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TENJIN PERSONAL DATA PRIVACY POLICY














1. Introduction to Tenjin Technology

Tenjin Technology ('Tenjin') develops web applications for the purpose of supporting accounting and finance education. Tenjin is typically engaged by a client in order to make the Tenjin application (the 'Application') available to the client's registered students ('individuals') for the purpose of formative self-assessment and revision of relevant subject matter content.

Contact details for Tenjin are listed at the bottom of this page.



2. Personal Data and Privacy

Personal data comprise information relating to an identifiable living individual. This policy sets out the principles that each of the client and Tenjin adhere to when processing personal data and sets out the operational aspects of the data processing activities.



3. What personal data points are typically collected and processed?

(a) In order for Tenjin to be able to fulfil its role as instructed by the client, personal data may be processed by each of the client and Tenjin.

Tenjin may receive the following personal data automatically from the client when a client-registered individual accesses Tenjin through the client student portal (for example a Moodle course page).

• Individual's Moodle username (for example 'sam.jones');

• Individual's display name (for example 'Sam Jones').

(b) Tenjin may process this personal data on the first occasion to create an account for the individual and to keep a record of the subsequent self-assessment and revision activities undertaken by that individual. The self-assessment and revision activities of the individual that may be recorded by Tenjin on behalf of the client are as follows:

• Date and time of on-screen quiz generation or PDF file download;

• Subjects for which on-screen quizzes are generated or PDF files downloaded;

• Question reference numbers included in each generated on-screen quiz or PDF file download;

• Types of questions included in each generated on-screen quiz or PDF download (for example, multiple-choice or short computational or long computational);

• Whether an on-screen quiz is generated in 'learning' mode or 'exam' mode;

• Actions taken by the individual in an on-screen quiz as follows:
o Whether a question is viewed (Yes or no);
o Whether a question is attempted (Yes or no);
o Whether an attempt is correct or incorrect (Yes or no);
o Whether the hint is viewed (in 'learning' mode) (Yes or no);
o Whether a 'similar question' is selected (in 'learning' mode) (Yes or no);
o Whether the solution is selected (in 'learning' mode) (Yes or no);
o Option selected for multiple-choice type questions ((a), (b) or (c));
o Values input for short computational questions.

(c) Individuals have the possibility to contact Tenjin directly through the 'contact us' tab. In this circumstance, the individual's email address and potentially other personal data are communicated by the individual directly to Tenjin.

(d) Cookies

A cookie is a small amount of information that may be stored on an individual's device. Cookies are used to make it easier for an individual to stay logged in to the Application. Further information about cookies is included on the Cookies page.



4. What are the typical purposes of the collection and processing of personal data?

(a) The client may communicate personal data to Tenjin in order to facilitate access to the Application and for Tenjin to present relevant subject matter to each individual. An individual may be authorised to use the Application solely by reference to the information that may be communicated by the client.

(b) With regard to personal data points that may be generated by individuals through use of the Application, the client may apply a range of data and learning analytics techniques.

(c) Tenjin may process personal data in order to implement a fair usage policy in respect of PDF file downloads. Each individual is typically limited in terms of the number of revision questions that may be downloaded during any continuous 24-hour, 7-day or 30-day period. For this purpose, Tenjin may process personal data in order to maintain a historical record of PDF downloads by each registered individual.

(d) Tenjin may process personal data when an individual communicates directly with Tenjin through the 'contact us' tab.



5. What is the typical legal basis of the processing of personal data?

By law, each of the client and Tenjin may only process personal data where there is a legal justification to do so. In accordance with that law, each of the client and Tenjin may process personal data in relation to the Application because it may be necessary for the purposes of the legitimate interests of the client and Tenjin.

(a) The client may process personal data in order to facilitate authorised access to the Application for each registered individual.

(b) Tenjin, in its capacity as a data processor on behalf of the client, may process personal data in order to facilitate data and learning analytics that are undertaken by the client.

(c) Tenjin may process personal data in order to implement its fair usage policy in relation to PDF file downloads. It may be necessary to process personal data in order to enforce this policy.

(d) Tenjin may process personal data when an individual communicates by means of the 'contact us' tab. This processing may be necessary in order to be able to respond to the individual.

Each of the client and Tenjin take care to be able to conclude that:

(a) the interests pursued by each in the context of the Application are legitimate interests that are solely related to the provision of a high-quality educational experience to registered individuals;

(b) the processing of personal data is necessary (in that it is targeted to apply only to the stated legitimate interests and is a proportionate way of achieving the stated legitimate interests);

(c) the fundamental rights and freedoms of an individual are not compromised by the legitimate interests of either the client or Tenjin. In this regard, the client and Tenjin give due consideration to the nature of the data processed, the expectations of an individual in an educational environment and the likely impact of the processing of personal data on an individual.



