This Policy describes how companies in the Dee Smith & Associates (Pty) Ltd group (together “Dee Smith & Associates (Pty) Ltd” or “we”) collect and process data which identify individuals (“Personal Data”) of customers and other users of our services (“Users”, “you”), and your associated rights. This Policy applies to Dee Smith & Associates (Pty) Ltd products and services, including websites operated by Dee Smith & Associates (Pty) Ltd. Your privacy is extremely important to us and we are committed to offering you a safe and hassle-free experience while visiting our websites and using our services.
- How We Collect and Use Personal Data
We may collect and/or process your Personal Data only as stated in this Policy, for the purposes described below. We do not sell, share or transfer Personal Data to third parties, other than in the specific circumstances described in section 1.a.
- Certification Services
Dee Smith & Associates (Pty) Ltd provides examination and certification services (“Certification Services”) as a Personnel Certification Body and Accredited Examination Institute. We may collect your Personal Data (including name, address, email address, phone number, photo ID, video and audio recordings of examination sessions, and other information) to confirm your identity, deliver examinations, and ensure the validity of the certification process. Certain Personal Data is required to be collected under our procedures to provide you Certification Services and other Personal Data is collected to provide you with a good experience.
Dee Smith & Associates (Pty) Ltd uses your Personal Data to provide examination and certification services. We may also use your Personal Data for internal research and development or quality control purposes, and extracts from examination work in anonymised form may be reproduced in published exam preparation material. In the process of providing Certification Services, we create additional Personal Data, including examination results. Recordings of examination sessions are retained for one (1) year to provide a record of examination integrity.
Some of our Certification Services are offered in cooperation with other organisations that provide examination content (“Test Owners”) and/or are authorised and approved by Dee Smith & Associates (Pty) Ltd for delivery of Certification Services (“Partners”). Some authorised Partners may also provide training services related to Dee Smith & Associates (Pty) Ltd certifications. We may share your Personal Data with those Test Owners and Partners to the extent necessary to provide you Certification Services. We require Test Owners and Partners to comply with data protection law, but we are not directly responsible for their privacy practices. For information on those practices, please refer to the privacy policies of the Test Owner who provides your examination (our websites contain information about Test Owners) and Partner(s) whose services you use.
We may disclose Personal Data to third parties in the following circumstances:
- if we have obtained your consent to do so
- by sending your examination results to the Partner where you took your examination, for sharing with you
- when we are required by law or court order, or by a regulatory or governmental authority legally authorised to request such disclosure
- if you are suspected and/or investigated for examination malpractice
- if required to protect the rights, property or safety of Dee Smith & Associates (Pty) Ltd its business partners or Test Owners.
Dee Smith & Associates (Pty) Ltd maintains a registry containing details of all certified persons. As a Personnel Certification Body and Accredited Examination Institute we operate publicly available Certificate Verification Service (“CVS”) accessible via our websites www.ds.co.za, www.language.org and www.languagecert.gr. The CVS allows Users and third parties (e.g. employers) to confirm the authenticity and accuracy of any Dee Smith & Associates (Pty) Ltd certificate by entering the serial number of the relevant certificate.
- Online Proctoring
Dee Smith & Associates (Pty) Ltd optionally offers examinations through the Dee Smith & Associates (Pty) Ltd Online Proctoring services, for Users who wish to take an online exam at their preferred time and location (i.e. almost anywhere they have internet access). Dee Smith & Associates (Pty) Ltd Online Proctoring connects Users via webcam directly to an authorised Dee Smith & Associates (Pty) Ltd proctor (invigilator), who guides them throughout the exam and monitors the exam session. The service records the exam session (video, sound and User’s computer desktop), ensuring its security and integrity. Recordings are retained for one (1) year to provide a record of examination integrity.
- Online Account
All Dee Smith & Associates (Pty) Ltd examination candidates (and in certain circumstances other Users) must have an online account (“Dee Smith & Associates (Pty) Ltd Account”), which is created and accessible via the Dee Smith & Associates (Pty) Ltd website. Users also may voluntarily create an Account. Your Account contains some or all of the Personal Data that we hold about you, and makes it easier for you to use our services. You may request deletion of your Account at any time by emailing email@example.com, this may reduce our ability to provide you services. We may be required to retain certain Personal Data after account deletion to ensure the functioning of Certification Services.
