This is the privacy policy ("Policy") of Teneo Education Proprietary Limited (“Teneo”, "us" or "we").
It sets out the manner in which we collect and use the information that we have about you (referred to as “you” or a “Parent” or prospective Parent or, where the person referred to is the one responsible for payment, a “PRFP”) and any minor child on behalf of whom you make an enquiry or enrolment application or that is currently enrolled at Teneo (referred to as a “Learner”), as well as your rights relating to that information. This Policy applies to the use of any Teneo website as well as its learning management system and all portals, and applies to pre-enrolment interactions, including when a person submits an enquiry form, downloads a document, uses a fee calculator, registers for an event, asks to be contacted or otherwise provides information to Teneo through any of its websites or portals. It also reflects the relevant provisions of Teneo’s Terms and Conditions.
Where this Policy refers to "Personal Information", this means personal information as defined in the South African Protection of Personal Information Act (“POPIA”) or other applicable law, which is, broadly speaking, information that may be used directly or indirectly to identify you.
1. General notice by use of websites and forms.
When submitting any form, downloading any document, using a fee calculator, or completing any registration or enrolment process on Teneo's websites or portals, the Parent or prospective Parent, and where applicable the Parent on behalf of the Learner and/or PRFP, acknowledges that this Policy is applicable to that interaction and acknowledges that Teneo will collect and process personal information as described in this Policy. Processing that is necessary to respond to an enquiry, take steps towards enrolment, perform the agreement, comply with law, protect vital interests or pursue legitimate interests does not depend solely on consent.
2. Responsible party and controller.
Teneo is the responsible party or controller of personal information processed for the purposes described in this Policy. Teneo may be contacted at help@teneoeducation.com. Where applicable law requires Teneo to appoint a representative, such as an Information Officer, that representative's details will be published on Teneo's website and may be obtained using the same email address.
3. Categories of personal information.
Teneo may collect and process personal information relating to prospective and current Learners, Parents, PRFPs and website users, including:
3.1. identity, age, date of birth, nationality, language, contact and address information;
3.2. Parent, guardian, family, emergency contact, custody and guardianship information;
3.3. application, enrolment, attendance, timetable, subject, academic, assessment, progression, conduct and disciplinary information of the Learner;
3.4. learning-support, disability, health, medical, mental-health, safeguarding and accommodation information where relevant;
3.5. payment, invoicing, transaction, fraud-prevention and creditworthiness information, excluding complete card details entered directly into a third-party payment gateway;
3.6. lesson recordings, video, audio, images, chat messages, submitted work, communications and support interactions;
3.7. platform, device, browser, network, login, usage, security, monitoring and technical information;
3.8. marketing preferences, enquiry history and engagement with communications; and
3.9. any other information voluntarily provided or reasonably required for the purposes described in this clause.
4. Sources.
Teneo may collect personal information directly from a Learner, Parent, PRFP or website user, and from schools, referees, service providers, payment providers, examination bodies, examination centres, public authorities, public sources and other persons authorised or reasonably expected to provide the information.
5. Purposes and lawful grounds.
Teneo may process personal information in order to:
5.1. respond to enquiries, provide information, assess applications and take steps before enrolment;
5.2. conclude, administer and perform its agreements reached with Parents/Learners/PRFPs, deliver lessons, provide platform access, support learning, assess progress, issue reports and communicate with Parents, PRFPs and Learners;
5.3. manage attendance, conduct, academic integrity, safeguarding, learner welfare, support needs, accommodations, complaints and disciplinary processes;
5.4. process payments, manage accounts, prevent fraud, recover amounts owing and comply with financial, tax and accounting obligations;
5.5. operate, secure, monitor, troubleshoot and improve websites, learning platforms, communications systems and educational services;
5.6. conduct quality assurance, staff training, academic development, educational research, service analytics and product development, using de-identified or aggregated information where reasonably practicable;
5.7. communicate about current and future programmes, courses, events, promotions, updates and other relevant educational offerings or for marketing purposes;
5.8. establish, exercise or defend legal claims, comply with legal and regulatory requirements, cooperate with authorities and protect the rights, safety and property of Teneo and others; and
5.9. carry out any compatible or related purpose permitted by applicable law.
6. Grounds for processing:
Depending on the circumstances, Teneo relies on one or more of the following grounds: consent; contractual necessity; compliance with a legal obligation; protection of the data subject’s legitimate interests; Teneo's or a third party's legitimate interests; and any other ground available under applicable law. Teneo's legitimate interests include operating and improving an online school, maintaining academic standards and integrity, protecting Learners and systems, preventing fraud, communicating with existing and prospective customers, and managing legal and commercial risk.
7. Required information.
Certain personal information is required in order for Teneo to consider an application, enrol and support a Learner, process payment, meet safeguarding obligations or provide the services it offers. Failure to provide or keep such information accurate may result in an application being refused, services or accommodations being limited, access being suspended or enrolment being terminated.