6. For how long is personal data typically held?

Personal data points that may be processed in connection with the Application may be held for up to one year after the end of the academic year in which the personal data points are first processed. An academic year commences at the beginning of September and ends at the end of the following August.

For example, 'Sam Jones' uses the Application on one or more occasions during the 2017/2018 academic year - personal data points relating to 'Sam Jones' are therefore processed during the 2017/2018 academic year. These personal data points may be retained up to the end of the 2018/2019 academic year, at which point the personal data points would be anonymised. Once anonymised, the Application activity data points are no longer be associated with an identifiable individual. Therefore, after an anonymisation process, Application activity that was previously associated with 'Sam Jones' is no longer associated with 'Sam Jones'.

Anonymised Application activity data points may be retained either by the client or by Tenjin on behalf of the client for archive, research and statistical analysis purposes.

Personal data points sent to Tenjin as a result of communication through the 'contact us' tab are retained by Tenjin only for as long as is required to address the subject matter of the communication. Once the matter is resolved or forwarded to the client, the personal data points are permanently deleted.



7. What are an individual's rights in relation to personal data?

(a) Right to information and access

An individual has the right to request access to the information about him or her that is held by the client or by Tenjin on behalf of the client. On request, the client will provide the individual with a copy of the personal data points that have been generated in connection with the Application. This information is provided in a convenient electronic format.

(b) Right to rectification

The client will rectify any noted inaccuracies in relation to an individual's personal data following a request by the individual concerned.

(c) Right to object to processing

An individual has the right to object to processing of personal data in connection with the Application on grounds relating to his or her particular situation.

(d) Right to restrict processing

An individual has the right to request the restriction of personal data. In this case, personal data points would be stored by the client or by Tenjin on behalf of the client but would not be processed in connection with any aspect of the Application.

(e) Right to erasure

An individual has the right to request erasure of personal data points that arise in connection with his or her use of the Application.

(f) Right to make a complaint to the Data Protection Commission

An individual has the right to make a complaint to the Data Protection Commission in order to ensure that his or her rights are fully upheld.



8. Is personal data shared with third parties?

The Application is hosted on a Microsoft cloud platform. Personal data that are processed as a result of accessing or using the Application are stored on the Microsoft cloud platform and in accordance with the terms and conditions of Tenjin's subscription to Microsoft Online Services.

Other than in connection with Tenjin's subscription to Microsoft Online Services, only the client or Tenjin on behalf of the client handle personal data that is processed in connection with the Application.



9. What data security measures are typically in place to protect personal data?

Each of the client and Tenjin take appropriate technical and organisational measures to protect personal data points that are transmitted, stored or otherwise processed in connection with the Application against accidental or unlawful destruction, loss, alteration, or unauthorised disclosure or access.

In general, personal data points are encrypted in storage and during transmission to and from client and Tenjin servers. Authorised access to the Application requires an individual to be logged in to the client's student portal by means of a username/password combination.

Any data files transferred between the client and Tenjin that contain personal data are password protected as a matter of standard policy. Any data files containing personal data that may be temporarily stored on a Tenjin portable device are password protected and encrypted.

Prior to introducing any technologies that are relevant to the processing of personal data in connection with the Application, both the client and Tenjin on behalf of the client undertake all necessary impact assessments.

Whereas the client and Tenjin strive to protect each individual's personal data, including through use of encryption and other measures, it is not possible to guarantee the security of any internet communication or transmission. If any individual has reason to believe that interactions with the Application are not secure, please notify Tenjin by using the contact details at the bottom of this page.

Where an individual is provided with, or has chosen, a password that enables access to certain parts of the application, the individual is solely responsible for keeping that password confidential.

In the event of any breach of client's or Tenjin's systems impacting on the security of an individual’s Application-related personal data, the client will inform the affected individuals at the earliest opportunity describing the nature of the breach, the possible consequences and the measures being taken to remedy the situation in accordance with client procedures and applicable law.



10. What about site links to third party sites?

The Application site may contain links to third-party resources. Individuals should note that these third-party sites may have their own personal data and privacy policies. Neither the client nor Tenjin accept any responsibility or liability in connection with those third party personal data and privacy policies.



11. Contact details

Comments and enquiries relating to this personal data and privacy policy should be directed to:

Bazwaldo Limited T/A Tenjin Technology
c/o Leahy O'Riordan Chartered Accountants
1-2 Marino Mart
Fairview
Dublin 3

Email: Use the form on the 'contact us' tab or email directly to 'dataprotection@tenjin.ie'.

The website for the Data Protection Commission is https://www.dataprotection.ie.



12. Updates to Personal Data and Privacy Policy

In the event that there are any changes to this personal data and privacy policy for the Application, an updated version will be posted on this page and all individuals will be notified of the updated version by means of the home page.

This version is dated May 2018.