- Customer Support Services
Dee Smith & Associates (Pty) Ltd offers 24/7 customer support to Users (both organisations and individual Candidates), through email, telephone and online chat. Telephone calls and online chats may be recorded for monitoring and training purposes, and to improve our services. Telephone recordings are retained for up to fifteen (15) days, and online chat recordings and emails are retained for up to one (1) year.
- Marketing Communications
If you have opted in to receiving marketing communications from Dee Smith & Associates (Pty) Ltd, we may occasionally contact you via various means (e.g. email, SMS, telephone) to inform you of new Dee Smith & Associates (Pty) Ltd products and services, and other Dee Smith & Associates (Pty) Ltd developments. Partners and Test Owners are not permitted to use your Personal Data for marketing or similar purposes, unless specific consent has been given by you. You have the option of opting out of such communications at any time, by using the “unsubscribe” links in the communications or by contacting us at firstname.lastname@example.org .
From time to time Dee Smith & Associates (Pty) Ltd may run surveys, polls and similar initiatives (“Surveys”), to request information from Users to assist us to improve our products, services and operating practices. Participation in Surveys is always voluntary, and Personal Data provided in Survey responses will always remain strictly confidential. The results of Surveys may be aggregated, and anonymised, and such anonymised information may be shared with third parties.
- Services to Children
Where the User of our services is a child below the age of 16 years, we will request consent for the collection and processing of Personal Data from a holder of parental responsibility over the child.
- Retention of Personal Data
Where retention of Personal Data is required by law, Dee Smith & Associates (Pty) Ltd complies with required retention periods. In other circumstances, Dee Smith & Associates (Pty) Ltd retains Personal Data for as long as necessary for the business purposes set out above. For certain specific circumstances, shorter retention periods are specified in this Policy.
- Cross-Border Transfer
We aim to comply with the data protection law in all countries where we do business, including the laws of the European Union. We transfer Personal Data across borders in accordance with applicable law. When we transfer or store Personal Data of EU residents outside the European Economic Area, we do so in compliance with the applicable EU laws on data protection (including by working with US partners who comply with the EU-US Privacy Shield).
- Rights Regarding Your Personal Data
You have the right to access, correct or delete your Personal Data. However, you acknowledge and accept that upon deletion of specific Personal Data, certificate validation and other services provided by Dee Smith & Associates (Pty) Ltd may not be available. Under EU law, you have certain rights to restriction of processing of your Personal Data and of portability of your Personal Data to other service providers. To exercise these rights, please email email@example.com.
- Data Security and Integrity
We use appropriate technical and organisational measures to protect Personal Data from unauthorised use, access, disclosure, alteration or destruction. These precautions include physical, electronic and managerial procedures in compliance with the ISO 27001 international information security standard.
- Online Purchases
Dee Smith & Associates (Pty) Ltd offers products, exams and services for purchase remotely and electronically. Payments are processed securely by our selected payment processors. Dee Smith & Associates (Pty) Ltd does not have access to any credit or debit card information. This information is securely provided by Users directly to our payment processors at the time of purchase.
- Third-Party Services and Sites
Dee Smith & Associates (Pty) Ltd provides Certification Services in cooperation with Test Owners and Partners (see section 1.a above), and Dee Smith & Associates (Pty) Ltd websites contain links to third party websites. Dee Smith & Associates (Pty) Ltd is not responsible for the privacy practices or the content of any third-party services and websites. For information on other organisations’ privacy practices, you should refer to the privacy policies of those organisations.
- Amendments to Policy
We may revise this Policy to reflect changes in Dee Smith & Associates (Pty) Ltd products or the law, or for other reasons. If we make any material change to this Policy, we will notify you by email. You will be bound by any changes to this Policy when you use Dee Smith & Associates (Pty) Ltd services after we have provided notice of such changes.