Privacy Notice

Last updated 05 April 2019

This privacy notice tells you how we, D-Learning Program, will collect and use your personal data to provide our service which allows educators, of any kind, to create a private space online, filled with tools that easily create courses and activities, all optimised for collaborative learning.

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 D-Learning Program need to collect and store personal data?

In order for us to provide you with D-Learning Program courses 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. D-Learning Program is a company which values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make the D-Learning Program Services 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 D-Learning Program share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to D-Learning Program in the course of dealing with you. We do this because there are some services, such as content in specific courses, which will 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 of course, your-behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with D-Learning Program’s 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, or if it is necessary to comply with an employment contract, unless we are legally required to do otherwise.

How will D-Learning Program use the personal data it collects about me?

D-Learning Program 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. D-Learning Program 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. D-Learning Program 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?

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

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

D-Learning Program accepts a request made through a D-Learning Program account while the person making the request is logged in. In certain circumstances D-Learning Program could ask for additional information and the following forms of ID when information on your personal data is requested:

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.

  3. Privacy notice

Annex 1

Purpose of processing

Categories of personal data

The source of the personal data

sending e newsletters to moodle.com users

email address, name

Data subject

sending e newsletters to moodle.org users

email address, name

Data subject

Attendee registrations and payment for moodlemoot.org

email address, name, payment details

Data subject

Presentation admission process run by Marketing department for moodle moot’s events

email address, name, workplace, summary of applicable presentations

Data subject

Communicating marketing campaigns on Facebook

name, email address, location, job title, interests, any other Facebook categories used

Data subject

Communicating marketing campaigns on Twitter

name, email address, location, interests

Data subject

MOOC participants information (Learn Moodle)

name, email address

Data subject

Recruitment

Name, Address, phone number, email, social media profile links, Photograph, educational and work history, interests

Candidate

Recruitment

Contact details

Candidate

On-boarding

Contact details, emergency contact details, drivers licence, passport, id documents, banking details, tax details, superannuation details, gender, qualifications, biometric data, date of birth

Employees

Health and Safety

Name, phone number, email, relationship with Employee

Employees

HR Records

Health Records

Employees

On-boarding

Contact details, emergency contact details, drivers licence, passport, ID documents, banking details, gender, qualifications, biometric data

Employees

On-boarding

Telephone number

Team Members

Performance

Performance information, contact details

Managers/HR

Engagement

Contact details, job information, engagement information

Employees/HR

Letter of Offer

Name, address, phone number, email and remuneration details

Employees/HR

Confirmation of Information

Contact details, remuneration details, length of service, job information

Employees, HR

Exit interviews

Contact details, feelings about working at Moodle

Employees

On-boarding

Photograph

Employees

Interview

Answers to questions around previous job and skills

Moodle HR

Central code repository

contact details (name, surname, email, photo), activity and contribution

Data subject

Community education and feedback (moodle.org)

contact details (name, surname, email, photo), activity and contribution

Data subject

Mirror of central code repository

contact details (name, surname, email, photo), activity and contribution

Data subject

Developer code repository

contact details (name, surname, email, photo), activity and contribution

Data subject

Developer code repository (Local git repositories on dev machines)

contact details (name, surname, email, photo), activity and contribution

Data subject

Sharing of rapid prototypes, research artefacts, usability testing feedback

Contact details, activity, contribution

Employee

Conduct user studies, interviews, and surveys

Contact details, activity, contribution

Employee

Conduct user surveys, Mobile – Support for Airnotifier websites

Contact details, form entries,

Data subject

Scheduler for usability testing & user interviews

Name, email, Contact details, schedules, location data

Data Subject, Employees

Hosts the usability tests and user interview recordings

Contact details, biometric, video, voice recording,

Data Subject, Employees

Community engagement & recruitment for user studies

Contact details, activity, contribution

Data Subject, Employees

Community engagement & recruitment for user studies

contact details (name, surname, email, photo), activity and contribution

MOBILE – Training in Moodlemoots

contact details (name, surname, email, photo), activity and contribution

Data subject

Paying wages to employees

Contact details (name, surname and email), Bank details, Tax details, sick leave, Annual Leave, salary, pension

Employee

Collecting fees payable by direct clients

Contact details (name, surname and email)

Client

Collecting fees payable by partners

Contact details (name of partner, email, name and surname of partner representative)

Partner

Receiving event registration fee

Contact details (name, surname, email of the participant, phone number, business name and address)

Attendee

Paying supplier invoices

Supplier details (name, surname, email, bank details)

Attendee

Individual’s Profile on Moodle Partner site

Contact details

Data subject and data subject employer

Individual’s data on Moodle Partner website

User and activity data

Data subject, Controller

Partner Marketing Support

Partner details, Location, Date, Times

Data subject

Partner Marketing Support

Client details, Partner details

Data subject, data subject employer, Partner organisation

Partnership support conference calls

Name, Voice Recording, Video/Photograph of user

Moodle HQ – Moodle Partner website Data

Partner Organisation Profile on Moodle Partner site

User details, Partner Organisation details

Partner Organisation provides info and manages it

Partnership team commercial discussion about Partners and sectors

HQ Organisation details, Partner Organisation details, names, emails, addresses

Controller(s) – Moodle Pty Employees (Moodle HQ) and for contractors ->themselves or company.

