This Privacy statement is intended to describe the practices followed in relation to the GetWise Learning Management System (“Tool”) with respect to the privacy of all individuals whose personal data is processed and stored in the Tool.
- Who manages the Tool?
“EY” refers to one or more of the member firms of Ernst & Young Global Limited (“EYG”), each of which is a separate legal entity and can act as a data controller in its own right. The entity that is acting as data controllers by providing this Tool on which your personal data will be processed and stored is EY Community Impact Services Limited (NZBN 942 903 182 8833). The information you provided is being collected by EY, as a service provider to ASB Bank Limited (NZ 942 903 943 5743) (“ASB”).
EY Community Impact Services Limited has been engaged by ASB to assist in the conduct, management and delivery of the GetWise Tool, services and platform to you.
The personal data you provide in the Tool may be shared by EY Community Impact Services with one or more member firms of EYG (see “Who can access your information” section below).
The Tool is hosted on secure servers in Sydney, Australia and accordingly, the personal information you provide in your use of the tool will be transferred to and stored, overseas (outside of New Zealand) in Australia.
- Why do we need your information?
The Tool is an online portal containing financial literacy learning modules for Year 7 and 8 school students in New Zealand.
Your personal data processed in the Tool is used as follows:
1. To allow you to register for/set up a user account on the Tool’s portal in order to use the services;
2. To allow you to reset your password.
3. To allow you participate in the eLearning modules available through the Tool’s portal; and
4. From the results of your participation in the eLearning modules, extract the evaluation data for manual investigation to create anonymised aggregated reports.
EY relies on the following basis to legitimize the processing of your personal data in the Tool: Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. The specific legitimate interest(s) for the processing of your personal data is to conduct client engagements, part of which includes the provision of the services to you.
The provision of your personal data to EY is optional. However, if you do not provide all or part of your personal data, we may be unable to carry out the purposes for processing.
- What type of personal data is processed in the Tool?
The Tool processes these personal data categories: School name, Class name, Username, Password, Email address, Year level, Answers to pre and post evaluation survey questions, Answers to questions regarding enjoyment and understanding, Student progress.
This data is sourced from users directly when they provide this information upon registration and whilst using the Tool.
Username and passwords are collected, stored and processed for the purposes of setting up accounts for users and for allowing users to access the platform and make use of the services/platform. Email addresses are collected, processed and stored for the purposes of setting up the account and assisting users for password recovery or other administrative or operational purposes only. Email addresses will not be otherwise used for contacting users generally (except in relation to the above administrative or operational purposes).
It is a requirement of the portal and website that a user under the age of 18 must confirm they have obtained consent of a parent or guardian to use the Tool. If you are under the age of 18 and do not have this permission, please do not use the Tool.
- Sensitive Personal Data
Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.
EY does not intentionally collect any sensitive personal data from you via the Tool. The Tool’s intention is not to process such information.
There are free text fields where information can be inserted – please do not insert any unnecessary personal or sensitive information in these sections.
Who can access your information?
Your personal data is accessed in the Tool by the following persons/teams:
- The EY engagement/evaluation team and program team – receives anonymous evaluation data in the form of an exported data file
- EY System Admin personnel – access to the entire system for administrative and operational purposes only. These personnel will not process or use your personal information for any other purpose.
- Teachers – receives information about the progress status (% completed) of students in their class
From time to time, we may also share data with our clients (or other third parties) who may be providing, offering, sponsoring or otherwise assisting in the conduct of, the program you are participating in or expressed your interest to participate in. In relation to the present program, this may include sharing information with ASB, the Client Project Owner.
Personnel at ASB may receive anonymized aggregated data in report format only. No unique or specific personal information about any individuals is provided to ASB.
The access rights detailed above involves transferring personal data in various jurisdictions (including jurisdictions outside the European Union) in which EY operates (EY office locations are listed at www.ey.com/ourlocations). EY will process your personal data in the Tool in accordance with applicable law and professional regulations in your jurisdiction. Transfers of personal data within the EY network are governed by EY’s Binding Corporate Rules (www.ey.com/bcr).
- Data retention
The policies and/or procedures for the retention of personal data in the Tool are:
Data is retained only in line with EY business need
- Common Data: duration of program (currently 2 years)
- Archived Data: duration of program plus 2 years
- Log Data: duration of program plus 2 years
Your personal data will be retained in compliance with privacy laws and regulations.
After the end of the data retention period, your personal data will be deleted.
EY is committed to making sure your personal data is secure. To prevent unauthorized access or disclosure, EY has technical and organizational measures to safeguard and secure your personal data. All EY personnel and third parties EY engages to process your personal data are obliged to respect your data’s confidentiality.
- Controlling your personal data
EY will not transfer your personal data to third parties (other than any external parties referred to in section 6 above) unless we have your permission or are required by law to do so.
You are legally entitled to request details of EY’s personal data about you.
To confirm whether your personal data is processed in the Tool or to access your personal data in the Tool, email your request to firstname.lastname@example.org.
You can confirm your personal data is accurate and current. You can request rectification, erasure, restriction of processing or a readily portable copy of your personal data by contacting your usual EY representative or by sending an e-mail to email@example.com.
If you are concerned about an alleged breach of privacy law or any other regulation, contact EY’s Global Privacy Leader, Office of the General Counsel, 6 More London Place, London, SE1 2DA, United Kingdom or via email at firstname.lastname@example.org. An EY Privacy Leader will investigate your complaint and provide information about how it will be handled and resolved.
If you are not satisfied with how EY resolved your complaint, you have the right to complain to your country’s data protection authority. You can also refer the matter to a court of competent jurisdiction.
If you have additional questions or concerns, call us on 0508 438 9473 or email email@example.com.