PRIVACY STATEMENT

INTRODUCTION

PLEASE READ THE FOLLOWING CAREFULLY

THIS STATEMENT PROVIDES GENERAL INFORMATION ABOUT THE PRIVACY STATEMENT OF THIS WEBSITE AND ITS RELATED PLATFORMS (MOBILE OR OTHERWISE). IF YOU ARE

UNDER 18 YEARS OF AGE, PLEASE BE SURE TO READ THIS PRIVACY STATEMENT WITH YOUR PARENTS OR GUARDIAN AND ASK THEM QUESTIONS ABOUT WHAT YOU DO NOT UNDERSTAND.

YOUR USE OF THIS SERVICE CONSTITUTES ACCEPTANCE BY YOU OF THIS PRIVACY STATEMENT.

THIS PRIVACY POLICY IS SUBJECT TO CHANGE FROM TIME TO TIME BY UPDATED POSTINGS. THE PRIVACY POLICY IN EFFECT AT THE TIME OF USE OR SUBMISSION OF PERSONALLY IDENTIFIABLE INFORMATION WILL BE APPLICABLE.

 

Pearson Clinical Assessments, a business of Pearson Education Ltd. (“Pearson”) recognises the importance of protecting the privacy of our visitors to this Site while permitting us to conduct legitimate business by providing goods, services and information of interest.

The rights and responsibilities described in our Privacy Policy do not cover third party websites that may be linked to our Site(s) or referred to on this Site(s). These third party websites have their own privacy policies and we encourage you to read and review them.

For purposes of this Privacy Policy “Personal Data” is any information that can be used to identify you or that when added with other Personal Data can be linked to you.

If you have any questions or concerns about the Privacy Statement, please contact us.

 

YOUR RIGHTS AND RESPONSIBILITIES

You agree that by visiting and/or providing, transmitting, or having another party you have authorised provide or transmit your Personal Data to us on any of our Sites, you are accepting the practices described in this Privacy Policy and any updates made to this Privacy Policy. It is your responsibility to read this Privacy Policy and check for updates on a regular basis. By continuing to use our Site, products or services after such updates have been made you are agreeing to be bound by any changes to this Privacy Policy.

You are never required to provide us with your Personal Data. If you do not agree to this Privacy Policy, please do not provide, transmit or allow anyone else to provide or transmit your Personal Data to us; however, if you decide to not provide to us your Personal Data it may affect our ability to provide to you any products or services offered.

You agree that we may collect or receive, use, process, disclose, transfer and retain your Personal Data as described herein. This Privacy Policy governs your use of any and all of our Sites, platforms, and in purchasing our products and services in general. We will use your Personal Data only for the purposes set forth herein.

 

For Educators, Administrators, Qualified Customers, and Test Administrators: 

Pearson is the Data Controller.  As the subject of the Personal Data collected, you have rights related to the Personal Data that we hold about you.

• Right of access. You can ask us for copies of your Personal Data. There are some exemptions, which means you may not always receive all the information we process. These exemptions include situations where the information requested also includes Personal Data about somebody else.  

• Right to rectification. You can ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.  

• Right to erasure. You can ask us to erase your Personal Data in certain circumstances.   

• Right to object to processing. You can object to processing of your Personal Data, including profiling, where we are processing it on the basis of a legitimate interest.  

• Right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us (using the contact details indicated above). 

• Right to restriction of processing. You can ask us to restrict the processing of your information in certain circumstances.  

• Right to withdraw consent. Where we are relying on consent to process your Personal Data, you can withdraw it at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.  

• Right to data portability. This only applies to information you have given us. You can ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on performance of a contract and/or your consent.  

 

For Students and Examinees: 

Pearson is the Data Processor, and the Educational Institution, Qualified Customer, or Test Administrator is the Data Controller.

Students and Examinees should direct any user rights requests related to educational or clinical records and data directly to their educational institution or clinician. As a Data Processor, Pearson cannot delete or modify education records or other records collected or processed for, or on behalf of, a Data Controller, unless it is directed to do so by the Data Controller and, therefore, for any requests submitted to Pearson, we will redirect you to your educational institution or clinician.

 

OUR RIGHTS AND RESPONSIBILITIES

We will provide you access to these Rights and Responsibilities and any subsequent updates.

We encourage you to periodically review this Privacy Policy to learn more about our information practices as they change over time. We reserve the right to update this Privacy Policy periodically, without notice. A change in the effective date will indicate that the Privacy Policy has been updated. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy on our Site(s). Your use of our Site(s), and any of our products and services following such changes constitutes your acceptance of the revised Privacy Policy then in effect.

Depending on the Services, we may collect and process your Personal Data in order to manage day to day business needs including, but not limited to, performing services on behalf of a business, payment processing and financial account management, business planning and forecasting, system improvements, security and fraud prevention, and compliance with legal and regulatory obligations.

