may include but is not limited to the following:
  • to verify your identity;
  • to process employment applications and assess your employability, which may include but is not limited to pre-employment medical checks, and to verify your academic and professional qualification by contacting the school, college, university, institute, and / or professional qualifying bodies;
  • to process payroll and administer matters relating to your benefits and / or compensation;
  • to process and administer matters relating to your career development;
  • to monitor compliance with internal rules and policies of the STTSS;
  • to meet any disclosure requirements or other compliance requirements of any law binding on STTSS or under and for the purposes of any guidelines or regulations issued by regulatory or other authorities with which STTSS is expected to comply;
  • to facilitate potential party of interest in any corporate due diligence exercise;
  • to enforce STTSS’s rights under employment terms or other applicable laws or to defend the STTSS’s rights under the law; and
  • any other purposes relating thereto.

* Where you have indicated your consent to receiving marketing or promotional updates from STTSS, you may opt out from receiving such marketing or promotional material at any time. You may select the “unsubscribe” option provided in STTSS bulk email / SMS or you may contact STTSS at the details provided in Section (6) below.

Data Analytics Processing

We will use your data for analytics and measurement purposes to understand how our course deliverance and services are used, to help improve the curriculum and services we offer, to provide you with more personalized courses and services deliverance, and provide a more seamless student experience. For example, we analyse data about your choice and preferences in relation to the courses, curriculum, and services you enrolled with us to send you targeted information and promotional materials.

  1. Disclosures and transfers of personal data (within or outside of Malaysia)
  • Entities within STTSS

Your personal data provided to us is processed by and disclosed within STTSS for the purposes stated in Section 2 (Purposes of collecting and further processing (including disclosing) your personal data) above.

STTSS will ensure that:

  • access to your personal data is restricted to staff who are contractually required to process your personal data in accordance with their respective job requirements.
  • Classes of third parties

Your personal data may be disclosed or transferred to relevant third parties (within or outside of Malaysia) as required under law, pursuant to relevant contractual relationships, our service providers, or for the purposes stated in Section (2) (Purposes of collecting and further processing (including disclosing) your personal data) above (or directly related to those purposes).

  • Universities, colleges, or other third-party entities

Your personal data (including sensitive personal data) may be disclosed or provided to other third-party entities and their advisers / representatives (within or outside Malaysia) for purposes of any promotional or marketing campaigns conducted by any third-party entities.

  • Student or potential student: Your personal data may be disclosed to the following classes of third parties:
  • The Ministry of Education, other relevant government departments / agencies, statutory authorities, and industry regulators;
  • Any person to whom we are compelled or required to do so under law or in response to a competent or government agency;
  • Malaysian immigration department (including agencies appointed by the Malaysian immigration department to carry out its services) if you are required to obtain or renew your student visa for your tenure of studies with STTSS;
  • Foreign embassies (including agencies appointed by foreign embassies to carry out their services) if STTSS assists you in your visa application as part of your transfer procedure from foreign schools;
  • Your sponsors and / or your guardians;
  • Third parties providing you with attachment placements as requested by you in order to further studies or career advancement;
  • Relevant professional or statutory regulatory bodies or accreditation bodies depending on your course requirements;
  • Law enforcement agencies; and
  • Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretaries, printing companies, telecommunications companies, contractors, conference / training / event organisers, other advisers, travel agencies, recruitment agencies, and insurance companies).

Upon your leaving the school or graduation, we will retain a summary of your personal data indefinitely for our records. Your contact details will be added to our alumni database. The Alumni Office may contact you in the future to keep you up-to-date with the news that may be of interest to you including opportunities to connect with your old classmates and to build up your network for personal and career development. If you wish to opt-out from receiving these updates, select the “unsubscribe” option provided in the email updates sent by the Alumni Office. Please note that the Alumni Office will not disclose your personal data to third parties.

  • Parent/guardian of our student or potential student: Your personal data may be disclosed to the following classes of third parties:
  • The Ministry of Education, other relevant government departments / agencies, statutory authorities, and industry regulators;
  • Any person to whom we are compelled or required to do so under law or in response to a competent or government agency;
  • Malaysian immigration department (including agencies appointed by the Malaysian immigration department to carry out its services) if the student is required to obtain or renew his / her student visa for his / her tenure of studies with STTSS;
  • Foreign embassies (including agencies appointed by foreign embassies to carry out their services) if STTSS assists the student in his / her visa application as part of his/her transfer procedure from foreign schools;
  • Law enforcement agencies;
  • Donors of students’ fees (including donors by organisations or individuals); and
  • Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretaries, printing companies, telecommunications companies, contractors, conference / training / event organisers, other advisers travel agencies, recruitment agencies, and insurance companies).
  • Event organisers / potential event organisers for products, services, events, conferences, seminars, and other marketing activities organised by us: Your personal data may be disclosed to the following classes of third parties:
  • Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretaries, printing companies, contractors, conference / training / event organiser, and other advisers);
  • Law enforcement agencies;
  • Government departments / agencies, statutory authorities, and industry regulators; and
  • Any person to whom we are compelled or required to do so under law or in response to a competent or government agency.
  • Scholarship and / Financial Assistance donor: Your personal data may be disclosed to the following classes of third parties:
  • Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretaries, printing companies, and other advisers);
  • Law enforcement agencies;
  • Government departments / agencies, statutory authorities, and industry regulators; and
  • Any person to whom we are compelled or required to do so under law or in response to a competent or government agency.
  • Vendor, supplier, tenant, or service provider: Your personal datamay be disclosed to the following classes of third parties:
  • Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretaries, printing companies, contractors, conference / training / event organisers, and other advisers);
  • Law enforcement agencies;
  • Government departments / agencies, statutory authorities, and industry regulators; and
  • Any person to whom we are compelled or required to do so under law or in response to a competent or government agency.
  • Employee or potential employee: Your personal data may be disclosed to the following classes of third parties:
  • Third parties contracted by the School to supply goods and / or services related to the purposes set out in Section 2 (vi);
  • School / College / University / Institute / Professional Bodies you studied at or obtained your accreditation to verify your academic qualification;
  • Your referees or persons seeking employee references in order to verify your professional experiences;
  • Statutory bodies if required or authorised to do so to discharge any statutory function, under any law or in relation to any order or judgment of a court;
  • Regulatory bodies or authorities for the purpose of detection or prevention of crime / illegal activities / fraud or for the apprehension or prosecution of offenders, or for an investigation relating to any of these;
  • Any party involved in or related to a legal proceeding (or prospective legal proceeding), for the purposes of the legal proceedings;
  • any other persons to whom the School is under an obligation to make disclosure under the requirements of any law binding on the School or under and for the purposes of any guidelines or regulations issued by regulatory or other authorities with which the School is expected to comply.

