PORTMAN College (“we”, “us”, “our”) is committed to protecting the privacy and personal data of all students, prospective students, parents, partners, affiliates, employees, and visitors within Malaysia, in accordance with the Personal Data Protection Act 2010 (PDPA Malaysia).
This Data Protection & Privacy Policy explains how we collect, use, store, and protect personal data when you access or use our platforms and services, including our website, Learning Management System (LMS), AI-assisted learning tools, chat systems, call bots, CRM systems, email platforms, and related online services.
By accessing or using our platforms and services, you agree to the terms of this policy.
1. Data Controller
PORTMAN College
Email: info@portman.edu.my
PORTMAN College acts as the Data Controller for all personal data processed under this policy in accordance with the PDPA Malaysia.
2. Personal Data We Collect
Depending on your interaction with PORTMAN College, we may collect the following types of personal data:
2.1 Identity & Contact Data
- Full name
- Email address
- Phone number
- Nationality & identification documents
- Mailing address
2.2 Academic Data
- Application and enrollment information
- Academic records and transcripts
- Assignments, submissions, and assessments
- AI-assisted grading feedback
- Attendance records and LMS activity logs
2.3 Financial & Billing Data
- Payment information (processed via secure third-party payment providers)
- Invoices, receipts, and scholarship or financial aid records
2.4 Technical & System Data
- IP address
- Device and browser information
- LMS login records
- Chat and call bot interaction logs
- Usage analytics
2.5 Marketing & Communication Data
- Enquiry and form submissions
- Lead generation data
- Email and WhatsApp communications
- Referral or affiliate tracking data (where applicable)
3. Legal Basis for Processing (PDPA Malaysia)
We process personal data in accordance with the Personal Data Protection Act 2010 (PDPA Malaysia) based on:
- Consent provided by the data subject
- Performance of contractual obligations
- Compliance with legal or regulatory requirements
- Legitimate educational and administrative purposes
- Purpose limitation and data minimisation principles
4. How We Use Your Data
We use personal data for the following purposes:
- Managing applications, admissions, and student enrollment
- Delivering academic programmes and online learning services
- Operating and improving our Learning Management System (LMS)
- Providing AI-assisted academic feedback and learning support
- Issuing certificates, transcripts, and official academic documents
- Providing student support, academic advising, and communications
- Improving our services, systems, and learning technologies
- Conducting marketing and outreach activities (with consent)
- Meeting regulatory, accreditation, and institutional requirements
All AI-assisted processes are subject to human oversight by academic or authorised staff.
6. International Data Transfers
Personal data is primarily stored and processed within Malaysia or on secure cloud infrastructure.
Where data is processed or stored outside Malaysia, PORTMAN College ensures:
- Adequate security safeguards
- Data processing agreements
- Compliance with PDPA requirements
- Secure transmission and encryption protocols
7. Data Retention
We retain personal data only for as long as necessary:
- Student academic records: 7–10 years
- Financial and billing records: as required by Malaysian tax and audit laws
- Marketing and communication data: 12–24 months
- Academic submissions: in accordance with institutional academic policies
Data that is no longer required is securely deleted or anonymised.
8. Your Rights Under PDPA Malaysia
You have the right to:
- Access your personal data
- Request correction of inaccurate or incomplete data
- Withdraw consent (subject to legal and contractual limitations)
- Request deletion of personal data where applicable
- Be informed of how your data is processed
You may also lodge a complaint with the relevant Malaysian authority if you believe your data has been mishandled.
9. AI, Automation & Profiling
PORTMAN College uses AI technologies for:
- Academic assessment support
- Learning analytics and recommendations
- Identity verification (where applicable)
- Chat and call bot interactions
- Administrative process automation
Students may request human review of any AI-assisted or automated decision affecting them.
10. Data Security
We protect personal data through:
- SSL/TLS encryption
- Role-based access controls
- Secure cloud hosting and encrypted backups
- Two-factor authentication (2FA) for staff systems
- Regular system monitoring and security reviews
12. Contact: Data Protection Officer (DPO)
For any data protection or privacy-related enquiries, please contact:
13. Policy Updates
This policy may be updated from time to time due to:
- Changes in Malaysian laws or regulations
- Updates to our systems or AI tools
- Accreditation or institutional requirements
- Improvements to internal processes
The latest version will always be published on our official website.