8. Lesson recordings and classroom participation.
Parents and Learners are informed and acknowledge that:
8.1. Teneo intends to record live lessons so that recordings can be used for educational delivery, revision, catch-up learning, quality assurance, safeguarding, academic development and staff training and marketing and promotional purposes, although Teneo does not guarantee that a recording of every lesson will be available;
8.2. recordings may include an Educator's presentation, Learner video or audio, names, profile images, submitted material, screen content and classroom chat, and Learners may therefore be identifiable;
8.3. Learners may be required to keep their cameras switched on and remain visible to the Educator in order to facilitate teaching, engagement, safeguarding and assessment integrity. A Parent or Learner who seeks an exception must submit the applicable request and supporting information for Teneo to consider case by case;
8.4. recordings may be stored or accessed in South Africa or another country and may therefore involve international transfers of personal information;
8.5. recordings may be made available through authenticated Teneo platforms to authorised current and future Learners, Educators, staff members and service providers for the purposes described above, including so that a Learner joining after the start of a school year can access earlier lessons; and
8.6. the recording and use of lessons for core educational, safeguarding, quality and training purposes is integral to the services offered by Teneo. Teneo may rely on contract, legitimate interests and other lawful grounds for those core uses. Withdrawal of marketing consent does not affect the core uses, and withdrawal of any consent has prospective effect only and does not affect processing already lawfully carried out or processing supported by another lawful ground.
9. Monitoring and automated tools.
Teneo may monitor use of its learning management system, communication channels and related platforms to the extent reasonably necessary to maintain platform security, enforce its rights and Teneo's policies, support safeguarding and online safety, investigate academic irregularities, prevent fraud and comply with applicable law. Teneo may use analytics, artificial intelligence, chatbots and other automated tools to assist with teaching, support, administration, communications, risk detection and decision-making. Teneo will not make a decision based solely on automated processing that produces legal or similarly significant effects unless permitted by applicable law and provided that appropriate safeguards, including any required opportunity for human intervention, have been provided.
10. Sharing.
Teneo may share personal information, to the extent reasonably necessary and lawful, with third parties, including:
10.1. educators, employees, contractors and group or affiliated companies;
10.2. providers of learning management, video-conferencing, cloud hosting, customer relationship management, communication, analytics, security, proctoring, payment, accounting and professional services;
10.3. an Examination Body or examination centre where the Parent or Learner requests or authorises the sharing, or where sharing is otherwise required or permitted by law, without this making Teneo responsible for examination registration or administration;
10.4. schools, universities or other educational institutions at the request of the Parent or Learner or where otherwise lawfully required;
10.5. regulators, courts, law-enforcement bodies, safeguarding authorities and other public authorities where required or permitted by law;
10.6. professional advisers, insurers, auditors, debt collectors, marketing or promotional service providers or persons involved in a corporate transaction; and
10.7. any other recipient notified to the relevant person or authorised by them.
11. Teneo does not sell personal information.
Service providers processing information on Teneo's behalf are required, where applicable, to act on documented instructions, protect the information and use it only for authorised purposes.
12. Retention.
Teneo will retain personal information only for as long as reasonably necessary for the purpose for which it was collected or another lawful purpose. In setting retention periods, Teneo may consider the duration of the enquiry or enrolment relationship, the nature and sensitivity of the information, educational and safeguarding recordkeeping needs, examination body requirements, tax and accounting duties, security and fraud-prevention needs, limitation periods, potential disputes and legal or regulatory requirements. Enquiry and marketing information may be retained while a relationship remains active and for a reasonable period thereafter; Learner, academic, safeguarding and disciplinary records may be retained after enrolment where needed for educational records, certification, references, safeguarding, complaints or legal claims; recordings may be retained while they remain useful for authorised educational, quality, safeguarding or training purposes and will be subject to periodic review; and financial records will be retained for applicable accounting and tax periods. Teneo may retain suppression records to honour marketing opt-outs and may retain anonymised information indefinitely.
13. Security and incidents.
Teneo will use appropriate and reasonable technical and organisational measures designed to protect personal information against accidental or unlawful loss, destruction, alteration, unauthorised disclosure or access. No system is completely secure. Where a personal information breach occurs, Teneo will investigate and notify affected persons and regulators where required by applicable law.
14. Rights.
Subject to applicable law and any lawful limitation, a person may have the right to request access to, correction of or deletion of personal information; restrict or object to processing; receive portable information; withdraw consent; object to direct marketing; and request human intervention in relation to a qualifying automated decision. Requests may be submitted to help@teneoeducation.com. Teneo may verify identity and authority before acting and, in the case of a minor Learner, may require the request to be made or authorised by a Parent. A person may also complain to the Information Regulator of South Africa or another competent regulator.
15. Accuracy and disclosure.
Parents and major Learners must ensure that personal information provided to Teneo is accurate and up to date and must promptly disclose information reasonably required regarding educational history, learning-support needs, medical conditions, mental health, behavioural concerns, safeguarding concerns, guardianship arrangements and any court order relevant to the Learner's schooling. Teneo may not be able to provide appropriate support or comply with its obligations where material information is withheld or inaccurate.
16. Cookies and similar technologies.
Teneo may use cookies and similar technologies on its websites and portals for essential operation, security, preferences, analytics and marketing. Where applicable law requires consent for a non-essential technology, Teneo will seek that consent through the relevant cookie or preference tool. Users may adjust available settings, although disabling essential technologies may prevent parts of a service from functioning.
17. Consent.
All Parents (and prospective Parents) and PRFPs, on their own behalf and on behalf of their Learner (and/or prospective Learner) children, and all major Learners and prospective Learners, through their pre-enrolment interaction and/or upon application for enrolment give express permission for Teneo to receive and process all personal information obtained by Teneo on the basis set out in this Policy, including, where relevant, the processing of all personal information obtained by Teneo through recordings as contemplated above.
18. Updates to this Policy.
Teneo may update this Policy as its services, technology or legal obligations evolve. Material changes will, where reasonably practicable, be notified. Continued use after the effective date of an update constitutes acknowledgement of the updated notice, but does not create consent where applicable law requires a separate affirmative action.
