IELTS Privacy Notice

This policy is applicable to IELTS-related testing services provided by BC Education Consulting (Beijing) Co., Ltd. of the British Council (hereinafter referred to as "we") in mainland China, including IELTS (both IELTS on Paper and IELTS on Computer), IELTS for UKVI (both IELTS on Paper and IELTS on Computer), IELTS Life Skills and One Skill Retake that's associated with an IELTS full test session. We are fully aware of the importance of personal information to you (hereinafter referred to as "you" or "the candidate"). We will abide by the principles described in the IELTS registration website "User Privacy Policy", and promise to collect, share and protect candidates' personal information during the test delivery and subsequent service stages (including registration, delivery and post-service of IELTS One Skill Retake) following the below standards.

I. How we collect and use your personal information
To ensure smooth delivery of IELTS related services, in addition to collecting your personal information through the IELTS registration website for registration purpose, we shall use WeChat applet to seek your authorization for us to collect and process your personal information as described in this privacy notice. Which includes:  

1.     Use of WeChat mini program to book your speaking test for IELTS on Computer

Candidates registered for IELTS on computer can choose to authorize the "IELTS Official Service Platform" WeChat mini program to collect your personal information in order to book your speaking test for a timeslot of your own choice. Candidates will not be able to access this service without granting his/her authorization, and scheduling will be done randomly by the system for such candidates. In addition to the above authorizations, candidates could choose to follow the IELTS official WeChat account to receive IELTS related information. Whether or not to provide this authorization will not affect your access to the speaking test booking service.

2.     Use of WeChat mini program as a medium for IELTS One Skill Retake registration

After completing the full test, you can choose to register and retake a specific skill within 60 days of the test date. The registration for the IELTS One Skill Retake is done through the "IELTS Official Service Platform" WeChat mini program. The personal information provided by you during the registration for the corresponding full test, as well as your relevant details of the full test, will be used by us for identity verification during the registration for the IELTS One Skill Retake and subsequent services. Except for necessary updates to the emergency contact phone number requested by the candidate or their guardian and proof of personal special circumstances submitted to support special test arrangements application, we will not collect additional personal information for registration purposes.

3.     Collecting and processing your personal information on test day

On the full test day, we will collect and process your photo for the Test Report Form printing, and conduct finger scan to verify candidate identity during speaking and written test modules.

On One Skill Retake test day, for UKVI candidates we will collect and process your photo again and will conduct finger scan for identity verification purpose. For regular IELTS candidates we will also collect and process your photo again, based on the two pictures collected for you on full test day and One Skill Retake test day respectively, through face comparison technology to verify identity consistency. The third-party supplier of our face comparison technology is Ali Cloud Computing Co., LTD. Please note that we only receive terminal verification results from Ali Cloud, and we do not collect or store your face information. The Ali Cloud platform does not store the original face pictures or file information involved in the user's use of the service.

We will videotape the entire test process for quality management and suspected malpractice investigation.

The collection of the above sensitive personal information is necessary for the purpose of ensuring the fairness of the examination and maintaining the reliability of the candidates' scores, and we will obtain your separate consent before collection. We shall not be able to provide the requested exam service if you refuse to provide the required information.

4.     Cancellation of test or application for special arrangements

Candidates who apply for cancellation under special circumstances after the close of registration and candidates with special needs applying for special arrangements must provide relevant personal information listed in the table below as proof for approval. We shall not be able to provide the requested service if you refuse to provide the required information.

The list below details the scenarios and personal information we collect in the course of IELTS delivery and in subsequent service stages (including registration, delivery and post-service of IELTS One Skill Retake):

You understand and accept that we will notify and seek your prior authorization if information collection needs to go beyond the purposes and scope stated above.

In the following cases, your consent is not required for the processing of your personal information (collection, storage, use, processing, transfer, sharing, disclosure): 

• In connection with the fulfilment of obligations of a contract to which an individual is a party, or necessary for the implementation of human resources management in accordance with legally formulated labour rules and regulations and legally signed collective contract.
• Directly related to performance of legal duties or legal obligations.
• In connection with response to public health emergency, or in emergency situations to protect the life, health and property safety of natural persons.
• In connection with news reports, public opinion monitoring and other acts for the public interest, and processing of personal information within a reasonable scope.
• Directly related to reasonable processing of personal information disclosed by individuals themselves or other legally disclosed personal information in accordance with the provisions of the "Personal Information Protection Law".
• Other situations stipulated by laws and administrative regulations.
   