Partnership team discussion

Partner Organisation details

Controller(s) – Moodle Pty Employees (moodle HQ) and for contractors ->themselves or company.

Moodle HQ team communications

Contact details and any other as comes up in emails

Controller

Moodle HQ team communications

Contact details

Controller

Moodle Client Customer financial data from Partners

Client details, Partner details

Moodle Partner

Moodle Client Customer financial data from Partners

Client details, Partner details

Moodle Partner

Lead / Customer Information

Contact Details

Data Subject

writing and storage of agreements/contracts/documentation with partners, and potential partners

Contact details

Moodle Partner / Applicant

General Business Documentation of meetings including attendees

Partner Organisation details, Partner details, Partner Employees

Controller

General Business Documentation

Partner Organisation details, Partner details

Controller

General Business Documentation

Partner Organisation details, Partner details

Controller

log storing and searching for analysing and troubleshooting MoodleCloud sites and signup/provisioning

Location, IP address

MoodleCloud site admins and MoodleCloud site users

Storing of historical logs – moodle, web server, statistics

website name, location, IP address

MoodleCloud site admins and MoodleCloud site users

Facilitating the signup and control of the MoodleCloud account

Name, email, location, telephone number

MoodleCloud site admins

Primary provider for text messaging. Logs for text message sending

Phone numbers

MoodleCloud site admins

Email processing (Moodle and signup)

email

MoodleCloud site admins and MoodleCloud site users

Backup text messaging service. Data processed by Twilio

Phone numbers

MoodleCloud site admins

News, Updates, Product tip emails subscriber lists (opt in)

Name, email

MoodleCloud site admins

Email sent to site admins regarding their MoodleCloud service

Name, email, financial data

MoodleCloud site admins

Operational reporting on cloud servers and moodle sites

Location, IP address, moodle activity data

MoodleCloud site admin

Recurring subscriptions and Payment

name, email, country

MoodleCloud site admins

Billing engine and subscription management

contact details, country, website name

MoodleCloud site users

Assignment submission document converter (when students submit assignments in various file formats, this process converts them into PDF file so the teacher can grade and annotate the document)

could be any data submitted in the file

MoodleCloud site users

Webconferencing feature for all MoodleCloud sites

contact details, voice, audio, video, biometrics, IP address, location data

MoodleCloud site users

Authentication, Design, development and tracking of Moodle code, profile published on Tracker site, notifications

Contact details, biometric (avatar)

Data subject

Authentication, profile published, notifications

Contact details, biometric (avatar), any details provided by user

Data subject

Authentication, notifications

Contact details, biometric (avatar)

Data subject

Statistics and error recording

IP Address, error logged messages potentially including usernames, and usage records

Website records

Business Development statistics generation

Data compiled from other listed data sources

Website records

Making and receiving phone calls

Call metadata including phone numbers and time & call duration

telephone records

Making and receiving phone calls

Call metadata

telephone records

Authentication, documents, usage, emails

Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records

Data Subjects, Moodle HQ

Communication in and outside of company

Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records

Data Subjects, Moodle HQ

Communication in and outside of company

Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records

Data Subjects, Moodle HQ

Internal HR functions, leave and communications

HQ personal staff information, leave information, communications details

Data Subjects, Moodle HQ

Partner billing, record keeping and communications

HQ authentication information, contact details, Moodle partner contact details, client statistics & invoicing

Data Subjects, Moodle HQ

Purchasing various services (domains, etc)

Profile data and credit card for Moodle HQ Staff or Contractor

Data Subjects, Moodle HQ

Licenses for software

Personal contact information, cloud stored work may have personal data in it

Data Subjects, Moodle HQ

Notifications of critical ICT events

Moodle HQ person information, possible data in alert if relevant to alerting

Data Subjects, Moodle HQ

Authentication, subscribed marketing & security notifications, bounce records, read and open records, link click records

Personal contact information (Name & Email)

Data Subjects, Moodle HQ

Billing & Purchasing

Billing information including name, addresses, order information

Data Subjects, Moodle HQ

Authentication, document management & office license

Contact Details, IP addresses

Data Subjects, Moodle HQ

Hosting corporate infrastructure

HQ Person information, all data covered by other register entries.