Pearson and its subcontractors will at all times protect your Personal Data with appropriate operational, administrative, technical, and physical security safeguards.

We do not disclose your Personal Data to third parties unless otherwise stated below. We do not monetise Personal Data. We have not sold, within the last twelve (12) months, any Personal Data collected through this site, except to the extent that third party targeted advertising cookies are ultimately determined to involve a sale of Personal Data under California law. We currently do not enable third party targeted advertising cookies on this site. The following categories of Personal Data may have been collected and shared through such cookies and related technologies during the past 12 months within the digital advertising ecosystem: Identifiers (limited to a numeric identifier, such as an IP address) Commercial Information, Internet or Similar Network Activity, Geolocation Data and Inferences draw from other Personal Data.

 

COLLECTION AND STORAGE OF INFORMATION ON THIS SITE

We will collect certain Personal Data during different activities on this Site or otherwise, such as user registration, when you purchase materials, participate in a survey, contact us with questions or offer feedback on the Site. In connection with such activities, you may be asked to provide certain information such as your name, mailing address, telephone number, fax number, credit card number and email address. In order to qualify for the purchase of materials we may also request professional qualifications, affiliations or employment information. We may maintain this information in our computer and ordering system.

 

PLATFORM AND SYSTEMS INFORMATION

CLINICAL ASSESSMENTS

Q-global® and Q-interactive®

Q-Global is a testing system that quickly and efficiently administer assessments, generate scores, and produce reports. Q-Global is a web-based system and is accessible from any computer. Q-interactive is a comprehensive digital system that can be used to administer and score tests traditionally given by an examiner in one-on-one settings.

 

Definitions

“Qualified Customer” means a qualified clinician, professional, clinic or institution, which has an agreement with Pearson to use this system for administration, scoring or reporting of certain assessments and complies with Pearson’s Terms and Conditions of Sale and Use, Software License, and meets Pearson’s Qualifications to Purchase.

“Test Administrator” means a Qualified Customer or an individual designated and authorised by the Qualified Customer to coordinate and manage the assessment and scoring process and/or receive assessment test results and reports.

“Examinee” means an individual who is assigned or administered a clinical assessment by a Test Administrator.

 

Access and Information Correction

Qualified Customer access to this system is restricted by password to Test Administrators designated and authorised by the Qualified Customer. The Qualified Customer authorizes the level and extent of access provided to each Test Administrator. Examinees assigned to take a clinical assessment through this system may be provided with access to the assigned assessment administration window only by, and under the supervision of, an authorised Test Administrator.

Test answers are not subject to change by anyone after the test report has been generated. Through this system, an authorised Test Administrator has the capability to access and correct Personal Data otherwise collected through this system.

 

Data Collection, Use and Lawful Basis

In providing tests and testing services through this system, We collect or receive Personal Data from Examinees, as well as Test Administrators. Certain Examinee Personal Data is provided to us by the Test Administrator; and other information is provided to us by the Examinee. Test Administrator Personal Data is provided to us by the Qualified Customer and the Test Administrator. We use Personal Data in order to administer and score the tests, provide test results to the Qualified Customer and authorised Test Administrators and provide reports and invoices to the Qualified Customer and authorised Test Administrators. We will handle and treat all Personal Data collected and received by us through this system in the manner outlined in this Privacy Policy.

Processing where Pearson acts as a Data Controller 

Processing where Pearson acts as a Data Processor

If you are an Examinee, your Personal Data will only be used in accordance with the Data Controllers (Qualified Customer / Test Administrator) instructions. This typically involves: 

• processing your Personal Data to provide the Services. 
• to communicate with Examinees regarding service updates and in accordance with this privacy policy; 

The Personal Data that We collect, receive or process with respect to Examinees may include: first name, last name, Examinee ID (as assigned by a Test Administrator), date of birth, gender, race/ethnicity, handedness and home language. In addition, depending upon the particular clinical assessment, a wide range of additional demographic information may be collected, including, but not limited to: clinical history; education history and issues; work and employment status, history and issues; health conditions; medications; employment status; marital status; family information and history; and living arrangements. Through this system, We collect and score the responses to the clinical assessment questions and derive raw scores and test scaled or percentile scores.

The Qualified Customer and the Test Administrator assigning and administering tests are responsible to obtain all legally required consents from Examinees and, if applicable, their parents or guardians, for the collection and processing of data through this system.

For more information please visit the privacy notice on the website of your educational institution or test administrator who provided you with access to our Services.

Aggregation of Non-Personally Identifiable Data. We will never use any personally identifiable information in any manner without Your prior permission. However, We may, request to use non-personally identifiable statistically aggregated data raw test data and other information collected in the testing process for our research, quality control, operations management, security and internal marketing purposes and to enhance, develop or improve tests and testing processes.

