Privacy Policy

Last Updated: 16 November 2024

Faith, Hope & Love Ministries (FHLM) is committed to safeguarding your privacy and ensuring the protection of your personal data. This Privacy Policy outlines how we collect, use, and protect your information in compliance with data protection laws, including the General Data Protection Regulation (GDPR) in the EU, the Protection of Personal Information Act (POPIA) in South Africa, and the California Consumer Privacy Act (CCPA) in the United States.

1. Information We Collect

We may collect the following types of personal data:

  • Personal Identification Information: Name, email address, phone number, and postal address.
  • Demographic Information: Age, gender, and location.
  • Usage Data: Information about how you use our website and services, including browsing activity and preferences.
  • Technical Data: IP address, browser type, operating system, and device information.

2. How We Collect Information

We collect personal data through:

  1. Direct Interactions: When you fill out forms, register for courses, or communicate with us via email, phone, or chat services.
  2. Automated Technologies: Using cookies, tracking pixels, and similar technologies when you interact with our website. These technologies allow us to collect information such as browsing patterns, device identifiers, and preferences.
    • Note: Disabling cookies may limit functionality, including course progress tracking and certification confirmation.
  3. Third Parties: From affiliated organisations such as Christian Leaders Alliance, Christian Leaders Institute, and Christian Leaders Soul Centres.

3. Use of Personal Data

We use your personal data to:

  • Provide and manage our services, including FHLM Equip courses.
  • Communicate updates, newsletters, and information relevant to your interests.
  • Improve our website, services, and overall user experience.
  • Conduct assessments, issue certificates, and ensure compliance with academic and administrative requirements.
  • Protect our legal rights, meet regulatory obligations, and comply with applicable laws.

4. Automated Services and Proctoring

To maintain academic integrity and ensure a fair assessment process, FHLM requires the use of automated proctoring technologies for course-related evaluations. Participation in proctoring is a condition of enrolment in courses where assessments require it. These services involve the collection and processing of data as outlined below:

  1. Data Collected:
    • Video: Live or recorded footage from your webcam to monitor your environment during the assessment.
    • Audio: Microphone recordings to detect unauthorised assistance or background noise.
    • Screen Activity: Recording of on-screen actions to prevent unauthorised resources during assessments.
    • Metadata: Device and session data, such as IP address, browser details, and time stamps.
  2. Purpose of Data Collection:
    • To verify the identity of participants.
    • To ensure compliance with assessment rules.
    • To maintain a secure and fair testing environment for all participants.
  3. Data Storage and Security:
    • All proctoring session data is securely stored on GDPR-compliant servers.
    • Data is encrypted during storage and transmission to prevent unauthorised access.
    • Access to data is restricted to authorised personnel or external reviewers when required for compliance or dispute resolution.
  4. Data Retention:
    • Proctoring data will be retained for a minimum of six months to address any disputes, appeals, or compliance requirements.
    • After the retention period, all data will be securely deleted unless otherwise required by law or accreditation standards.
  5. Mandatory Consent:
    • Participation in automated proctoring is mandatory for all assessments that require it and constitutes a condition of enrolment in such courses.
    • By enrolling in these courses, users agree to the collection and processing of their data as outlined in this policy.
    • Failure to participate in required proctoring sessions will result in ineligibility for certification or assessment completion.
  6. Your Rights:
    • You may request access to your proctoring session data or seek clarification on how it was processed by emailing legal@fhlm.org.
    • Objections to the use of proctoring technologies will not be accommodated for courses where proctoring is mandatory.
  7. Third-Party Service Providers:
    • FHLM partners with trusted proctoring service providers that comply with GDPR, CCPA, and POPIA standards. All service providers are subject to strict data protection agreements to ensure confidentiality and security.

5. Legal Basis for Processing

Our processing of your personal data is based on:

  1. Consent: When you provide explicit consent for specific activities (e.g., receiving newsletters or participating in assessments).
  2. Contractual Necessity: For fulfilling agreements, such as enrolling in and completing courses.
  3. Legal Obligation: To meet statutory and regulatory requirements.
  4. Legitimate Interests: For purposes like improving our services, provided these interests do not override your rights.

6. Data Sharing

We may share your personal data with:

  • Affiliated Organisations: Christian Leaders Alliance, Christian Leaders Institute, and Christian Leaders Soul Centres, to deliver seamless service.
  • Service Providers: Third-party vendors that provide services like cloud hosting, analytics, and payment processing. All vendors are subject to data protection agreements.
  • Legal Authorities: If required by law, or to protect FHLM’s rights and interests.

7. International Data Transfers

As a global organisation, FHLM ensures data transfers comply with:

  • GDPR: Using Standard Contractual Clauses (SCCs) for EU data transfers.
  • CCPA: Implementing adequate safeguards for data transfers to the US.
  • POPIA: Ensuring equivalent data protection measures for South African users.

Where proctoring or hosting services are based outside your jurisdiction, FHLM guarantees compliance with applicable data transfer regulations.

8. Data Security

FHLM implements robust technical and organisational measures to protect your data from unauthorised access, disclosure, or alteration. These include:

  • Encryption of sensitive data.
  • Regular security assessments and audits.
  • Role-based access controls for internal systems.

9. Data Retention

FHLM retains personal data based on its intended purpose and applicable legal requirements:

  1. Course Data, Account Information, and Certification Records:
    • Retained for 10 years to ensure verification of certifications and academic history.
    • Deletion requests within this period may result in certificate invalidation.
  2. Financial Records:
    • Retained for 7 years in compliance with accounting and tax laws.
  3. Data Deletion:
    • Upon account closure, FHLM will delete personal data unless retention is legally required.

10. Your Data Protection Rights

In line with GDPR, POPIA, and CCPA, you have the following rights:

  • Access: Request a copy of your personal data.
  • Rectification: Correct inaccurate or incomplete data.
  • Erasure: Request deletion of data, subject to legal obligations.
  • Restriction: Limit processing under specific circumstances.
  • Objection: Object to processing for specific purposes.
  • Portability: Request data transfer to another organisation.
  • Consent Withdrawal: Revoke consent at any time.
  • Lodging Complaints: Contact relevant authorities for disputes.

Requests:

  • All requests must be sent to legal@fhlm.org. Verification of identity is required.

Response Times:

  • GDPR/POPIA: 30-60 days.
  • CCPA: 45-90 days.

11. Cookies and Tracking Technologies

FHLM’s website uses cookies to:

  • Enhance functionality (e.g., course tracking).
  • Analyse performance and user engagement.
  • Support security measures.

Disabling cookies may affect your user experience and certification eligibility. Refer to our Cookie Policy for details.

12. Changes to This Privacy Policy

FHLM reviews this policy regularly to reflect updates in legislation or organisational activities. The latest version is always available on our website.

13. Contact Us

For any questions or concerns regarding this Privacy Policy or our data practices, please contact us at:

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