Privacy and your learning data
Version 1.0 · Trade Shield Academy · learning.tradeshield.ai
Trade Shield (Pty) Limited (“Trade Shield”) strives to ensure that your privacy is protected. This policy regulates the manner in which we collect, use, process, disclose, transfer and retain personal information on the Trade Shield Academy learning platform.
It applies to everyone who learns with us: Trade Shield employees and interns, and clients and external learners who take our courses. It sits alongside the main Trade Shield Privacy Policy, which governs our credit and business-information services. Where the two differ on training data, this policy applies.
In short
- We record who you are, where you work, and what training you have completed - because a training record is only useful if it can be tied to a person and a date.
- Only your name and email address are required. Everything else is optional.
- Population group, gender and disability are optional, default to “prefer not to say”, and are reported only as group totals for Employment Equity and B-BBEE purposes.
- Your learning data plays no part in credit decisions, is never shared with a credit bureau, and is never used for marketing.
- Training records are kept for five years so we can evidence them; certificates are kept indefinitely so they can always be verified.
- You can ask what we hold, have it corrected, or withdraw the optional fields at any time.
1. Laws we comply with
The Academy exists to train people and to evidence that training for skills-development purposes. Our processing is governed by:
- the Protection of Personal Information Act, 2013 (No. 4 of 2013) (“PoPIA”);
- the Skills Development Act, 1998 (No. 97 of 1998) and the Skills Development Levies Act, 1999 (No. 9 of 1999). Trade Shield is not yet registered with a SETA. We keep training records in the form those returns require, so that a Workplace Skills Plan and Annual Training Report can be submitted once registration is in place;
- the Employment Equity Act, 1998 (No. 55 of 1998), where training forms part of our employment equity reporting;
- the Broad-Based Black Economic Empowerment Act, 2003 (No. 53 of 2003) and the Amended Codes of Good Practice, under the skills-development element;
- the National Qualifications Framework Act, 2008 (No. 67 of 2008), where training is delivered against a registered qualification or part-qualification;
- the principles in Sections 50 and 51 of the Electronic Communications and Transactions Act, 2002 (No. 25 of 2002).
2. What we collect
| Information | Why we collect it |
|---|---|
| Name and email address | To create and administer your account, name your certificates, and contact you about training. |
| ID or passport number | To confirm that a training record and certificate belong to you. Identity numbers are required in skills-development reporting and in learner records for accredited training. |
| Employee number and job title | To link your training to your employment record and report it against the correct occupational category. |
| Employment status and organisation | To distinguish employee training from client and external learner training in our reporting. |
| Highest qualification (NQF level) | To pitch training at an appropriate level and plan future programmes. Optional. |
| Population group, gender and disability status | Optional. Used for Employment Equity and B-BBEE skills-development reporting, and reported as group totals. See section 4. |
| Your learning activity | Courses and lessons accessed and completed, assessment scores and attempts, certificates issued, and the dates of each. This is the record that evidences your training. |
| Technical information | Standard platform logs - sign-in times, IP address and pages accessed - used to keep the platform secure and to confirm that learning activity is genuine. |
Only name and email address are required to hold an account. Every other field is optional, and leaving one blank does not affect your access to training, your results, or your certificates.
3. Why we process it, and on what basis
| Purpose | Lawful basis under PoPIA |
|---|---|
| Delivering training, tracking progress, issuing certificates | Necessary to perform under our agreement with you or your employer (section 11(1)(b)). |
| Skills-development records and returns, including a Workplace Skills Plan and Annual Training Report once we are registered with a SETA | Compliance with an obligation imposed by law (section 11(1)(c)), and our legitimate interests in being able to report accurately when that obligation begins. |
| Employment Equity reporting | Compliance with an obligation imposed by law (section 11(1)(c)). For race and ethnic origin, see section 4. |
| B-BBEE skills-development reporting and verification | Our legitimate interests in claiming recognition for training spend (section 11(1)(f)), and your consent for the optional fields. |
| Quality assurance, moderation and accreditation | The requirements of the relevant quality council or accreditation body, and our legitimate interests. |
| Improving our courses | Our legitimate interests, using aggregated results rather than individual performance. |
| Platform security and integrity | Our legitimate interests in protecting the platform and your account. |
What we do not do
Your learning data plays no part in any credit decision, is never shared with a credit bureau, and is never used for direct marketing. Assessment results are not used on their own to make decisions about your employment. We do not sell, rent or lease your personal information.
4. Population group, gender and disability
Information about race or ethnic origin, and about health or disability, is special personal information under section 26 of PoPIA, and its processing is restricted. We handle it as follows.
