Privacy Policy
1. Introduction/Scope
This document is prepared in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Nigerian Data Protection Regulation (NDPR). It sets out how Learn Africa Plc applies and complies with the principles of the regulations in processing the personal data of individuals, clients, vendors, and even third parties that interact with Learn Africa Plc.
For personal data of individuals, this document also highlights their rights and covers the data subject(s) whose personal data is collected and processed in compliance with the GDPR/NDPR.
This privacy policy describes why and how we collect and use personal information about our customers, clients, vendors, and visitors (data subjects) . It also highlights with whom we might share Personal Information and how long we keep such information. It also makes data subjects aware of their rights under the regulation.
2. Roles and Responsibilities
| Roles | Responsibilities |
|---|---|
| Data Protection Officer | To ensure that this notice is correct and up-to-date and bring this notice to the awareness of data subjects before the collection and processing of personal data by Learn Africa Plc, including data collected via Learn Africa Plc’s website. |
| All Employees/Staff who interact with personal data | To follow the provisions of this policy document. |
| To seek the consent of data subject(s) for the secure processing of their personal data. | |
| To ensure that this notice is brought to the attention of the data subject(s). |
3. Policy Statement
At Learn Africa Plc, we are committed to ensuring the protection, confidentiality, and integrity of all personal data we handle. We recognise the importance of data protection and privacy for our customers, employees, and partners. This policy outlines our commitment to comply with relevant data protection laws and regulations, including the Nigeria Data Protection Act (NDPA), and to continuously improve our data protection practices. Learn Africa Plc is required to notify data subjects of the information contained in this document.
3.1 Who We Are
Learn Africa Plc is the leading learning resource business with a history spanning over 60 years. The company was established in 1961 as Longman Nigeria- a book publishing firm wholly owned by Longman Group UK Limited, now Pearson Education.
On July 23, 1996, the shares of Longman Nigeria Plc were listed on the Nigeria Stock Exchange. In 2008 the company became a subsidiary of Pearson plc following the latter’s increase in its shareholding from 29 to 51 percent. In 2011, however, Pearson and Longman agreed to become separate corporate entities in Nigeria.
The main business of Learn Africa is the publication and marketing of textbooks for the entire gamut of the educational system –nursery, primary, secondary, and tertiary. The company has equally distinguished itself in the marketing of reference, professional, and general reading materials. Today, the company has the widest range of books /educational resources and a very expansive distribution network in Nigeria.
3.2 What Personal Data Do We Need?
The personal data we would collect and process, depending on the processing requirement, are under the following categories:
| Personal Data Type | Description of Data | Sources |
|---|---|---|
| Biodata/Identity data | Full name, maiden name, marital status, title, NIN, date of birth, gender, employment history and citizenship, email address. | Curriculum Vitae, Employee records form, service/royalty agreement, e-payment form |
| Contact data | Address, email address, telephone numbers | Curriculum Vitae, Employee records form, service/royalty agreement, e-payment form, business card, e-mails, invoices, face-to-face meetings, phone calls, letters |
| Financial | Bank account information, BVN, debit or credit card information, TIN | Employee records form, service/royalty agreement, e-payment form, invoices, tax cards |
| Educational/Professional | Curriculum Vitae, Employee records forms, and data collection forms. | |
| Technical data | Internet protocol (IP) address, login data, details of browser and operating system, time zone setting and location, browser plug-in types and versions, platforms, and other technology such as device ID, geolocation, IP, model, and user agent on the devices used to access the Learn Africa website or Mobile APP. | Website, mobile app, and emails |
| Marketing and communications data | Information about data subject communications with the company. | Preferences in receiving marketing e-mails and consents given by data subject to Learn Africa Plc |
| Usage Data | Information about how data subject uses our website, products, and services. |
In certain instances, the personal data we need to collect may fall under a special category of sensitive personal data, which includes race, political opinion, ethnic origin, religion, philosophical beliefs, genetic/biometric data, health record, sex life/sex orientation, criminal records, or alleged criminal activity. In such instances, our lawful basis of processing will be the explicit consent of the individual, compliance with a legal obligation, or legal proceedings/advice.
3.3 Why Do We Need the Data?
Learn Africa Plc ensures that the personal data collected and processed is necessary for collection and Learn Africa Plc shall not collect or process more data than is reasonably required for a particular processing activity.
