Putra Business School’s Personal Data Protection Act (2010) Policy Notice

Personal Data is defined by the PDPA 2010 as any information in respect of commercial transactions, which—
(a) Is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose
(b) Is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
(c) Is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system, that relates directly or indirectly to a data.
The data collected could be dependent on your relationship with us, you could be a prospect student, existing students , alumnus, permanent staff, contractual staff, vendor, service provider, donor or contributor or any person/persons or organization relating to us.
In a nutshell, it refers to your personal information and may include your name, contact details, religious belief, passport particulars , banking account information, telephone contact, medical details, dietary preference, previous examination results, academic records, information in audio and/or video format (including voice, video recording, closed-circuit television (“CCTV”) and security recording), images (including photographs) and location tracking / GPS information and all other personal information that may have been excluded above.

2.1 Student or Potential Student and Staff
Putra Business School collects your personal data directly from you or indirectly from your parents, guardians and / or recruitment agents when you, your parents, guardians and / or recruitment agents send us completed enquiry, application and / or registration forms via various means, including online and physical hardcopies at public venues, education fairs, online portals and / or when you, your parents / guardians and / or your recruitment agents visit our campuses. The data for staff, which includes all classes of staff,  may be collected via online application, submission of hard copy resume or via recruitment agencies. Your personal information may also be collected from cookies through the use of our website.

2.2 Student or potential student and staff
Putra Business School collects your personal information directly from you or indirectly from your son or daughter / ward, recruitment agents when you send us completed enquiry, application and / or registration forms via various means, including online and physical hardcopies at public venues, education fairs held at selected venues and / or when you, your son or daughter / ward and / or your recruitment agents visit our campuses. Your personal information may also be collected from cookies through the use of our website.

2.3 Client / customer or potential client / customer for our products, services, events, conferences, seminars and / or other  activities organised by us
Putra Business School collects your personal information directly from you when you express an interest to be contacted for such events and marketing activities (including business card collections via fish bowl method or during previous events organised by us). Your information may also be collected indirectly (for example, via trade / online directories) or from cookies through the use of our website.

2.4 Vendor, supplier or service provider 
Putra Business School collects your personal information directly from you or indirectly from your employer or credit reference agencies when tendering for projects or as part of the commercial transactions. Your personal information may also be collected from cookies through the use of our website.

2.5 Donor/contributor to Putra Business School and it’s affiliates
Putra Business School collects your personal information directly from you when you pledge to us and this information is taken note. Your information may also be collected from cookies through the use of our website.

2.6 Persons or parties not mentioned hereof 
Data would also be collected from person or parties not mentioned above but have entered or intend into a commercial or non-commercial relationship with us.

The Personal Data collected by Putra Business School from you would be used or disclosed for the below mentioned purposes:

3.1 Student or prospect student and staff
Your personal data is collected and further processed by us as required or permitted by law and for various academic and administrative purposes, including the following:

1. to process your application for admission and thereafter to ensure continuous provision of academic and educational services to you (including recording the details of studies) and determining your academic achievements;
2. Evaluating suitability for admission or employment, enrolling or employing, providing educational courses and training, including sending materials on course / study / assignment / lecture materials, information on time tables and examination details via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;
3. Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by us, including  obtaining of references and/or other information from prior educational institutions and employers
4. Investigating possible fraud, misconduct, unlawful action or omission, and utilizing electronic access and video systems to maintain campus security of persons or property, control access and investigate suspicious or inappropriate activities;
5. Processing application(s) for scholarships and/or financial aid, and research support, and administering and managing scholarship/financial aid/grant and other support programmes, which may include use of personal data for development and fund raising activities and disclosure of personal data to donors, grantors, external evaluators and/or external organisations for purposes of periodic reports, event invitations, surveys and/or publicity of PBS’s related programmes;
6. Responding to requests for information from government or public agencies, ministries, statutory boards or other similar authorities or non-government agencies authorised to carry out specific Government services or duties;
7. Processing, administering and conferring awards of prizes, medals, scholarships, classes of honours and other marks of distinction, and student or graduation status, and publication or releasing of information on the same;
8. to provide ancillary services such as visa application and insurance coverage throughout your tenure of studies with us;
9. to assist you in placements, internships or attachments with third parties (where such internships, placements or attachments are required in order to complete your course);
10. to administer and communicate with you in relation to our tuition fees and other relevant payments;
11. to manage your use of our facilities and management of our events such as libraries, residences, computing facilities, graduations, alumni;
12. Facilitating participation in student life and alumni development opportunities which may include social, cultural, athletic, and educational activities, events, volunteering and training programmes, student membership and leadership positions in clubs, societies, halls and residences, and orientation/reception activities;
13. to operate our campuses in a manner which is physically safe, secure and befitting of health and safety requirements;
14. to conduct internal marketing analysis and analysis of student pattern and choice;
15. to comply with Putra Business School’s legal and regulatory obligations in the conduct of its business;
16. to contact you regarding products, services, upcoming events, promotions, advertising, marketing and commercial materials which we feel may interest you;
17. 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
18. for Putra Business School internal records management.
19. any other activities not mentioned above

