Data Privacy Agreement

• Identity and account data: full name, student or employee number, email address, contact details, date of birth, nationality, address, course, section and department, as obtained from enrollment and personnel records, and your profile photo or avatar.
• Academic data: the classes you belong to, attendance, grades, scores, your answers to assessments, scanned paper answer sheets, submitted assignments (files, links and text), instructor feedback, and enrollment status.
• Assessment integrity data: while you take an online assessment, STEP-S records when you start, leave and return, how long you were away, and how many times you switched away from the exam. Exam pages may show your name and ID as a watermark. This protects the fairness of assessments for everyone.
• Classwork activity and sign-ins: STEP-S records when you sign in (on the web or the mobile app, including failed attempts), when you open, start and submit assessments and assignments, the reminders it sends you, and any errors or connection problems on those pages, with the time, IP address and device. Instructors use this record to verify reports of technical problems fairly, for example when deciding whether to give another attempt.
• Communications: messages, comments, announcements and community posts you send in STEP-S, and the notifications STEP-S sends you.
• Evaluations and surveys: your responses to faculty evaluations and institutional surveys. Your account is linked to your response so that each evaluation or survey is submitted once.
• Technical data: session and sign-in cookies needed to keep you signed in, and preferences your browser stores on your own device (such as light or dark mode). STEP-S also notes when you were last active, the page you were on, and your IP address and device, so administrators can see who is using the system. The mobile app receives push notifications for the classes you belong to.
• Financial information, such as payment history, scholarships and financial aid data, is processed by the institution to manage tuition and fees.

The institution keeps personal data only for as long as necessary:

• Academic records, including final grades and scores, are kept indefinitely.
• Your individual answers to each assessment question are kept for four years; the final score is kept with your academic record.
• Your assignment submissions, including uploaded files, links and online text, are kept for four years after the assignment's due date; the score is kept with your academic record.
• Classwork activity and sign-in records are kept for two years.
• Financial records are kept as required by applicable regulations.

When a retention period ends, the data is permanently deleted, or for paper records, securely shredded.

Within STEP-S, access depends on role. Your instructors see the work, scores and classwork activity for the classes they teach. Deans, academic heads and other authorized officials see records for the programs they oversee. Authorized system administrators access data only to support and secure STEP-S. Other students do not see your scores or activity.

Data is shared outside the institution only when required by law, with your consent, or with service providers that help run STEP-S and are bound by confidentiality. For example, Google Firebase Cloud Messaging delivers the mobile app’s push notifications; these carry the class and classwork title, not your personal records.

Under the Data Privacy Act, you have the right to:

• be informed about how your personal data is processed;
• access your personal data and obtain a copy of it;
• have inaccurate or incomplete data corrected;
• object to processing, and ask for data to be blocked or erased, except where the institution must keep it by law or for your academic record;
• data portability, receiving your data in a commonly used electronic format;
• claim damages, and file a complaint with the National Privacy Commission.

Send requests in writing to the Data Protection Officer at the address below.