Privacy Policy
This document outlines the guidance for obtaining the informed consent and for providing the notice for collecting and processing the Personal / Sensitive Personal Data. MSB Training Consultancy (hereafter referred to as “we” or “our” or “us” or “MSB” or “organization”) shall obtain informed consent and shall provide notice to Data Subjects for collecting and processing the Personal / Sensitive Personal Data
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Definition
- Personal Data: Any information relating to a Data Subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that Data Subject. This may also include photographs and/or video footage taken during events or for a specific purpose.
- Sensitive Personal Data: Data that reveals the Data Subject’s racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or data concerning your health.
- Processing: Processing is any operation or set of operations which is performed on personal / sensitive personal data or on sets of Personal / Sensitive Personal Data , whether or not by automated means, such as collection, recording, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Scope & Limitation
This document relates to MSB Training Consultancy and entities which alone or jointly determine the purpose and means of the processing of personal / sensitive personal data of Data Subjects. This document applies to all stakeholders involved in dealing with, transacting with, and enrolled in any capacity with MSB Training Consultancy
Data Privacy Principles
In handling Personal / Sensitive Personal Data as a DC, MSB Training Consultancy Stakeholders must abide by the following ten key principles:
- Transparency: MSB Training Consultancy will ensure transparency through authorized dissemination and usage of Digital Data and PMI’s literature.
- Purpose limitation: MSB Training Consultancy will only process Personal Data for the purposes (i) set out in any notice made available to the relevant individuals; (ii) as required by law or (iii) where consented to by the relevant individuals.
- Data quality and proportionality: Personal / sensitive personal data should be kept accurate and where necessary, up to date. The Personal Data that MSB Training Consultancy holds must be adequate, relevant and not excessive for the purposes for which they are collected and should only be retained for as long as necessary for the purposes of the relevant processing.
- Security and confidentiality: Reasonable precautions must be taken to secure Personal / Sensitive Personal Data against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access. These precautions should include technical, physical and organizational security measures, such as measures to prevent unauthorized access, that are commensurate with the sensitivity of the information and the level of risk associated with the processing of the Personal / Sensitive Personal Data.
- Rectification, object, blocking and erasure: Individuals may lodge a request accompanied with proof of identity to MSB Training Consultancy to rectify, object, block or erase Personal Data upon request where it is inaccurate or where it is being used contrary to these key principles. An individual should be able to object to the processing of the Personal/sensitive personal data relating to them if there are compelling legitimate grounds relating to their particular situation, to the extent required by relevant laws.
- Sensitive data: Where MSB Training Consultancy processes Sensitive Personal Data, they will take such additional measures (e.g., relating to security) as are necessary to protect such Sensitive Personal Data in accordance with the applicable law(s).
- Data used for marketing purposes: Where MSB Training Consultancy processes Personal Information for the purposes of direct marketing, it shall have effective procedures allowing individuals at any time to “opt-out” from having their Personal Data used for such purposes.
- Automated processing: Where MSB Training Consultancy processes Personal Data on a purely automated basis that has a significant impact on an individual, it shall give the individual the opportunity to discuss the output of such processing before making those decisions (save to the extent otherwise permitted under applicable law).
- Data minimization: Where MSB Training Consultancy retains an individual’s Personal Data, it will do so in a form identifying or rendering an individual identifiable only for so long as it serves the purpose(s) for which it was initially collected or subsequently authorized except to the extent permitted by applicable law;
Code of Conduct/Ethics Principles
This Code of Conduct/ Ethics applies to all Board Members, officers, full-time and part-time employees, contractors, volunteers and all third parties of MSB Training Consultancy by virtue of their roles and responsibilities within the organization. They have a special duty to observe the highest standards of personal and professional conduct.
MSB Training Consultancy requires all relevant stakeholders to comply with the following principles:
- safeguard privacy rights and confidential information related to personal data of every individual;
- follow the letter and spirit of the laws and privacy regulations affecting the organization;
- actively encourage colleagues to join us in supporting the privacy laws and regulations and the standards of conduct in these Principles.
Security Measures for Personal/Sensitive Data
MSB Training Consultancy’s organizational security measures aim to maintain the availability, integrity and confidentiality of personal data and protect them against natural dangers such as accidental loss or destruction and human dangers such as unlawful access, fraudulent misuse, unlawful destruction, alteration and contamination. Access to personal information is restricted to qualified and authorized personnel only who hold the information with strict confidentiality.
At the other end of the spectrum, wherever the client, students and other stakeholders that are seeking coaching, training or lessons from MSB Training Consultancy as an ATP will have full access to their own personal/sensitive data at any point In time, and can always disclose and provide disclaimer wherever they are sharing personal, confidential or sensitive information from their own organizations, personal lives or personal digital or knowledge assets that they would intend to keep confidential and only within the boundaries of the classroom.
MSB Training Consultancy would ensure that such students and clients seeking services would (even without providing disclaimer for knowledge secrecy) would be satisfied pre-emptively that such information (whether shared knowingly or unwittingly) would be kept confidential in order to protect the interests of the students or clients in the highest manner of integrity and mutual respect.
Confidentiality & Data Privacy Protection
Wherever Literature, reading material, artifacts, templates or any sensitive and confidential learning material is shared at any point with full authorization from PMI-USA and its related bodies, a confidentiality clause in an NDA would be signed off by the students in the context of coaching, training and lessons. The NDA would contain all contractual obligations under the guidelines of PMI-USA and which part of its information is highly confidential and sensitive and must be only discussed and disseminated within the classroom setting under authorized PMI ATP (Authorized Training Partner) boundaries.
All data provided by PMI-USA to MSB Training Consultancy would be under the assumption of goodwill and trust between the two entities, therefore records of processing and data inventory in cases such as purchase of Digital Data from PMI-USA for any given course that is being taught by the ATP would be always available in digital form to be presented as evidences of legal purchase at a given point in time with all dues paid or no liabilities pending from either the customer or MSB Consultancy.
Likewise, the customers in the form of clients and students will have ongoing, immediate and everlasting access to records of processing transactions that involve external parties including but not limited to PMI-USA and its related entities in the context of digital data, course exams or any other kind of special literature or product that is authorized by PMI-USA with MSB Training Consultancy and other training institutes as intermediaries.
MSB Training Consultancy utilizes the best kinds of practices and approaches to ensure data privacy for both our clients and students and PMI-USA.
Any breach or possible breach of data (private or near-private) would be reported immediately after incident identification through the following process:
- Subject or stakeholder is looped in and reached out immediately.
- Subject is notified about breach or possible breach of secure data.
- PMI-USA is also informed regarding the data breach while keeping PMI-USA updated regarding the developments in real time.
- Criticality of the data at breach is analyzed and evaluated in real time.
- Legal and external information security teams are involved to ensure that impact breach is mitigated.
- If possible, then root cause is identified and PMI-USA is informed of the root cause in order to ensure that MSB Training Consultancy plays a responsible role of an Authorized Training Partner
Non-Compliance
- MSB Training Consultancy expects all employees to comply with this Policy and supporting or associated policies.
- Failure and/or refusal to abide by this policy may be deemed as misconduct and may result in an investigation and / or disciplinary action against an associate, grounds for termination of a contract, or refusal by MSB Training Consultancy to enter into a contract.
- It may also result in legal action against the employee and any other applicable third party.
- If any provision of this Policy is rendered invalid under law, such provision should be deemed modified or omitted to the extent necessary, and the remainder of this Policy should continue in full force and effect