In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below:
| Purpose of Processing | Lawful Basis of Processing |
|---|---|
| Account creation, Identity verification, and maintenance of records | Consent, Contract, Legal obligation |
| Staff onboarding and update, HMO, Certificate verification, insurance | Consent, Contract, Legal obligation |
| Managing author information | Consent, Contract obligation. |
| Royalty payment | Consent, Contract, Legal obligation |
| Compliance with Statutory tax regulations (WHT) | Legal Obligation |
| Payment of salary, Pension, and tax | Consent, Contract, Legal obligation |
| Payment of bills | Consent, Contract |
| Debt Verification | Consent, Contract obligation. |
| Customer order/ invoice processing | Consent, Contract |
| Email usage | Consent |
| Staff emails | Consent, Legal obligation |
| Marketing Promotions | Consent |
| Vendor Validation/information processing | Consent, Contract obligation. |
Where Legitimate Interest is considered the legal basis for processing personal data, Learn Africa Plc shall follow the steps below in carrying out a Legitimate Interest Assessment.
- Determine the Purpose for Processing
In carrying out the purpose test, Learn Africa Plc must establish the exact reason for the processing and how it benefits the organisation. Answers to the following shall be provided to determine the exact purpose for processing:
- Description of the processing objective
- The likelihood of meeting the objective and how to determine if the objective was met.
- The benefit of the processing and the significance to the organisation
- Description of the possible impact of not processing and any other issues that might be relevant.
- Determine the Necessity of the Processing
Learn Africa Plc must establish why the processing must take place, how the processing relates to the expected benefits and any other alternatives, and why they were not considered.
- Balance the identified interest with the Privacy Interest of the Data Subjects
The following questions will be addressed under the balance test:
- Who are the data subjects (category)?
- What is the relationship between Learn Africa Plc and the data subject?
- What personal data is to be processed.
- How will the processing impact the data subject.
- How will the data subject react to the processing.
Learn Africa Plc records this information in line with this policy, data protection impact assessment, and data inventory.
4. Consent
Learn Africa Plc requires your explicit consent to process collected personal data. By consenting to this privacy policy, you are permitting us to use/process your personal data specifically for the purpose identified before collection.
If, for any reason, Learn Africa Plc is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used.
- Withdrawal of Consent
You may withdraw consent at any time by requesting for withdrawal of the consent form, following the Learn Africa Plc withdrawal of consent procedure.
For child consent, Learn Africa Plc shall confirm that the holder of parental responsibility over the specified child has withdrawn consent via written instruction from the parent. Learn Africa Plc will also confirm that reasonable efforts have been made to establish the authenticity of the parental responsibility when withdrawing consent for the specified child, considering available technology.
Where applicable, the Data Protection Officer will inform the relevant process owner of this change, and the processing activities that relied upon the consent will be stopped immediately, under the relevant process.”
You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the Learn Africa Plc Withdrawal of Consent Procedure.
- Use of Cookies
The Learn Africa Plc website also uses cookies provided by trusted third parties, such as Google Analytics, to help us understand and improve users’ experience on the website.
Learn Africa Plc may use the information obtained from the use of our cookies to:
- Recognize a computer when a user visits the Learn Africa Plc website.
- Track whoever navigates the website
- Improve the website’s usability (including the Live Chat application to answer questions a user may have in real-time
- Analyse the use of its website – such as how many people visit it each day, and
- Manage the website.
Users can disable cookies and prevent the setting of cookies by adjusting the settings on their browser. However, this is not recommended, as disabling cookies may also disable certain functionality and features of the site.
- Disclosure
Learn Africa Plc will not pass on your personal data to third parties without first obtaining your consent.
The following third parties will receive your personal data for the following purpose(s) as part of the processing activities.
| Third parties | Purpose |
|---|---|
| Anchor HMO | Medical |
| IBN Insurance brokers | Insurance |
| Government Agencies | Statutory Audit |
| Human Manager | Payroll |
| Pension Managers | Pension |
| Bista Publishing | Data processing |
Where there is a need for a third party to process the personal data of data subjects, Learn Africa Plc will enter into a Data Processing Agreement with the third party and be satisfied that the third party has adequate measures in place to protect the data against accidental or unauthorised access, use, disclosure, loss, or destruction.
In a case where the disclosure is to third parties outside the jurisdiction of the GDPR and NDPR, Learn Africa Plc will ensure that the third party meets the core regulatory standards before the transfer. This may include transferring the personal data to a third party where Learn Africa Plc has satisfied that:
- the country of the recipient has adequate data protection controls established by the legal or self-regulatory regime.