Retention of Information

Through this system, the Qualified Customer can establish the time period parameters for retaining Examinee test data and Examinee Personal Data on this system. The Qualified Customer has the flexibility to archive or export Examinee test data and Examinee Personal Data at any time.

Transmission of Information

Data collected and received by us in connection with the delivery of assessments may be transmitted to Canada, the United States, and other countries. The Personal Data for the Q-Global and Q-Interactive systems are located in Canada, which has been deemed an adequate country for the protection of data by the UK ICO and the European Commission. In the event a customer is using the Conners 4th edition through the Q-global system, data necessary to provide the scoring services only for the Conner 4th edition will be temporarily processed in the United States. The Internet is a global environment. By using this system and sending information to us electronically, You consent to transborder and international transmission of any Personal Data collected or processed through this system.

 

INFORMATION DISCLOSURE AND TRANSMISSION OF DATA

Except for the limited exceptions set forth below, Pearson will not share with, or disclose to, third parties the names of users, examinees or other personally identifiable information collected through or in connection with this Site. Pearson may, however, use or disclose personally identifiable information:

As requested or required by the Qualified Customer or Test Administrator in support of the platform’s purpose.

In response to subpoenas, court orders or legal process, and as otherwise required by law;

To protect examinee or user security, or the security of other persons, consistent with applicable laws;

In connection with the sale, joint venture or transfer of some or all of the assets of NCS

Pearson, Inc., subject to written approval from the Educational Institution; and/or

To affiliated companies and contractors providing services for the Assessment Program who are obligated to take appropriate commercially reasonable steps to maintain the confidentiality of such information and use it solely for the purposes specified in this Privacy Policy.

Non-personally identifiable aggregated information collected through this website may be disclosed to third parties, unless otherwise specified for a particular product above.

 

DATA RETENTION

Unless otherwise specified for a particular product above, we will retain data as long as our Qualified Customer and the Test Administrator require us to retain this data.

 

COOKIES AND OTHER ONLINE DATA

The Internet is a global environment. By using this site and sending information to us electronically, you consent to transborder and international transmission of any data that you choose to submit, including transmission within and to the United States, where our computer operations are currently based.

With the use of cookies and other technologies, Pearson may receive and store certain types of information about you whenever you interact with this Service.

Cookies are small text les that we transfer to your hardware, through your web browser or app, to (a) speed your navigation on the Service, (b) recognize you and your access privileges, (c) track your usage and preferences of the Service, (d) detect the existence of any cookies previously set by our server, and (e) identify certain information on how and when you accessed the Service such as type of browser, operating system, domain names, IP addresses and the like. The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer. However, cookies allow you to take full advantage of this Service (disabling cookies may prevent proper functioning of certain parts of the Service), and we recommend that you leave them turned on. We currently do not enable third party targeted advertising cookies on this site, except to the extent that the third party uses the information solely as a service provider to Pearson.

Pearson may also use single pixels images, web beacons and other similar technology (collectively “Beacons”) to (a) track your usage of the Service, (b) track response rates to certain activities and promotions within the Service and in marketing campaigns, and (c) identify certain information on how and when you accessed the Service such as type of browser, operating system, domain names, IP addresses and the like.

 

Sharing of Non-Personally Identifying Information with Third Parties

Pearson may share with third parties (including advertising companies and networks) any anonymised information collected through the Service, including those collected through the use of cookies and Beacons technology. In such instance, we do NOT provide such third parties with any personal data about you or any other users of the Service.

BY USING THE SERVICE, YOU AGREE THAT PEARSON MAY USE, LICENSE AND OTHERWISE DISTRIBUTE ANY SUCH NON-PERSONALLY IDENTIFIABLE INFORMATION (ANONYMISED DATA) AVAILABLE ON THIS SERVICE, WHETHER COLLECTED BY PEARSON OR A THIRD PARTY, TO ASSIST IN MARKET EVALUATION, PRODUCT ASSESSMENT AND IMPROVEMENT, EDUCATIONAL RESEARCH, AND FOR OTHER MARKETING AND COMMERCIAL PURPOSES AS REASONABLY DETERMINED BY PEARSON.

IP Addresses

An IP address is a number that is assigned automatically to your computer whenever you use the World Wide Web. Web servers – the big computers that “serve up” Web pages – automatically identify your computer by its IP address. Pearson collects IP addresses for system administration; to report aggregate information to our advertisers, sponsors, and partners; and to audit the use of our Service. When visitors request pages from Pearson sites, our servers log the guests’ IP addresses. We typically do not link IP addresses to anything personally identifiable. This means that a visitor’s session will be logged, but the visitor remains anonymous to us. We can and will use IP addresses to identify a visitor if any of the circumstances mentioned in the above section titled “Sharing Of Personally Identifying Information With Third Parties” occurs.