Data Subjects, Moodle HQ

Legacy ticketing system

Contact details, biometric (avatar), any details provided by user

Data Subjects, Moodle HQ

Ticketing System / Public Comms Hub

Contact details, biometric (avatar), any details provided by user

Data Subjects, Moodle HQ

CRM for Services team

Contact details, contract details with partners, any other information related to partnership with Moodle HQ

Data Subjects, Moodle HQ

Monitoring

No personal data, just system level metrics

Data Subjects, Moodle HQ

Authentication, Database/API query derived statistics

Contact details

Data Subjects, Moodle HQ

Credential and secure information store

Username and passwords for cloud services, may contain other notes

Data Subjects, Moodle HQ

Public site spam prevention

User contributed content (forum posts)

Data Subjects, Moodle HQ

DNS and Denial of Service Protection (gradually being phased out)

Website usage and all passed traffic data

Data Subjects, Moodle HQ

Voice and Video Meetings

Moodle HQ Employee contact information and recorded video

Data Subjects, Moodle HQ

Monitoring sites

Email address & Name for Authentication

Data Subjects, Moodle HQ

Virus & Malware scanning for Windows Users

Email address, Name, Scan data from local computer

Data Subjects, Moodle HQ

Moodlebot Telegram Bot (Allows Telegram to interact with Tracker and logs conversation in public chat rooms)

Any data listed in Tracker as well as free form chat

Data Subjects, Moodle HQ

Sharing created courses with other Moodle users worldwide for moodle.net

Profile data for course creators

Data Subjects, Moodle HQ

Notification & Contact Forwarding, Analytics for moodle.com

HQ Staff and Contractor profile information

Data Subjects, Moodle HQ

Moodle Staging Sites for internal use only

Any non-anonymised data from production instances for testing

Data Subjects, Moodle HQ

Test specific features as part of development

Should be no personal data stored, however IP addresses and other data may end up in logs, Moodle will also display IP data in internal logs which is publicly available

Data Subjects, Moodle HQ

Demo most recent version of software to the public

Should be no personal data stored, however IP addresses and other data may end up in logs, Moodle will also display IP data in internal logs which is publicly available

Data Subjects, Moodle HQ

Statistics and Marketing Tracking

IP addresses and logs, site behaviour analytics

Data Subjects, Moodle HQ

Communication about Moodle Moot Events

HQ Staff and Contractor profile information

Data Subjects, Moodle HQ

Ongoing testing of software

Logins for staff, possible other data as test cases

Data Subjects, Moodle HQ

Distribution of software

Source code with names in it and Moodle profiles for HQ Staff and Contractors

Data Subjects, Moodle HQ

Language translations for Moodle

Profile data

Data Subjects, Moodle HQ

Moodle documentation repository

Profile data

Data Subjects, Moodle HQ

Private Moodle Code Repository

Profile Data

Data Subjects, Moodle HQ

Learning Moodle course

Profile data, course results

Data Subjects, Moodle HQ

Public Moodle Code Repository

Profile data

Data Subjects, Moodle HQ

Storage of documents and other communications

Free form storage of documents, so any personal data is possible

Data Subjects, Moodle HQ

Home page for Moodle User Association

Profile data

Data Subjects, Moodle HQ

Data collection for applications to be part of the Partner Network

Partner applications, Profile data

Data Subjects, Moodle HQ

Service status notifications

User logins for HQ Staff

Data Subjects, Moodle HQ

User login and other information

Login and other personal profile information

Data Subjects, Moodle HQ

Course hosting service

Login and other personal profile information

Data Subjects, Moodle HQ

Testing accessibility features in Moodle

Login and other personal profile information

Data Subjects, Moodle HQ

Collaborative document/code editing

Open system with varied data as well as user IP addresses

Data Subjects, Moodle HQ

Register of research related to Moodle

Published research documents, login details and profile

Data Subjects, Moodle HQ

Hosting applications for Moodle

Login information

Data Subjects, Moodle HQ

Legacy Moodle sites

Login information

Data Subjects, Moodle HQ

Indexing for search purposes

Any data supplied over our sites network

Data Subjects, Moodle HQ

Collection and processing of anonymized data from third parties

Anonymized data from other institutions as well as login/profile for Moodle HQ employees and contractors

Data Subjects, Moodle HQ

News and information for the Development community

Login and other personal profile information. Details of specific development project participants

Data Subjects, Moodle HQ

Communication to Moodle community

Login and other personal profile information

Data Subjects, Moodle HQ

Accounts for access to software and licensing

Login and other personal profile information

Data Subjects, Moodle HQ