MoodleBites from HRDNZ Moodle Partner since 2006

Last updated 25th May 2018

This privacy notice tells you how we, Human Resource Development International Limited (HRDNZ), will collect and use your personal data to provide our online training service.

The MoodleBites site provides a number of courses, and is hosted by HRDNZ. This notice will tell you how HRDNZ uses your data.  HRDNZ has a Data Protection Officer and you can contact them if you have queries:

Contact details of the Data Protection Officer

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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 natural person”.

Why does HRDNZ need to collect and store personal data?

In order for us to provide you with courses on MoodleBites we need to collect personal data for correspondence purposes and/or to allow us to provide you our service. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose. HRDNZ is a company that values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make the MoodleBites courses work for you.

If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s OK to do that.

Will HRDNZ share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to HRDNZ in the course of dealing with you. We do this because there are some services, such as 3rd party plugins,that may not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our and your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with HRDNZ procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise. If you would like an up-to-date register of all our third-party service providers, please contact privacy@hrdnz.com and we will be happy to provide it.

How will HRDNZ use the personal data it collects about me?

HRDNZ will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. HRDNZ maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. HRDNZ is required to retain certain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Can I find out the personal data that the organisation holds about me?

HRDNZ at your request, can confirm what information we hold about you and how it is processed. If HRDNZ does hold personal data about you, you can request the following information:

• Identity and provide contact details of the person or organisation that has determined how and why to process your data.
• Contact details of our data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of HRDNZ or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

HRDNZ accepts the following forms of ID when information on your personal data is requested:

• A colour copy of a Passport, driving licence or National ID Card

DATA POLICY

1. Scope

   All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

   All data subjects whose personal data is collected, in line with the requirements of the GDPR.

   • 2.1 Where HRDNZ is hosting a website on its own behalf (in this case MoodleBItes), HRDNZ is the Data Controller for all the data collected.

3. Privacy notice

• 3.1 Who are we?

  HRDNZ is an educational services and e-learning company which provides support for online learning, and hosts and manages the Moodlebites site. The Moodle software is free and open source (FOSS).

  We collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with HRDNZ. We are committed to transparency in this and have provided a very detailed breakdown of these processes in Annex 1 at the end of this document.

  Our legal basis for processing for personal data:

  1. 1. • Article 6.1(a), GDPR, Consent
        • Article 6.1(b), GDPR, Contract
        • Article 6.1(f), GDPR, Legitimate Interest

  Any legitimate interests pursued by us, or third parties we use, are as follows:

  1. 1. • Business Development
          
        • Providing login systems to users via their existing social media accounts

  The special categories of personal data concerned are:

  1. 1. • Biometric Data in the form of facial images
        • Any special categories of special personal data which any user volunteers while using the Moodle systems or any Moodle website- for example in a forum or submission

  3.2 Consent

  By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for HRDNZ to process both standard and sensitive types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice and its accompanying Terms and Conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.

  You may withdraw consent at any time by:

  Please identify your role in relation to Moodle (if you are a Student, Teacher, Site Admin etc.), and the data you wish to withdraw consent to be processed. Please include a copy of a state-issued Photo ID, in order to confirm that you are the person whose data is to be removed.

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  3.3 Disclosure

  HRDNZ will pass on your personal data to certain third parties. MoodleBites is a distributed, global site and it uses cloud services which may be accessed by HRDN employees in any part of the world, including our Head Office in New Zealand.

  MoodleBites uses the open source Moodle software platform.  In this circumstances, we are the Data Controller and ensure we have put the necessary safeguards in place for any international transfers outside the EU.

  Third country (non-EU)/international organisation	Safeguards in place to protect your personal data
  MoodleBites site: New Zealand, Global	Use of the EU’s Standard Contract Clauses, Privacy Shield, and binding corporate rules
  Other Moodle sites and services (e.g. Mobile App)	Use of the EU’s Standard Contract Clauses, Privacy Shield, and binding corporate rules

• 3.4 Retention period

  HRDNZ will processes different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact privacy@hrdnz.com

• 3.5 Your rights as a data subject

  At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that HRDNZ refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

  Where HRDNZ are your Data Controller, you may make a request directly to the Data Protection Officer using the email address dpo@hrdnz.com

  Where HRDNZ are a Data Processor, and act on behalf of a data controller (such as Moodle Mobile App) any requests received by HRDNZ will be passed on to the Data Controller.

  Where HRDNZ are not involved with your data, such as where the Moodle platform has been self-hosted, you should address your requests to the data controllers of those sites. HRDNZ have no independent access to your data.

• 3.6 Complaints

  In the event that you wish to make a complaint about how your personal data is being processed by HRDNZ (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and HRDNZ’s data protection Officer.

  If you wish to make a complaint about how your personal data has been processed by the Moodle Mobile App, or by a Self-Hosted installation of the Moodle Software you should contact your Moodle Site Admin or the Data Controller for your Moodle installation. (For example, if your university or school hosts their own Moodle site, they will be the Data Controller).

  The details of Contacts for where HRDNZ’s is the Data Controller:

  	Supervisory authority contact details	Data Protection Officer (DPO) / GDPR Owner contact details
  Contact Name:	Data Protection Commissioner	Data Compliance
  Address line 1:	Canal House	HRDNZ
  Address line 2:	Portarlington	324 Puketona Road
  Address line 3:	Co Laois	Haruru Falls, Paihia, 0204
  Address line 4:	R32 AP23	New Zealand
  Email:	info@dataprotection.ie	dpo@hrdnz.com
  Telephone:	+353 57 8684800	+64 21 467774

  The details of contacts for where HRDNZ is not the Data Controller, in your installation of Moodle, are available directly from your Data Controller.

Annex 1