According to relevant laws, we may take technical measures or other necessary measures to anonymize personal information so that the data recipient cannot re-identify a specific individual and data could not be recovered. Your prior authorization will not be required for the sharing, transfer and public disclosure of such processed data.

You are aware that we will collect and process your registration information provided to us by the National Education Examinations Authority in accordance with this Privacy Policy (please refer to the "User Privacy Policy" for specific types of information).

 
II. How we entrust processing, share, transfer and disclose your personal information
1. Entrusted processing

Part of IELTS test administration process may be assisted by external service providers. For example, entrusts authorized test centre and venue staff to process personal information for delivery of test, entrusts couriers like "SF Express (Beijing) Co.,LTD" and "Sinotrans DHL International Air Express Co., Ltd. Beijing Branch" for delivery of original Test Report Form and extra Test Report Form, entrusts human resources companies with part of the data processing. We confirm strict confidentiality undertaking agreements and data processing agreements have been entered with companies and organizations entrusted to process personal information, making sure your personal information is handled in accordance with the requirements of IELTS test, IELTS Privacy Policy and relevant information protection policy and data security procedures. Relevant processing of personal information shall be conducted under our supervision.

2. Sharing

As part of IELTS operations need, we may share your personal information with partner companies and organizations for the delivery of the IELTS test. We shall sign strict confidentiality undertaking agreements and data processing agreements with receiving companies and organizations, making sure your personal information is processed in accordance with this Privacy Policy. Receiving companies and organizations shall in no circumstances use such information for any other purpose. Your authorization will be required should there be a need for your personal information to be used for other purposes. Sharing of your personal information includes:

We may share your personal information in accordance with laws and regulations or mandatory requirements of government authorities or upon your consent. For example, sharing with recognizing organizations like educational institutions, government authorities, visa and immigration control agencies, professional bodies and commercial institutions, or legal institutions and regulatory authorities to verify the identity of candidates and prevent any forms of cheating and violations from infringement of the rights and interests of IELTS and its stakeholders.

Please use caution when sharing your Test Report Form number as it can be used for the IELTS results service, which provides access to your personal information collected and generated during the IELTS registration and testing process.

IELTS scores and answers may be used anonymously for information collection, IELTS scores and test items validity argumentation, data statistics and examiner training. Such information could not be associated with or used to identify an individual.

1. Transfer

We will not transfer your personal information to any other company, organization or individual, except:

• Your consent or authorization is obtained in advance
• We and our affiliates may conduct mergers, acquisitions, asset transfers or other similar transactions. If the relevant transaction involves the transfer of your personal information, we will make sure the receiving company, organization and individual continues to be bound by this policy, otherwise we will require the company, organization and individual to obtain your authorization and consent again.

2. Public disclosure

We will publicly disclose your personal information only if

• Your consent or authorization is obtained in advance.
• Under the requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements.

III. How we store your personal information
We will only store your personal information for a necessary period for the purposes stated in this policy and within the retention period specified by laws and regulations. At the end of retention period, your personal information will be deleted or anonymized as required by relevant laws. Before the end of retention period stipulated by laws or administrative regulations, or it is technically difficult to delete personal information, we will stop all data processing except storing and necessary security measures. The details of retention period are provided as follows:

IV. How we protect personal information of minors
Although local laws and customs may have different definition of minors, we deem all candidates under the age of 18 as minors. Minors should not create their NEEA account for IELTS without the consent of their parents or guardians.

Minors under 18 years old are expected to be fully aware of the content of this policy with the company and assistance of their parents or guardians (children under 14 years old please refer to "British Council Policy for the Protection of the Personal Information of Child Users"), and only use IELTS related services or provide personal information with the consent from their parents or guardians. 

We will handle the personal information of minors in strict accordance with the requirements of laws and regulations such as "Provisions on the Cyber Protection of Children's Personal Information", adhering to the principles of legitimacy and necessity, informed consent, clear purpose, security and legal utilization.

