The Revolution Media is committed to protecting and respecting the individual's right to privacy in relation to the collection, management, storage, use and disclosure of personal information, and ensuring the accuracy and security of any personal information it holds regardless of whether the personal information relates to staff, students, contractors or visitors.
The Privacy and Confidentiality policy informs how Revolution Media processes personal information:
i. Personal information provided to Revolution Media
ii. Personal information Revolution Media collects about the individual
iii. Personal information Revolution Media obtains from other sources.
By submitting personal information to Revolution Media, or using Revolution Media ’s services, the individual is accepting and consenting to the practices described in this policy.
For the purpose of the Protection of Personal Information Act 4 of 2013, the the responsible party is Revolution Media for Higher Education.
An HTTP cookie (also called web cookie, Internet cookie, browser cookie) is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing
In South Africa fraud is defined as “the unlawful and intentional making of a misrepresentation which causes actual and or potential prejudice to another”
IP (Internet Protocol) address
An IP address is a set of numbers which is assigned to the user’s computer during a browsing session whenever the user logs onto the Internet via their internet service provider
or their network (if they access the Internet from, for example, a computer at work)
Information about an identifiable individual, such as name, age, date of birth, home address and phone number, marital status, financial information and details of one’s involvement with the institution
A protocol for specifying addresses on the Internet; an address that identifies a particular file on the Internet, usually consisting of the protocol, as http, followed by the domain name
3. LEGISLATIVE CONTEXT
The Privacy and confidentiality Policy is benchmarked against and should be read in the context of the relevant legislation underpinning the principles against which institutional policies, processes and standard operating procedures are developed, implemented and maintained. These include:
i. Companies Act 71 of 2008
ii. Electronic Communications and Transactions Act 25 of 2002
iii. Protection of Personal Information Act, No 4 of 2013
iv. Promotion of Access to Information Act 2 of 2000
v. South African Constitution No. 108 of 1996.
Revolution Media Policies:
vi. Acceptable use of Information Systems
vii. Communication and Media
ix. Information Security
xi. Records and Administration Management
xii. Social Media
xiii. Wireless Communication.
This policy refers to all individuals or groups utilising Revolution Media ’s resources and includes the following parties:
4.3. Temporary staff
4.6. Members of the public
4.7. Any other party utilising Revolution Media’s resources.
Revolution The media respects individual privacy and the laws governing it and remains committed to protecting and safeguarding the personal information of students, staff, alumni, donors and others who access its products and services. This policy affirms the institution’s commitment to maintaining that privacy and to inform interested parties of the institution’s policies and practices in protecting such personal information.
Revolution Media’s privacy commitment includes ensuring the accuracy, confidentiality and security of personal information and allowing individuals to request access to, and correction of their personal information.
6. PERSONAL INFORMATION
The institution may collect information provided in writing (including via electronic media) or verbally about its students, faculty, alumni, donors and others who access its products and services and does so for the following purposes, depending upon the specific circumstances:
i. Maintaining a record of one’s involvement with the institution
ii. To respond to requests for information, counselling and guidance
iii. To provide instruction, mentoring, counselling and follow up activities for students
iv. Communicating with and understanding the needs of students, staff, alumni and their
v. To deliver requested products and services
vi. Fund-raising and institutional advancement activities
vii. Recording and processing of donations and gifts
viii. Meeting any legal, accreditation or regulatory requirements ix. Analysis of data for
x. Other purposes consistent with the aim to fulfil the institution’s mission.
7. PERSONAL INFORMATION PROVIDED TO REVOLUTION MEDIA
Revolution Media may receive personal information by any of the following means:
i. Individuals filling in forms available on the Revolution Media website, or at its offices
ii. Corresponding by phone, e-mail or other means
iii. When registering a student
iv. Completing a form to contact Revolution Media
v. Subscribe to Revolution Media ’s services
vi. Participate in Revolution Media ’s social media forums
vii. Linked to Revolution Media ’s website
viii. Completing a survey
ix. Reporting a problem via Revolution Media ’s website.
8. PERSONAL INFORMATION COLLECTED BY REVOLUTION MEDIA
When visiting the Revolution Media website, information may be collected automatically by the following means:
8.1. Technical information, including the Internet protocol (IP) address used to connect the computer to the Internet, the user’s login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
8.2. Information about the web visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from Revolution Media ’s site including date and time; services/products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, and any phone number used to call the customer service number.
8.3. Information received when a student is registered, or if authorised to collect information from selected third parties (i.e. from bursaries or sponsorships). In this case, Revolution Media would have informed the individual when the information was collected, and that it may be shared internally, and combined with information collected on the website.
8.4. Information from third parties Revolution Media is working with. Revolution Media may receive information about the individual from third parties including business partners, sub-contractors, payment and delivery services, advertising networks, analytics providers, information search providers, credit reference agencies and contract staff.
9.1. Cookies may be used by Revolution Media to understand the users of their site better. Cookies allow Revolution Media to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited, and
to determine the most popular areas of the site. Depending on the type of cookie used (persistent or session cookies), cookies also allow the sites to be more user friendly; permanent cookies allow to save the user’s password so that the user does not have to re-enter it every time the user visits the specific site.