Do Not Track

This Service does not respond to your browser’s (or app’s) “do-not-track” signals or comparable signals or mechanisms. Please check our Privacy Statement frequently as this may change in the future.

Third-Party Promotional Activities

Within the Service, Pearson may offer contests, sweepstakes or promotions that are sponsored by third-party advertisers or sponsors. These third parties may obtain personally identifiable information that users voluntarily submit while participating in the activity. Pearson does not control the third parties’ use of such information so you should read their privacy policy before participating in such activities.

Links to Third-Party Sites

Links from the Service can take you to other Pearson sites – School, Higher Education, Professional, Global, among others – as well as to third-party sites and resources (collectively, “Other Sites”). The information practices of such Other Sites are not covered by this Privacy Statement or any other policies or terms of this Service. Please make sure to review such Other Site’s terms of use and privacy policies prior to interacting with such sites.

Public Forums

Pearson may make chat rooms, forums, message boards, web pages, and/or public spaces available to its users. Please remember that any information that is disclosed in these areas may become public information but, regardless, may be available to other users of the Service and may be used by Pearson. Consequently, you should carefully consider whether to disclose your Personal Data in such public areas.

Security, Purchases and Credit Card Use

Pearson and its subcontractors will at all times protect your Personal Data with appropriate operational, administrative, technical, and physical security to protect the loss, misuse, and alteration of the information under our control. Essentially, we encrypt all transmission of sensitive data and secure all of our repositories of data. When you use your credit card to shop at Pearson, your transaction is secure. For the purposes of handling credit card transactions, we have contracted with a PCI DSS compliant ecommerce partner. Our servers use Secure Sockets Layer (SSL), an advanced encryption technology that works with most major browsers. This technology safeguards your Personal Data and privacy. However, you should understand that “perfect security” is never guaranteed.

Nature of Data on the Internet

Due to the complexity and open nature of the Internet, there is always a risk that information collected by and/or displayed on the Service may be compromised or accessed notwithstanding the implementation of reasonable data security measures by Pearson. To mitigate such risks, you should (a) use secure usernames and passwords and carefully protect them from disclosure; and (b) implement updated internet security and virus protection software on your computer system. Should you suspect that your computer’s security has been compromised or that your username or password may have been accessed by a third party, please contact us immediately and request to have your password changed.

Cross-Border Transfer of Data

Any personally identifiable information you provide to Pearson in connection with this Service will be stored on Pearson’s servers or those of its affiliates and/or authorised vendors and will be accessible by authorised employees, agents and contractors of Pearson and its affiliates and authorised vendors. Due to the global nature of the Service, personally identifiable information may be transmitted, stored or processed in a country other than the one in which you reside (“Resident Jurisdiction”), including primarily in the United States, the European Union and India. Reasonable contractual or other measures Pearson may take to protect your personally identifiable information while outside the Resident Jurisdiction are subject to applicable foreign legal requirements, for example, lawful requirements by governmental authorities or court order to disclose personally identifiable information to government authorities in the countries in which such data may be stored or processed. SUBJECT TO APPLICABLE LAW, IF YOU RESIDE IN THE EUROPEAN UNION, CANADA OR OTHER JURISDICTION WITH SIMILAR DATA TRANSFER REGULATIONS, BY ACCEPTING THE TERMS OF THIS AGREEMENT, YOU EXPLICITLY CONSENT THAT THE PERSONALLY IDENTIFIABLE INFORMATION YOU PROVIDE MAY BE TRANSFERRED AND STORED IN COUNTRIES OUTSIDE THE EU, CANADA OR YOUR RESIDENT JURISDICTION, INCLUDING THE UNITED STATES, IN CONNECTION WITH THE TERMS OF USE, THIS PRIVACY STATEMENT, AND IN ORDER TO PROVIDE SERVICES TO YOU. IF YOU DO NOT CONSENT, PLEASE DO NOT PROVIDE US WITH ANY PERSONAL DATA. YOUR PERSONAL DATA SHALL ONLY BE USED IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY STATEMENT.

 

SITE AND CONTENT OWNERSHIP

This Site is owned and operated by Pearson Education Limited. The content thereof is protected by copyright of Pearson and/or its licensors.

 

CHANGES TO THE PRIVACY POLICY

We reserve the right to change the terms of this Privacy Policy from time to time by posting an updated Privacy Policy. We encourage You to review this Privacy Policy from time to time for any changes or updates.

 

CONTACT INFORMATION

If you have any questions or comments about this Privacy Statement or your rights, please contact us at dataprivacy@pearson.com.