Transfer of your personal data outside Malaysia 

It may be necessary for us to transfer your personal data outside of Malaysia if any of the third parties mentioned in section 3 (Disclosure of personal data) above including our service providers or associates who are involved in providing any services to us are located or have processing facilities in countries outside of Malaysia.

You consent to us transferring your personal data outside Malaysia to such third parties and for the purposes set out in section 2 (Purposes of collecting and further processing (including disclosing) your personal data).

We shall take the necessary steps to ensure that any such third parties are contractually bound to protect your personal data and that they can only process your personal data under our instructions.

  1. Websites
  • Links to other sites

Links to other sites are provided for your convenience and information. These sites may have their own privacy statements in place, which we recommend you review if you visit any linked websites. We are not responsible for the content on the linked sites or any use of the site.

  • Location-enabled products or applications

Location-enabled products or applications transmit your location data to us. We do not use the data sent or provided other than to provide the service you request. 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 utilize Google Analytics (or a similar tool) to help us better serve you through improved products, services, and revisions to the mobile applications. This collected data will not identify you to us. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country, and language of download.

  • Cookies

A cookie may be used in the processing of your data. A cookie is a text file placed into the memory of your computer and / or device by our computers. A copy of this text file is sent by your computer and / or device whenever it communicates with our server. We use cookies to identify you. We may also collect the following data during your visit to our website and/or the fully qualified domain name from which you accessed our site, or alternatively, your IP address:

  • the date and time you accessed each page on our website;
  • the URL of any webpage from which you accessed our site (the referrer); and
  • the web browser that you are using and the pages you accessed.

Some web pages may require you to provide a limited amount of personal data in order to enjoy certain services on our websites (system login credentials, email address, contact, etc.). This personal data will only be used for its intended purposes only, i.e., to respond to your message or deliver the requested services.

  1. Right to access and correct personal data

You have the right to access and correct your personal data held by us (subject always to certain exceptions). You have the right to limit, stop processing, and disclosure of your personal data for any other purpose other than stated in Sections 2 and 3 above.

You are responsible for providing accurate, not misleading, complete, and up-to-date personal data of yourself and any other person whose personal data you provide to the School.

You are also responsible for updating and / or correcting such data when it becomes inaccurate, incomplete, misleading, and out-of-date by obtaining and submitting a “Personal Data Correction Form”.  Personal Data Correction Form is available on our website, referred to the link: https://www2.sttss.edu.my/wp-content/uploads/2023/01/STTSS-PERSONAL-DATA-CORRECTION-FORM-20221221.pdf

Pursuant to the Act, we reserve the right to withhold access to your personal data under certain situations, that is, when we are unable to validate your identity, or where you were not specific about the data you require, or in the event of we receive vexatious / frivolous / repeated / unreasonable requests for data. Nevertheless, we will notify you of the reason(s) for not being able to attain your request.

The School reserves the right to review and/or amend this Notice from time to time and will communicate such changes via email, memo and / or other appropriate communication means as may be determined by the School

  1. Security and Retention of Personal Data

The School is committed to keeping your personal data safe and secure.  The School has appropriate technical, administrative, and physical procedures in place to protect your personal data from loss, theft, and misuse as well as against unauthorised access, disclosure, alteration, and destruction.  All personal data whether in hard copy documents / files or stored on a server or any physical device will be kept in a secure environment (locked cabinets / drawers within a locked room) with controlled access.

For electronic personal data, access to all data and server rooms that contain hardware and software storing personal data is restricted to authorised personnel only.  All access to software programs containing personal data will be protected from unauthorised access and entry using passwords defined by user group / level, firewall technologies, anti-virus and encryption software.

  1. Limiting the processing of personal data, further enquiries, and complaints

If:

  • you would like to obtain further information on how to limit the processing of your personal data;
  • you have any further queries; or
  • you would like to make a complaint in respect of your personal data, you may contact:

088-254 154 or email to sttss_admin@sttss.edu.my

  1. Conflict

In the event of any conflict between this English language Personal Data Protection Notice and its corresponding Bahasa Malaysia Personal Data Protection Notice, the terms in this English language Notice shall prevail.

This Personal Data Protection Notice was last updated on 21 December 2022.

 

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