9.2. Users can usually adjust their browser so that their computer does not accept cookies. If this is done, the user will still be able to browse around the site, but the functions that allow access to an existing account or page that requires a username or password, will not be available.
9.3. Users can adjust their browser to inform the user when a website tries to put a cookie on their computer. How the users adjust their browser to stop it accepting cookies, or to notify the user, will depend on the type of internet browser programme their computer uses.
9.4. Cookies do not contain personal information such as the user’s home address, telephone number or credit card details, but the personal information that is stored about the user may be linked to the information stored in, and obtained from cookies.
9.5. The user’s browser also generates other information, including which language the site is displayed in, and their Internet Protocol address (IP address). The user’s IP address is automatically logged by Revolution Media’s servers and used to collect traffic data about visitors to its sites. Revolution Media does not use the user’s IP address to identify them personally.
9.6. Revolution Media will only keep cookies for the duration of the user’s visit to its site.
9.7. Revolution Media does not exchange cookies with any third-party websites or external data suppliers.
10. THE USE OF PERSONAL INFORMATION
Revolution Media uses the information held about the user in the following ways:
10.1. Carry out Revolution Media ’s obligations (whether day-to-day administration or educational, social and health needs obligations) arising from any contracts entered into between the user and Revolution Media , and to provide the user with the information and services that they request from Revolution Media
10.2. Provide the user with information about their child’s education and associated matters
10.3. Provide the user with information about other services on offer that are similar to those that they have already acquired or enquired about
10.4. Provide the user with information about educational activities.
10.5. Provide the user, or permit selected third parties to provide the user with information about goods or services they feel may be of interest to them:
10.5.1. If the user is an existing customer/registered student, Revolution Media will only contact them with information about goods and services similar to those that were the subject of a previous service provision or service negotiations.
10.5.2. If the user is a new customer/new registered student, and where Revolution Media permits selected third parties to use their information, Revolution Media (or the third party) will contact the user only if they have consented to this.
10.6. Should the user not want Revolution Media to use their information, or to pass their details on to third parties for marketing purposes, the user can ‘tick’ the relevant box situated on the form on that is used to collect the user’s data.
10.7. Revolution Media will not share the user’s information or the information of the student with any third party except as stated in this policy.
11.1. Revolution Media will ensure that content from its site is presented in the most effective manner for the user and their computer.
11.2. Revolution Media will deal with enquiries and complaints made by, or about the user relating to Revolution Media ’s site or other services the users use.
11.3. Measure or understand the effectiveness of advertising served to users and others, and to deliver relevant advertising to individuals who access the site.
11.4. Make suggestions and recommendations to students, staff and other users of Revolution Media ’s site about goods or services that may interest users.
11.5. Allow users to participate in interactive features of Revolution Media ’s service (when users choose to do so).
12. INFORMATION COLLECTED ABOUT USERS
Revolution Media will use the information to:
12.1. Administer its site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
12.2. Improve its site to ensure that content is presented in the most effective manner for Revolution Media and for the user’s computer.
13. INFORMATION RECEIVED FROM OTHER SOURCES
13.1. Revolution Media may combine this information with information provided to Revolution Media and information Revolution Media collects about users. Revolution Media may use this information and the combined information for the purposes set out in this policy.
13.2. Should users provide information on behalf of someone else (i.e. the student or spouse), then it is the user’s responsibility to ensure that they have the authority and/or have obtained the necessary consent from such person/s before making the information available to Revolution Media . On receipt of personal information, Revolution Media assume that the necessary consent has been obtained and will process the personal information as per the user’s instructions. The user indemnifies Revolution Media against any third party claim where a third party claim that personal information have been processed without the necessary consent, or other available exception under the The Promotion of Access to Information Act.
13.3. Revolution Media will only use personal information received for another purpose when:
13.3.1. The user consents thereto
13.3.2. It is in the interest of the user (or their child), i.e. necessary to lessen or prevent a serious or imminent threat to life, health or safety
13.3.3. Is required by law or for law enforcement purposes.
13.4. Where consent for the use and disclosure of personal information is required, Revolution Media will seek consent from the data subject directly.
13.5. In the case of a student’s personal information, then Revolution Media will seek the consent from the student and/ or parent depending on the circumstances and the student’s mental ability to understand the consequences of the proposed use and disclosure.
14. DISCLOSURE OF PERSONAL INFORMATION
14.1. Revolution Media may share the information with:
14.1.1. Any member of its group, which means their ultimate holding company and its subsidiaries, as defined in the Companies Act
14.1.2. Selected third parties including business partners, contract staff; suppliers and sub-contractors for the performance of any contract entered into with them or the user
14.1.4. Advertisers and advertising networks that require the data to select and serve relevant adverts to users and others. Revolution Media does not disclose information about identifiable individuals to their advertisers, but may provide them with aggregate information about their users. Revolution Media may also use such aggregate information to help advertisers reach the kind of audience they want to target. Revolution Media may make use of the personal information that has been collected from users to enable Revolution Media to comply with its advertisers' wishes by displaying their advertisement to that target audience
14.1.5. Analytics and search engine providers and support administrators of Revolution Media ’s Student Management Systems that assist Revolution Media in the improvement and optimisation of their site and SMS.
