Privacy

University Village only collects personal data that is necessary for, or directly related to, one or more of University Village’s functions or activities. The term “you” or “your” in this Privacy Collection Notice extends to any individual whose personal data has been provided to University Village that includes current students, prospective students, past students, job applicants, benefactors, research participants, external contractors/suppliers, and directors/shareholders of the external contractors/suppliers. While University Village normally collects corporate information from the third party or external contractors/suppliers (e.g. company bank details, business registration certificate number, business tax ID, capital structure information, financial statement), there are cases where University Village collects personal data of the involved personnel from the supplier company.

The personal data that University Village collects and processes from you may include (depending on the services provided and accessed):

• names and other related contact details of the individuals;
• Identification Numbers and official university email addresses;
• emergency contacts;
• photographic identification;
• academic qualifications, history and progress;
• information relating to entitlements to related educational government payments or support (e.g. PTPTN, JPA, MARA);
• information relating to non-government sponsorship, study loan and industrial award;
• complaints or misconduct details or information;
• if engaging any health service, information necessary to deliver that service (e.g. medical history);
• other related personal data required for the effective management of the university.

Please inform the involved personnel about this Privacy Collection Notice, the terms of which would also apply to them and please ensure that their consent is first obtained before their personal data is disclosed to us for the purpose set out in this Privacy Collection Notice. In addition, in some situations, you may give us personal data about someone else (e.g. when you provide the personal data about a referee to validate your past company track record). In such situation, please also inform the other individuals about this Privacy Collection Notice and please ensure that his or her consent is first obtained before their personal data is disclosed to us.

University Village generally collects information at enrolment or at the evaluation of your job application or commencement of employment, at the evaluation of your service proposal or commencement of contract, when you access University Village’s IT systems, or when you participate in special activities or projects. Some special projects or activities may have their own collection notice which is in addition to the information contained in this general collection statement (e.g. when accessing counselling services or using University Village’s IT services).

University Village will not collect sensitive information unless:

• you consent to the collection, and the information is reasonably necessary for, or directly related to, one or more of University Village’s functions or activities; or
• the collection of the information is required or authorised by or under a Malaysian law or a court/ tribunal order; (e.g. when providing Government Student Support); or
• the information is necessary to provide health services to you; or the information is necessary to process your contract.

Some of the main reasons University Village collects your information includes:

• to correspond with you;
• for administrative purposes;
• for the purposes of undertaking university-commissioned research;
• for the facilitation of student elections;
• to meet legal obligations;
• to inform you about your course or other university courses/ events; to confirm your entitlement to a scholarship;
• for government reports;
• to verify your internal/ external grants/ scholarships
• for performance management;
• to process your service proposal with University Village (e.g. reference check);
• to track the provision of your goods and services entitled to us.

What if I study a University Village course, program or unit through a third party?

If you study a University Village course, program or unit through a third party, such as partner or joint venture providers, other service providers or education providers, your personal data may also be collected and used by such third parties in accordance with their privacy statements.

What happens if I elect to not provide my information?

Generally, you may elect to not provide University Village with your personal data; however, much of the personal data collected by University Village is necessary to provide you with educational services, access to government support or for the fulfilment of your contract. Without this information, University Village may be restricted in its ability to provide these services or support, to perform these contract-related activities or to process our payment to you. In some cases, enrolment at University Village will not be possible without certain information provided.

University Village will only collect personal data by lawful and fair means.

University Village will generally collect personal data from you directly, unless:

you consent to the collection of the information from the related individuals in which the individuals are also subjected to Privacy Collection Notice; or University Village is required or authorised by, or under, a Malaysian law, or a court/ tribunal order, to collect the information from someone else; or it is unreasonable or impracticable to get the information from you directly. University Village stores personal data in both electronic and hard copy forms, and must comply with the retention requirements of the University Personal Data Protection Policy and Procedure.

Before University Village discloses personal data about you to a person (the overseas recipient):

• who is not in Malaysia or an external Territory; and
• who is not in University Village network of Universities or an individual from University Village;

University Village will take such steps as are reasonable in the circumstances to ensure that the overseas recipients also adhere to the Personal Data Protection Act or similar Act in their countries in relation to personal information.

For research students whose supervisor or examiner is located in a country other than Malaysia, your personal data may be sent electronically or through the mail to that individual in that country.

Some University Village IT systems use cloud computing services and are hosted in countries other than Malaysia. Depending on the service accessed this could include selected countries in the Americas, Europe or Asia-Pacific region.