V. Your personal information rights
We appreciate your concerns about personal information, and we will protect your personal information rights in accordance with relevant laws and regulations, including but not limited to:

1. Amendment to your personal information

You may request amendment to your personal information if you have submitted inaccurate information (excluding registration information for IELTS One Skill Retake, which must be consistent with the corresponding IELTS full test).

• To amend your core personal information such as Chinese and English name, gender, ID document type, ID document number and date of birth, please contact NEEA IELTS National Call Centre (email: ielts@mail.neea.edu.cn, Tel: 010-82345671) with “IELTS Candidate Personal Information Amendment Form” and supporting documents.
• Before close of registration, you can log in to NEEA IELTS registration website at any time to change your personal information other than the above-mentioned core personal information. After close of registration, if you need to change your non-core personal information, please contact NEEA IELTS National Call Centre (email: ielts@mail.neea.edu.cn, Tel: 010-82345671) with supporting documents.

2. Deletion of personal information

In case of the following, we will take the initiative to delete your personal information; If it is not done, you can make a request to us to delete your personal information. 

• If our processing of personal information violates laws and regulations
• Where prior authorization is required, we collect and use your personal information without your authorization, or you have withdrawn your authorization
• If our processing of personal information violates our agreement with you
• If the purpose for which we collect and use your personal information has been achieved, cannot be achieved or is no longer necessary
• If you no longer use IELTS related services
• If we no longer provide you with products or services

3. Change the scope of your authorization

Where we process your personal information based on your authorization, you have the right to withdraw your authorization. Upon withdrawal of your authorization, we will no longer process the relevant personal information, and the corresponding service will not be delivered. Please note that withdrawal of your authorization will not affect the effectiveness of personal information processing activities based on your prior authorization.

4. Obtain a copy of your personal information

You have the right to obtain a copy of the personal information you submitted in the process of using IELTS related services. Please make a request to our dedicated email address for personal information protection (CNDisclosures@britishcouncil.org). A fee may occur for this service.

For you or your potential guardians, close relatives and other authorized subjects to make the above request to us or to execute your personal information rights under the laws of the People's Republic of China, you can contact us through our designated email address for personal information protection as listed in Chapter VII.

Please be advised that we will not be able to respond to your request in the following cases:

• Related to performance of our obligations under laws and regulations
• Directly related to state security, national defense security
• Directly related to public safety, public health and major public interests
• Directly related to criminal investigation, prosecution, trial and execution of judgment
• We have sufficient evidence of the subject of personal information having subjective malice or abuse of rights
• For the purpose of safeguarding the life, property and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain prior authorization
• Response to the individual’s request of their personal information will cause serious damage to the legitimate rights and interests of the said individual or other individuals and organizations
• Related to trade secrets

VI. Cross-border transfer of personal information
Apart from being stored within the People's Republic of China, your personal information will also be shared with Cambridge University Press and Assessment ( www.cambridge.org) based in the UK and British Council Headquarters (www.britishcouncil.org) for test administration and management, test delivery, IELTS scores and test items validity argumentation, and test day malpractice investigation report.

Where cross-border transfer is required, we are committed to complying with relevant laws to ensure that your personal information is protected during all transactions. Details of cross-boarder transfer are provided in "2. Sharing of Chapter II. How we entrust processing, share, transfer and disclose your personal information".

We will carry out security assessment and sign data processing agreements in accordance with relevant laws to protect the security of your personal information during the course of cross-border transfer. 

If you do not authorize cross-border transfer of your registration information to overseas companies or organizations, you will not be able to register for IELTS test. 

VII. How to contact us
You can contact us in the following way if you have any questions, comments or suggestions about the content of this Privacy Policy: 

Our registered address: 3/F Building No. 4, 8 Dongsanhuan Beilu, Beijing

Our designated personal information protection email: CNDisclosures@britishcouncil.org

We will respond to your request as soon as possible, in principle within 15 working days. The service is in principle free of charge, but we reserve the right to charge a reasonable fee for repeated requests or those beyond our ordinary service scope. We shall not accept requests that are unreasonably repetitive, require excessive technical solutions (for example, involving development of a new system or dramatic changes to the current norms), or infringe other’s legal rights or unrealistic (for example, involving information saved as an additional backup).