3.2 Parent / guardian/ sponsor of our student or potential student
Your personal data is collected and further processed by Putra Business School as required or permitted by law and for various academic, educational and administrative purposes, including the following:

1. to process the student’s application for admission;
2. to contact you in the event of emergency or accident;
3. to inform you about the progress of the students, our tuitions fees and other relevant payments;
4. to provide ancillary services to the students such as visa application and insurance coverage;
5. to conduct internal marketing analysis and analysis of student pattern and choice;
6. to comply with Putra Business School ‘s  legal and regulatory obligations in the conduct of its business;
7. to contact you regarding products, services, upcoming events, promotions, advertising, marketing and commercial materials which we feel may interest you*;
8. 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
9. for Putra Business School internal records management.
10. Any other activities not mentioned above.

3.3 Client / customer or potential client / customer for products, services, events, conferences, seminars and other marketing activities organised by Putra Business School or it’s affiliates
Your personal information is collected and further processed by Putra Business School for the following commercial purposes:

1. to provide you with information, products or services that you request from us and any incidental purposes thereto;
2. to contact you regarding products, services, upcoming events, promotions, advertising, marketing and commercial materials which we feel may interest you;
3. to improve the products or services offered by Putra Business School;
4. to conduct internal marketing analysis and analysis of consumer pattern and choice;
5. to notify you about changes to our products and services;
6. to ensure that the content from our website is presented in the most effective manner for you and for your computer and / or device;
7. to comply with Putra Business School’s legal and regulatory obligations in the conduct of its business; and
8. for Putra Business School internal records management.
9. Any other activities not mentioned above

3.4. Vendor, supplier or service provider
Your personal information is collected and further processed by Putra Business School as required or permitted by law and to give effect to your requested commercial transaction, including the following:

1. to administer and give effect to the commercial transaction;
2. to process any payments related to the commercial transaction;
3. for internal investigations, audit or security purposes;
4. to comply with Putra Business School’s legal and regulatory obligations in the conduct of its business;
5. to contact you regarding product, services, upcoming events, promotions, advertising, marketing and commercial materials which we feel may interest you*;
6. 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
7. for Putra Business School’s  internal records management.
8. Any other activities not mentioned above.

3.5 Donor/contributor to Putra Business School and it’s affiliated bodies
Your personal information is collected and further processed by Putra Business School as required or permitted by law and for Putra Business School internal records management.

3.6 Persons or parties not mentioned hereof
Data collected from person or parties not mentioned above will be used for the specified purposes only.

4.1 Entities within Putra Business School

1. Your personal information provided to us is processed by entities (within or outside of Malaysia) within Putra Business School (including related companies, subsidiaries, holding companies, associated companies and outsourcing partners)
2. access to your personal information is restricted to staff who are contractually required to process your personal information in accordance with their respective job requirements; and
3. only necessary information is released to the relevant employees.

4.2  Statutory bodies and other third parties 

1. Your personal information may be disclosed or transferred to statutory bodies and relevant third parties (within or outside of Malaysia) as required under law, pursuant to relevant contractual relationship (for example, where we appoint third party service providers) or for the purposes stated in Section (2.4) above (or directly related to those purposes).
2. In the event of a potential, proposed or actual sale of business, disposal, acquisition, merger or re-organisation (“Transaction”), your personal information may be required to be disclosed or transferred to a third party as a result of the Transaction. You hereby acknowledge that such disclosure and transfer may occur and permit Putra Business School to release your personal information to the other party and its advisers / representatives.

4.3 Student or potential student 
Your personal information may be disclosed to the following statutory bodies and third parties:

1. The Ministry of Education, other relevant government departments / agencies, statutory authorities and industry regulators;
2. Any person to whom we are compelled or required to do so under law or in response to a competent or government agency;
3. Foreign government departments, government agencies or authorities if you are enrolled in a foreign accredited programme;
4. Malaysian immigration department (including agencies appointed by 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 Putra Business School
5. Foreign embassies (including agencies appointed by foreign embassies to carry out their services) if Putra Business School assists you in your visa application as part of your transfer procedure to foreign universities;
6. Your sponsors including your parents / guardians;
7. Our external counterparts providing external, twinning or other similar educational programmes ;
8. Third parties providing you with attachment placements or internships as part of your course requirements;
9. Relevant professional or statutory regulatory bodies or accreditation bodies depending on your programme or course requirements;
10. Law enforcement agencies; and
11. Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, printing companies, telecommunications companies, contractors, conference / training / event organiser, other advisers, travel agencies, recruitment agencies and insurance companies).