If University Village holds personal data about you that was collected for a particular purpose (the primary purpose), University Village will not use or disclose this information for another purpose (the secondary purpose), unless:

• you consented to the use or disclosure of the information; or
• you would reasonably expect University Village to use or disclose the information for the purpose other than the primary purpose that may or may not be apparent to the individual concerned, or within his or her reasonable expectations.

External organisations

Information collected may be disclosed to various organisations, including:

• government departments such as MYRA and MASTIC, the Ministry of Higher Education, regulatory agencies, statutory authorities (e.g. EPF, SOCSO, IRB, BAITUMAL, Immigration statistical and reporting, Department of Statistics, MDC, MQA, etc.) as well as related accreditation bodies;
• External organisations such as professional bodies, hospitals or government agencies, in connection with your studies;
• third parties, such as partner or joint venture providers, other service providers or other education providers, in circumstances where you study a University Village course, program or unit through such third parties. Your information may be disclosed for the purpose of improving the delivery of your University Village course, program or unit. (such as auditors, recruitment agencies, insurance companies, printing companies, telecommunication companies, conference/training organisers)
• Malaysian Immigration Department and foreign embassies for the purposes of student visas and work permits;
• Foreign government departments/agencies or authorities if you are registered with a foreign credited programme or sponsorship;
• Your education sponsors.

Direct marketing

University Village may use or disclose personal data (other than sensitive information) about an individual for the purpose of direct marketing if:

• University Village collected the information from the individual; and
• the individual would reasonably expect University Village to use or disclose the information for that purpose; and
• University Village provides a simple means by which the individual may easily request not to receive direct marketing communications from University Village; and
• the individual has not made such a request to University Village.

University Village may use or disclose sensitive information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose.

Emergency situations and criminal activity:

University Village may disclose your information for a secondary purpose if it reasonably believes that the use or disclosure is necessary to lessen or prevent:

• a serious and imminent threat to an individual’s life, health, safety or welfare; or
• a serious threat to public health, public safety or public welfare.

University Village may disclose health information for a secondary purpose where it has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the health information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities and, if University Village, would not be breaching confidence by such use or disclosure.

University Village may disclose health information for a secondary purpose where it reasonably believes that the use or disclosure is reasonably necessary for a law enforcement function by or on behalf of a law enforcement agency and, if University Village, would not be breaching confidence by such use or disclosure.

University Village will take such steps (if any) as are reasonable in the circumstances to ensure that the personal data that it uses or discloses is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.

Subject to an overriding legal consideration, if University Village holds personal data about an individual, University Village will, on request by the individual, give the individual access to the information. Information can be requested from University Village Student Operations (for students) or from University Village Finance (for suppliers) using the Personal Data Access Request Form.

University Village University may require an individual to pay a fee in relation to their request to access their personal information. The fee will be set at the rate prescribed by the Personal Data Protection (Fees) Regulations 2013.

Under University Village’s Personal Data Protection Policy and Procedure, University Village is not required to give you access to your personal data if:

• University Village reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
• giving access would have an unreasonable impact on the privacy of other individuals; or
• the request for access is frivolous or vexatious; or
• the information relates to existing or anticipated legal proceedings between University Village and the individual, and would not be accessible by the process of discovery in those proceedings; or
• giving access would reveal the intentions of University Village in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
• giving access would be unlawful; or
• denying access is required or authorised by or under an Malaysian law or a court / tribunal order; or
• University Village has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to University Village’s functions or activities has been, is being or may be engaged in AND giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
• giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
• giving access would reveal evaluative information generated within University Village in connection with a commercially sensitive decision-making process.

Your right of correction

If University Village holds personal data about you and University Village is satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, or, you request University Village to correct the information, University Village will take such steps (if any) as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. Information can be corrected using the Amendment to Personal Details Form (for students) or by contacting University Village Finance at proc.fin@uvillage.education (for suppliers).

If you believe that University Village has breached privacy laws, within six (6) months of the time you first became aware of the apparent breach, you may either:

• Lodge a written complaint with yourfeedback@uvillage.education; or
• For suppliers, contact University Village Finance, proc.fin@uvillage.education; or
• For any other privacy matters, contact University Village’s Privacy Officer, Mr Tan, evgan@uvillage.education, 02-6260 727.

Your complaint will be reviewed and managed as set out in the People, Culture and Integrity Policy, available and searchable at http://www.universityvillage.education/about/leadership-governance/policies-regulations/policies/people-culture-integrity/integrity/.