Privacy Notice

LearnerLens (Pty) Ltd is committed to protecting personal information and respecting the privacy of schools, learners, parents, educators and authorised users. This Privacy Notice explains how LearnerLens collects, uses, stores and protects personal information when providing its services, in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA). It is intended for publication on the LearnerLens website and should be read together with the LearnerLens School Services Agreement (SSA) and Data Processing Agreement (DPA).

• Responsible Party: The school determines why and how personal information is processed.
• Operator: LearnerLens processes personal information on behalf of the school.
• Personal Information: Information relating to an identifiable natural person as defined by POPIA.
• De-identified Information: Information from which direct identifiers have been removed so that an individual cannot reasonably be identified.
• Aggregated Information: Combined statistical information that cannot reasonably identify an individual learner.

In respect of learner, school and authorised user information processed to deliver the contracted services, LearnerLens acts as the Operator on the documented instructions of the school, which remains the Responsible Party. In respect of information collected directly through this website, such as enquiry forms, newsletter sign-ups and website analytics, LearnerLens (Pty) Ltd is the Responsible Party and determines the purpose and means of that processing.

• School contact and organisational information.
• Authorised user account information.
• Learner identifiers required to deliver authorised learner reports.
• Survey responses and wellbeing indicators.
• Technical information required to operate and secure the platform.

LearnerLens processes information only for legitimate educational purposes agreed with the school.

• Configure and operate the platform.
• Generate learner, class, grade and school reports.
• Support implementation, training and technical assistance.
• Maintain platform security and reliability.
• Meet applicable legal and contractual obligations.

In most implementations the school is the Responsible Party and determines the lawful basis for processing under POPIA. Depending on the circumstances, processing may be based on consent, contractual necessity, legal obligations, or another lawful basis recognised by POPIA. LearnerLens processes information only on the documented instructions of the school unless otherwise required by law.

Where you provide information directly to LearnerLens through this website, doing so is voluntary, but LearnerLens may not be able to respond to your enquiry or provide certain services without it. Information may be shared with authorised sub-operators who support LearnerLens in delivering the platform, on terms consistent with this Notice and the DPA.

LearnerLens' approach is to minimise the retention and use of identifiable information. Identifiable learner information is processed only where necessary to provide the contracted services, such as generating authorised learner reports or supporting implementation.

For benchmarking, quality assurance, product improvement, statistical reporting and research, LearnerLens uses aggregated and de-identified information. These datasets exclude names, learner numbers, identity numbers, contact details and other direct identifiers and are structured so that individual learners cannot reasonably be identified.

• Role-based access controls.
• Authentication for authorised users.
• Encryption during transmission and appropriate protection of stored information.
• Confidentiality obligations for authorised personnel.
• Reasonable backup and business continuity arrangements.

LearnerLens hosts production data within South Africa. Where any information is transferred to or accessed from outside South Africa, LearnerLens will ensure the transfer complies with section 72 of POPIA, including through the use of an equivalent level of protection, binding corporate rules, or another appropriate safeguard recognised by POPIA.

Where the platform processes a child's personal information, this occurs under the school's arrangements with LearnerLens, and any consent required from a parent or legal guardian is obtained by the school in accordance with POPIA. LearnerLens does not knowingly collect personal information directly from children through this website.

• Request access to personal information through the Responsible Party (the school).
• Request correction of inaccurate information.
• Object to processing where permitted by POPIA.
• Request deletion where appropriate and lawful.
• Object to receiving direct marketing communications from LearnerLens at any time.
• Lodge a complaint with the Information Regulator of South Africa if concerns cannot be resolved, including via POPIAComplaints@inforegulator.org.za or www.inforegulator.org.za.

LearnerLens does not use automated decision-making in respect of website visitors that produces legal or similarly significant effects. Where the platform generates wellbeing profiles or reports for learners, these are reviewed and applied by the school's educators and support staff, and are not used as the sole basis for decisions affecting a learner.

The LearnerLens website uses cookies and similar technologies. Strictly necessary cookies, required for the website to function, do not require consent. Analytics and other non-essential cookies are only set with your consent, given through the website's cookie banner. These technologies are not used to identify learners. You may withdraw consent or manage cookie preferences at any time through the cookie banner or your browser settings, although some website features may not function correctly if cookies are disabled.

LearnerLens will not retain identifiable learner information beyond the agreed retention period unless required by law or expressly instructed by the school. Following completion of the agreed retention period, identifiable learner information is securely deleted or returned to the school. LearnerLens may retain only aggregated and de-identified statistical information that cannot reasonably be linked to an identifiable learner, school staff member, or other data subject, used solely for quality assurance, service improvement, benchmarking, research and product development. Information submitted directly to LearnerLens through this website, such as enquiries, is retained only for as long as necessary to respond to and resolve the relevant request.

LearnerLens may update this Notice from time to time to reflect changes in its practices or legal requirements. The Effective Date and Review Date above indicate when this Notice was last issued and when it is next due for review. Material changes will be reflected on this page.

• LearnerLens (Pty) Ltd
• Information Officer: ______________________
• Email: privacy@learnerlens.co.za
• Website: www.learnerlens.co.za

To lodge a complaint with the Information Regulator of South Africa: POPIAComplaints@inforegulator.org.za | www.inforegulator.org.za