4.4 Alumni

1. Upon your graduation, we will retain a summary of your personal information indefinitely for our records. Your contact details will be added to our alumni database.
2. The Alumni Office may contact you in future to keep you up-to-date with news which 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.
3. If you wish to opt-out from receiving these up-dates, select the “unsubscribe” option provided in the email updates sent by the Alumni Office.
4. Please note that the Alumni Office will not disclose your personal information to third parties.

4.5 Parent/guardian of our student or potential student
Your  personal information may be disclosed to the following classes of third parties:

1. The Ministry of Education, other relevant government departments / agencies, statutory authorities and industry regulators;
2. Any person to whom we are compelled or required to do so under law or in response to a competent or government agency;
3. Foreign government departments, government agencies or authorities if you are enrolled in a foreign accredited programme;
4. Malaysian immigration department (including agencies appointed by 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 Putra Business School;
5. Foreign embassies (including agencies appointed by foreign embassies to carry out their services) if Putra Business School assists the student in his / her visa application as part of his/her transfer procedure to foreign universities;
6. Our external counterparts providing external, twinning or other similar educational programmes;
7. Law enforcement agencies; and
8. Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, printing companies, telecommunications companies, contractors, conference / training / event organiser, other advisers travel agencies, recruitment agencies

4.6 Client / customer or potential client / customer for products, services, events, conferences, seminars and other marketing activities organised by us
Your personal information may be disclosed to the following classes of third parties:

1. Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, printing companies, contractors, conference / training / event organiser and other advisers);
2. Law enforcement agencies;
3. Government departments / agencies, statutory authorities and industry regulators; and
4. Any person to whom we are compelled or required to do so under law or in response to a competent or government agency.

4.7 Vendor, supplier, tenant or service provider 
Your personal information may be disclosed to the following classes of third parties:

1. Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, printing companies, contractors, conference / training / event organiser, other advisers);
2. Law enforcement agencies;
3. Government departments / agencies, statutory authorities and industry regulators; and
4. Any person to whom we are compelled or required to do so under law or in response to a competent or government agency.

4.8 Donor/ contributor to Putra Business School and its affiliated bodies
Your personal information may be disclosed to the following classes of third parties:

1. Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, printing companies and other advisers);
2. Law enforcement agencies;
3. Government departments / agencies, statutory authorities and industry regulators; and
4. Any person to whom we are compelled or required to do so under law or in response to a competent or government agency.

4.9 Persons or parties not mentioned hereof
Your personal information may be disclosed to the following classes of third parties:

1. Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, printing companies and other advisers);
2. Law enforcement agencies;
3. Government departments / agencies, statutory authorities and industry regulators; and
4. Any person to whom we are compelled or required to do so under law or in response to a competent or government agency.

5.1 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.

5.2  Location enabled products or applications

1. Location enabled products or applications transmit your location information to us. We do not use the information 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.
2. Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve you through improved products, services, and revisions to the mobile applications. This collected information 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.

5.3 Cookies
A cookie may be used in the processing of your information. 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 information during your visit to our website and/or the fully qualified domain name from which you accessed our site, or alternatively, your IP address:

1. the date and time you accessed each page on our web site;
2. the URL of any webpage from which you accessed our site (the referrer); and
3. 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 information in order to enjoy certain services on our websites (system login credentials, email address and contact, etc). These personal information will only be used for its intended purposes only, i.e. to respond to your message or deliver the requested services.

1. You have the right to access and correct your personal information held by us (subject always to certain exceptions). We will make every endeavour to ensure your personal information is accurate and up to date therefore we ask that if there are changes to your information you should notify us directly.
2. If you would like to access your personal information, please refer to our standard data access form available on http://putrabs.edu.my/pdpa/pd_req_form.pdf and send us the completed form or query to the contact details in Section (6). If you would like to correct your personal information, please contact us at the details provided in Section (7) below.
3. If you have any further query; or
4. If you would like to make a complaint in respect of your personal information, you may contact Jasmin Bin Saihon ([email protected]).

1. We will take appropriate measures to keep your personal data accurate, complete and updated.
2. We will also take reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured.
3. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data.
4. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
5. We will also take reasonable efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
6. This Data Protection Policy applies only to PBS websites. Our websites may contain links to other websites not maintained by us. Such third party websites are subject to their own data protection and privacy practices and you are encouraged to examine the privacy policies of those websites

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 usage language notice shall prevail.