14.2. Revolution Media may disclose the information to third parties:
14.2.1. In the event that Revolution Media may sell or buy any businesses or assets, in which case Revolution Media may disclose the information to the prospective seller or buyer of such business or assets
14.2.2. If Revolution Media or substantially all of its assets are acquired by a third party, in which case personal information held by Revolution Media about its customers, will be one of the transferred assets
14.2.3. If Revolution Media is under a duty to disclose or share the information in order to comply with any legal obligation, or in order to enforce or apply its
15. STORAGE OF PERSONAL INFORMATION
15.2. All of the information provided to Revolution Media is stored on secure servers or in terms of paper documents, stored in secure locations. Where Revolution Media has given a user (or where a password has been chosen by a user) a password that enables users to access certain parts of the site, they are responsible for keeping this password confidential. Revolution Media requests users not to share a password with anyone. Where a student has been issued with a password, Revolution Media expects the parent to reinforce the necessity for their child to keep his/her password secure.
15.3. Records of information will not be retained for longer that is necessary for operational or archiving purposes for which the information was collected, unless retention of a record is required or authorised by law. Records of the information may be retained for periods in excess of those contemplated for historical, statistical or research purposes, subject to Revolution Media establishing appropriate safeguards against the records being used for any other purpose.
15.4. The transmission of information via the Internet is unfortunately not completely secure. Although Revolution Media will use appropriate and reasonable technical and organisational measurements to protect the information, the security of the users’ data transmitted to Revolution Media ’s site or to any other location by electronic means cannot be guaranteed; any transmission is at the user’s own risk. Once Revolution Media has received the information, appropriate and reasonable technical and organisational measurements will be applied to endeavour to prevent unauthorised access.
16. SOCIAL MEDIA PLATFORMS
16.1. Communication, engagement and actions taken through external social media platforms that Revolution Media , the directors or employees participate in, are custom to the specific terms and conditions as well as the privacy policies held with each social media platform respectively.
16.2. Users are advised to use social media platforms wisely and communicate/engage with due care and caution in regard to their own privacy and personal information. Revolution Media will never ask for personal or sensitive information through social media platforms, and encourage users wishing to discuss sensitive details, or to resolve issues/concerns, to contact Revolution Media through primary communication channels such as by telephone or email.
16.3. The Revolution Media social networks page may share web links to relevant web pages. By default, some social media platforms shorten lengthy URL's. Users are advised to take caution and good judgement before clicking any shortened URL's published on social media platforms by this website. Despite the best efforts to ensure only genuine URL's are published, many social media platforms are prone to spam and hacking, and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
17. INTERCEPTION AND MONITORING OF COMMUNICATIONS
17.1. Revolution Media reserves the right to intercept, monitor, and copy or block communications to and from its communication facilities (including, but not limited to its site, e-mail, SMSs, etc.) in accordance with the relevant provisions of the law.
18. THE RIGHTS OF USERS
18.1. Users have the right to ask Revolution Media not to process the information collected for marketing purposes. Revolution Media will usually inform the user (before collecting their data), if the intention is to use data for such purposes, or if the intention is to disclose the user’s information to any third party for such purposes.
18.2. Users can exercise their right to prevent such processing by checking certain boxes on the forms used to collect user’s data. Users can also exercise their right at any time by contacting the Insights and Growth Marketing and Communications Manager, or use the ‘unsubscribe’ functionality on Revolution Media ’s e-mail communications.
18.3. Revolution Media ’s site may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates (third party websites/social media sites). If users follow a link to any of these websites, Revolution Media does not accept any responsibility or liability for these website’s policies, as these websites have their own privacy policies. The onus is on users to check these policies before they submit any personal information to these websites.
18.4. Users have a right to see/access the information that is kept by Revolution Media . Users may instruct Revolution Media to provide them with any personal information Revolution Media may hold about the user or their child, upon receipt of a written request and payment of a fee as per the Promotion of Access to Information Act 2 of 2000 (PAI Act) (click here to view the PAI Act). It is important to take note that not all information requested may be disclosed. Disclosure of information shall take place in accordance with the PAI Act.
19. QUALITY OF PERSONAL INFORMATION
19.1. It is the user’s responsibility to check the accuracy of the information prior to submission to Revolution Media . On receipt of the information, Revolution Media will assume that the user has checked it, and that the information is accurate.
19.2. The user has to contact the Registry if the information that is held about a user/the student needs to be corrected or updated. The request to update information may take up to 48 (forty eight) hours to execute;
19.3. Revolution Media will endeavour to the best of its ability to make available to the user any means to amend the information by the user self.
20. REVIEW OF THIS POLICY
Regular review and amendment of this policy will be done in line with the approved institutional policies. This will take place in consultation with the relevant quality assurance structures at departmental and institutional level, under the auspices of the official custodian of this policy, namely the Registrar.