- It is optional. Every one of these fields offers “prefer not to say”, which is the default answer. Declining changes nothing about your training, your results or your certificates, and we do not ask you to explain.
- We rely on two grounds. Your consent, given when you choose an answer (section 27(1)(a)); and section 31 of PoPIA, which authorises the processing of information concerning race or ethnic origin in order to identify data subjects for the purpose of complying with laws and measures designed to protect or advance persons disadvantaged by unfair discrimination - which is what Employment Equity and B-BBEE skills-development reporting are.
- It is reported as totals. These figures leave Trade Shield as counts by category, never as a named list of individuals.
- It is hidden on the platform. Other learners cannot see these fields on your profile. Access is limited to platform administrators and the staff named in section 5.
- You may withdraw it at any time, by changing the field to “prefer not to say” or by contacting us. Withdrawal does not affect reports already submitted.
- Disability information is used for Employment Equity reporting and to make training materials accessible where you need us to. It is not a health record and we do not ask for a diagnosis.
The main Trade Shield Privacy Policy states that, unless permitted by law or with consent, Trade Shield does not use personal information concerning race or ethnic origin. The Academy's processing falls within both of those exceptions, and is limited to the purposes set out above.
5. Who your information is shared with
| Recipient | What they receive |
|---|---|
| Learning & Development | Course progress, completions and assessment results, to run the Academy and produce reports. |
| Human Resources | Completion and assessment records for employees and interns, for skills reporting and development planning. |
| Your line manager | Whether you have completed training assigned to your team. |
| A SETA, once Trade Shield is registered | Training records submitted in the Workplace Skills Plan and Annual Training Report, including identity numbers and demographic totals as those returns require. |
| B-BBEE verification agency | Training records and supporting evidence, during a verification. |
| Quality council or accreditation body, and auditors | Learner records, assessment evidence and certification records, where they are entitled to inspect them. |
| Our platform provider | Hosts the platform and processes data on our behalf as an operator under a written contract, and may not use it for any other purpose. |
We disclose information without your consent only where the law requires or permits it - for example in response to a lawful request from a regulator, to comply with legal process, or to protect our rights or the safety of people.
6. Where your information is kept
Trade Shield uses cloud storage located in South Africa and Northern Europe. Where personal information is transferred outside South Africa, we transfer it only to jurisdictions with data-protection laws of an equal or stronger standard, or under a written contract that gives your information equivalent protection, as required by section 72 of PoPIA.
7. How long we keep it
- Training and assessment records - five years from the date of the training, so that it can be evidenced for skills-development, B-BBEE and accreditation purposes.
- Certificates and the record of their issue - retained indefinitely, so that a certificate can always be verified.
- Platform logs - currently retained indefinitely. These logs are what show that a learner opened a lesson and completed an assessment on a given date, and accreditation and audit evidence depends on them.
- Your account - active while you are an employee, intern or current learner. After that it is deactivated and only the training record is kept, for the periods above.
We keep personal information no longer than is necessary for the purpose it was collected for, unless a law requires or authorises us to keep it longer.
8. Security
We maintain appropriate technical and organisational safeguards for the platform: access is granted on a need-to-know basis, administrative access is limited to named staff, and information is encrypted in transit using industry-standard secure transport. Before we grant access to a record or change one, we take reasonable steps to verify identity. If a security compromise affects your personal information, we will notify you and the Information Regulator as section 22 of PoPIA requires.
9. Your rights
- Ask what personal information we hold about you, and receive a copy of it.
- Have information that is inaccurate, misleading or out of date corrected, or have information we are no longer entitled to keep deleted.
- Object to the processing of your personal information, on reasonable grounds.
- Withdraw consent for the optional fields, including population group, gender and disability.
- Complain to the Information Regulator, and to be told the outcome of a request we refuse.
Exercising any of these rights is free, and never affects your access to training.
10. How to contact us
Your training record - corrections, missing completions, certificates:
Amy Price, Learning & Development - support@tradeshield.ai, ext. 211.
Formal requests about your personal information:
Marius Vorster, Information Officer - mariusv@tradeshield.ai
Trade Shield Contact Centre: +27 10 753 1630
If you are not satisfied with our response, you may complain to the Information Regulator of South Africa:
inforeg@justice.gov.za
SALU Building, 316 Thabo Sehume Street, Pretoria
Telephone 012 406 4818 · Fax 086 500 3351
11. Changes to this policy
Our compliance with this policy is monitored quarterly. Trade Shield may modify this policy, and the version published on the Academy platform at any time is the version then in effect. Where a change materially affects how we use your information, we will tell learners rather than rely on the published version alone.