BNM RENEW-BUSINESS ESSENTIALS TRAINING PROGRAM

PRIVACY POLICY 

 

Who we are

This is the Privacy Policy for The Boston Consulting Group, Inc. and its affiliates (BCG or we). This privacy policy was last updated in November 2022. For more detail on BCG’s international operations please see https://www.bcg.com/about/offices/default.aspx

 

Applicability of this Privacy Policy

This Privacy Policy applies only to your use of the RISE website where access is granted to you by BCG for you to access the learning materials to enhance productivity as part of BNM Renew Business Essentials Training Program (“Program”).

 

Important information about this Privacy Policy

BCG understands that your privacy is important. This Privacy Policy (together any applicable Terms & Conditions (Trainees Terms) which you may also be asked to agree to and any additional terms of use incorporated by reference into the Trainees Terms) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Website is not intended for and does not intentionally target or solicit to children or anyone of 18 years of age and younger. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

 

Changes to this Privacy Policy

Please note that BCG may, in its discretion, amend this privacy policy from time to time. To ensure you are able to remain informed about the information we collect and how we use it, material changes to our statement will be reflected here and we will notify you whenever we make a material change to this Privacy Policy. The Website may contain links to external sites or services which are not governed by this Privacy Policy.  We encourage you to review the privacy (and/or cookies) policies of any such sites before you submit information there.

 

The data we collect about you

Based on filling in the forms on the Website (listed below), you consent to allow the website to collect, use, store and transfer the following personal data about you in different ways:

 

  • For fulfilling the program administration and compliance – your first name, last name, email and job designation;
  • For in-course participation, your first name, last name, email for the purpose of learning, operations, compliance as part of the Program;
  • Your IP addresses for verifying class attendance.

 

We also collect, use and share aggregated data such as statistical data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate the data relating to details of your use of the Website to calculate the percentage of users accessing a specific Website feature. However, if we do ever combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences

 

How your personal data is collected

We will collect and process the following data about you:

Information you give us. This is information you consent to giving us about you by filling in forms on the Website, or by corresponding with us (for example, by email or phone), photos and videos taken during and at the end of the class sessions. It includes information you provide when you register to the Website or when you report a problem with the Website. If you contact us, we will keep a record of that correspondence.

Information provided by BNM: your name, email address, telephone number and other contact details.

Cookie/Device storage objects

Essential Cookies

These cookies are essential to enable you to move around the Website and use its core features. Without these cookies, the core features of this Website (such as navigating between pages) cannot be provided. These cookies are also used to remember choices you make (such as your username, language, or the region you are in), recognize the website from which you access the Website, and to ensure secure, accurate session management, the Internet Protocol (IP) address of your machine will be recorded for the period of time that you visit the Website. Essential Cookies are enabled.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented on or before the collection, use and/or disclosure of your personal data;
  • In some situations, as listed below we may need to process your personal data for the legitimate interests pursued by us for following purposes, unless consent is required specifically under applicable data privacy laws;
  • Where we are otherwise permitted to do so under applicable

Purposes for which we will use your personal data

We process your personal information for the following purposes:

  • managing access to the Website,
  • monitoring usage of the Website and providing support related to accessing and using the Website via email, phone call, SMS or WhatsApp;
  • Informing you about updates to the Website via same ways;
  • Tailoring your experience at the Website with relevant materials; provide trainings, run surveys for course evaluation;
  • Understanding the Website’s user population, identifying subject areas of interest, and determining whether the Website is designed to work with the Device settings of a majority of our visitors; and Improving our Website content and navigation; and
  • to confirm your participation at the events, workshops and/or to related courses/programmes you are registering to or registered in.

Insofar as you have granted us consent to the processing of personal information for specific purposes (including registration on the Website), the lawfulness of such processing is based on your consent. You may withdraw your consent to the extent permitted by applicable law, by sending an email to BCG’s Data Protection Office – Dataprotectionoffice@bcg.com.

We will not sell, share, or rent or otherwise make available your personal information to other parties, except that we may disclose the information to third parties who perform services on our behalf and have a need to access the information in connection with those services. Any third parties will only process this information to the extent to which and within the limits that BCG itself is permitted to process that data.

 

Disclosures of your personal data

The third parties with whom we may need to share personal information to help us provide the Website are: our subsidiaries or affiliates; our advisors; our business partners, vendors; learners (when you are part of the WhatsApp and or an email group to be able to receive key announcements and lesson preparations); third-parties for maintenance; our third-party service providers who process information on our behalf to provide training content, assessment and to be able to run operations (enrolments, surveys etc.); some of our internal business operations including IT services and IT infrastructure and cloud storage capabilities to enable the Website to function or any other third parties that we appoint to supersede such service providers; and law enforcement bodies in order to comply with any legal obligation or court order.

Because BCG is a global organization, we need to transfer personal information which is collected by the Website or through other means across the BCG group of companies https://www.bcg.com/about/offices/default.aspx to help operate our business efficiently. This also includes third parties located in different countries around the world, including outside Malaysia. These arrangements may involve your personal information being located in various countries around the world where privacy laws differ. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect information held in that country. In addition, the Website may be viewed and accessed anywhere in the world including countries that may not have laws regulating the use and transfer of personally identifiable information.

 

Compliance with law

BCG complies with all applicable privacy laws and regulations. BCG may be compelled to surrender personal user or customer information to legal authorities if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction. Also, in the event of a violation of the terms and conditions of use of the Website or a violation of any restrictions on use of materials provided in or through the Website, we may disclose personal user information to authorities.

 

Data security

All information you provide to us is stored on our secure servers operated by our third-party hosting providers, BCG has in place appropriate technological and operational security processes designed to protect personal data from loss, misuse, alteration or destruction. Only authorized employees and contractors will have access to any data provided by you, and that access is limited by need. Each employee or contractor having access to any personal data is obligated to maintain its confidentiality. Although we take steps that are generally accepted as industry standard to protect your personal data, BCG cannot guarantee that your personally identifiable information will not become accessible to unauthorized persons and BCG cannot be responsible for any actions resulting from a breach of security when information is supplied over the internet or any public compute network. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

 

Data retention

BCG retains your personal information for so long as is necessary to fulfil the purpose for which it was collected. We may retain your personal information for longer if they may be the subject of a legal claim, or may otherwise be relevant for future litigation.

In some circumstances we will anonymise and/or aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

Your legal rights

In accordance with applicable data protection laws you have a right to request a copy of the personal information we hold about you and details of how we use that information. If any of the information held about you is incorrect or out of date, you have the right to amend or rectify it, please follow the process outlined below and we will amend our records where appropriate. You also have the right to require us to erase your personal data, stop processing your personal data, restricting the processing of your personal information, right of portability of your personal information and/or to withdraw your consent to processing. This may not apply if there are other legal justifications to continue processing. If you think we may have incorrect personal information, or would like a copy of the personal information we hold on you, or to exercise any other data protection right, please contact us via EnrolmentRISE@bcg.com or DataProtectionOffice@bcg.com. Please note that we need you to prove who you are before we can provide you with any information.