The purpose of this policy is to ensure that all reasonably available measures are in place to protect the privacy of information collected. The Mind Lab Limited (including subsidiary Tech Futures Lab1) fully complies with obligations under the Privacy Act (1993).
- This policy applies to all staff members and processes at The Mind Lab (including any programme delivery partners). The Mind Lab (TML) must ensure that, when using or dealing with personal information relating to other staff members, users, contractors or any other individuals, they comply fully with this policy.
- This policy applies to all personal information provided, whether in person or via other means, including through The Mind Lab sites (including themindlab.com, applynz.force.com, techfutureslab.com, and the Learning Management System).
- This policy applies to information collected from all users of The Mind Lab’s products and services including adults, children, students, parents and guardians.
This policy covers the following:
- Collection of personal information
- Storage, use and disclosure of personal information
- Cookies and data security
- User access to and correction of personal information
1. Collection of Personal Information
a. The Mind Lab collects personal information about users (and where applicable their parents/caregivers) through website registration forms, online accounts and personal transactions over the phone or online. The Mind Lab may collect, store, and use the following categories of personal data about the user: contact details (including name, title, address, telephone number, email address); date of birth; log in details and passwords; application details; credit card/payment details; location information either provided by the user, by a mobile device or associated IP address (where permitted by law); usage, viewing and technical data, including device identifier, server address, IP address, domain name, browser type, and activity/conduct on the Site; aggregated data (such as tracking of site traffic and cookies), and other information the user provides to us through any other method (including, without limitation, correspondence and discussions whether on the Site, by phone or via other means).
b. The Mind Lab gathers various information depending on the site and/or programme (from application through to matriculation and graduation), including:
i. Registration information created by setting up an account on The Mind Lab websites (sites), including first name and surname, date of birth, email address, username and password.
ii. Personal information that is required for enrolment in TML programmes including identification, qualification, academic and immigration information where relevant.
iii. Personal information provided to us through any other method (including without limitation correspondence and discussions whether on The Mind Lab sites or via other means).
iv.Location information either provided by a mobile device or associated with an IP address, where The Mind Lab is permitted by law to process this information.
v. Usage, viewing and technical data, including a device identifier or IP address, when users visit The Mind Lab sites.
vi. Aggregated data, which tracks traffic to The Mind Lab sites, and cookies, which are pieces of information transferred to a user’s computer hard drive for record keeping (such as preferences on The Mind Lab sites).
2. Storage, Use and Disclosure of Personal and Academic Information
a. All personal information will be stored on external, secure cloud hosted infrastructure. Additional individual access through the sites may be logged. This could include:
i. browser’s internet address
ii. server’s address
iii. domain name
iv. IP address
v. date and time of the visit to the site
vi. the pages accessed and documents downloaded
vii. the type of browser used
b. The Mind Lab may use this information for statistical purposes and for system administration tasks to maintain this service. The Mind Lab does not identify individuals as part of this practice. However, in the event of an investigation, by a law enforcement agency or other government agency, The Mind Lab may exercise its legal authority to inspect relevant server logs.
c. Personal information collected by The Mind Lab will be held for the purposes of enrolling users and administration. Other purposes may include reporting back to parents/caregivers (when appropriate i.e. parents of under 18 year old students and other court appointed guardians), celebrating and recording user achievement. Personal applicant information, including uploaded documents, is securely stored on the The Mind Lab’s Student Management System (the Salesforce platform) under The Mind Lab domains. The Mind Lab agreement with Salesforce ensures that both parties control the protection of personal data. The Mind Lab is responsible for protecting users data at all times, except where there is a situation with the Salesforce infrastructure out of The Mind Lab’s control. Salesforce very clearly outlines this responsibility and commitment on their website. For further information: Trust and Compliance Documentation and Data Processing Addendum.
d. A unique identifier will be assigned to each user, which will be used in conjunction with a secondary means of identification or password.
e. Staff members and other personnel within The Mind Lab will have access to users’ personal information for purposes relevant to normal Mind Lab operations including but not limited to: student recruitment, marketing, admission, enrolment, study, academic progress, tuition fees and charges, establishing and maintaining academic and graduation records, assessment, academic agreements (scholarship providers or sponsors, programme delivery partners), academic advice and support, student services, discipline, security and safety, library and IT services, and records, managing records of graduates, and alumni, and managing and improving the quality of services provided by The Mind Lab.
f. A student’s academic achievements i.e. completion of academic qualifications are public record, and The Mind Lab can verify qualification achievements to those who enquire. However, the specific details or individual components of a student’s qualification (i.e. Academic Transcripts) will not be disclosed by The Mind Lab without the student’s consent.
g. The Mind Lab will use anonymised information (including learning analytics) gained from The Mind Lab student learning activities for academic and marketing purposes, including research and to improve The Mind Lab programmes design and delivery. All possible precautions will be taken to ensure that The Mind Lab students, past and present, will not be identifiable as individuals.
h. In addition, The Mind Lab will survey students for feedback on their experience of The Mind Lab programmes and courses. This data will be anonymised. The Mind Lab may also ask individuals and groups of students to volunteer feedback and data (including videos and photographs) for research and marketing purposes.
i. The Mind Lab uses email addresses to communicate regarding current bookings, surveys, programme or course updates and administrative matters. All recipients are given the option to opt out of receiving promotional emails.
k. The Mind Lab will not disclose any personal information held to a third party, unless required by law, or except as set out below:
i. Service Providers: The Mind Lab works with third-party service providers who provide hosting, maintenance, backup, storage, infrastructure, payment processing, subscription, analysis, marketing and other services for us, which may require them to access information about the user. If a service provider needs to access information about a user to perform services on their behalf, they do so under instruction from The Mind Lab, including abiding by policies and procedures designed to protect the users information. Some of these service providers may be located in countries other than New Zealand.
ii. Legal Obligations: In exceptional circumstances, The Mind Lab may share information about a user with a third party if The Mind Lab believes that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce The Mind Lab agreements, policies and terms of service, (c) protect the security or integrity of The Mind Lab sites and services, or (d) protect The Mind Lab, related companies, customers or the public from harm or illegal activities.
iii. Sale of our business: In the event that The Mind Lab proposes to sell the business or any of its assets, The Mind Lab may provide user personal data as part of a database to a prospective buyer solely so that they can consider the purchase of the business. Should The Mind Lab proceed to sell the business (or a material part of it) The Mind Lab may provide user personal data as part of that sale so that the purchaser can continue to operate the business and contact users about their plans for the business.
3. Cookies and Data Security
a. A cookie is a very small text file that is sent to a browser from our web server and stored on the user’s computer. Cookies help provide users with a customised experience without having to re-enter their preferences each time they return to The Mind Lab websites. Customers may disable cookies, however doing so may restrict access to some web pages.
b. The Mind Lab takes all reasonable precautions to guard against unauthorised access to confidential and personal information including the loss, misuse and alteration of the information held by The Mind Lab. When personal information is no longer required for the purposes for which it was collected, it may be deleted.
c. The Mind Lab booking systems are PCI-DSS compliant. NB. The Payment Card Industry Data Security Standard (PCI DSS) is a set of security standards designed to ensure that companies that accept, process, store or transmit credit card information maintain a secure environment.
d. The Mind Lab has in place measures to ensure the security of the personal data that is collected and stored about users. The Mind Lab uses all reasonable endeavours to protect personal data from unauthorised disclosure and/or access, including through the use of network and database security measures.
e. The Mind Lab has put in place procedures to deal with any suspected personal data breach and will notify users and any applicable regulator of a breach where legally required to do so.
4. Access to and Correction of Personal Information
a. A user may request access to their personal information by logging in to their Account on the The Mind Lab sites or by emailing email@example.com. If a user contacts The Mind Lab by email or phone (+64 9 964 4444), The Mind Lab may need to verify their identity for security purposes. Changes may take up to 10 days to take effect. If a user has questions regarding the specific personal information about them that The Mind Lab holds, they can contact firstname.lastname@example.org. Users can also contact Tech Futures Lab Limited by email email@example.com or phone +64 (9) 522 2858.The Mind Lab will hold a user’s information for as long as their User Account is active or as is needed to provide services to the user, or as long as TML is legally obliged to. If a user wishes to cancel their Account or request that The Mind Lab no longer uses their information to provide services, they can contact The Mind Lab at firstname.lastname@example.org.
b. The Mind Lab will hold students enrolment records to comply with NZQA PTE Enrolment and Academic Records Rules 2012. This means enrolment records will be held until at least two years after the completion of the education.
1 Tech Futures Lab is an education facility of The Mind Lab, a NZQA registered Tertiary Education Organisation under the provisions of the Education Act 1989. All policies and procedures of The Mind Lab also apply to Tech Futures Lab unless expressly stated otherwise.