- Learn Africa Plc has a contract in place that uses existing or approved data protection clauses to ensure adequate protection.
- Learn Africa Plc is making the transfer under approved binding corporate rules.
- Learn Africa Plc relies on approved codes of conduct or certification mechanisms, together with binding and enforceable commitments in the foreign country or international organisation to apply the appropriate safeguards concerning data subject rights.
- Provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority.
8. Retention of Records
In compliance with the GDPR/NDPR data retention policy, Learn Africa Plc will process your personal data and intend to retain it for as long as necessary, as it is contained in our records of retention policy.
This retention period has been established to enable us to use the personal data for the necessary legitimate purposes identified, in full compliance with the legal and regulatory requirements. When we no longer need to use your personal information, we will delete it from our systems and records, and/or take steps to encrypt/anonymise it to protect your identity.
9. Data Subject Rights
Data subjects, according to the provision of the GDPR/NDPR, have certain rights. At any point while Learn Africa Plc have or processing your personal data, you, the data subject, have the right to:
- Request a copy of the information that we hold about you.
- Correct the data that we hold about you that is inaccurate or incomplete.
- Ask for the data we hold about you to be erased from our systems/records.
- Restrict the processing of your personal data where certain conditions apply.
- Have the data we hold about you transferred to another organisation.
- Object to certain types of processing like direct marketing.
- Object to automated processing like profiling, as well as the right to be subject to the legal effects of automated processing or profiling.
- Judicial review. If Learn Africa Plc refuses your request under the rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All the above requests will be forwarded should there be a third party involved in the processing of your personal data.
- Complaints
If for any reason you wish to make a complaint about how Learn Africa Plc (or any of our third parties described in 3.4 above) processes your personal data, or how your complaint has been handled, you have the right to complain directly with the supervisory authority and the Data Protection Officer of Learn Africa Plc.
Below are the details for each of these contacts:
| Supervisory Authority | Data Protection Officer (DPO) | |
|---|---|---|
| Contact Name: | Adedapo Adeneye | |
| Email: | info@ndpc.gov.ng | dpo@learnafricaplc.com |
- Privacy statement
For more information on how we use your personal data and why, please see our privacy statement on the website.
- Online Privacy Statement
Personal Data
Under the EU’s General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation (NDPR), personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
How We Use Your Information
This privacy notice tells you how we, Learn Africa Plc, will collect and use your personal data for relationship management, profiling, business analytics/development, communication, registration, subscription, cookies, and all-round efficient service delivery.
Why Does Learn Africa Plc Need to Collect and Store Personal Data?
We need to collect your personal data for us to provide you with our services as mentioned in clause 3.3 above and to contact you at any time through your provided telephone number, email address, or other contact details. In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose(s) only and will in no way invade your privacy. If there is a need to use your data for marketing purposes, Learn Africa Plc will ensure to seek additional consent from you.
Will Learn Africa Plc Share My Personal Data with Anyone Else?
Learn Africa Plc may pass your personal data to third-party service providers contracted by us. Any third parties that we may share your personal data with are under an obligation to secure your details and use them only to fulfill the service for which they were contracted. When they no longer need your details to fulfill this service, the data will be disposed of in line with Learn Africa’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are required to do otherwise, legally.
How Will Learn Africa Plc Use the Personal Data It Collects About Me?
We will process (collect, use, and store) the information you provide in a manner that complies with the EU’s General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation (NDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Learn Africa Plc is required to retain information following the law, such as information needed for income tax and audit purposes. The retention period for certain kinds of personal data may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Learn Africa Plc contact me?
We do not intend to be intrusive, and we will not ask irrelevant or unnecessary questions. Moreover, we will subject the information you provide to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I Find Out the Personal Data That Learn Africa Plc Holds About Me?
Learn Africa Plc, at your request, can confirm what information we hold about you and how it is processed. If we do hold your personal data, you have the right to request the following information:
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- Information about interests, if the processing is based on the legitimate interests of Learn Africa Plc or a third party.
- The categories of personal data collected, stored, and processed.
- Recipient(s) or categories of recipients to whom the data is/will be disclosed.
- Information about how we intend to securely transfer personal data to a third party or international organisation. The Attorney General of the Federation will approve sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored?
- Details of your rights to correct, erase, restrict, or object to such processing.
- Information about your right to withdraw consent at any time.
- How to complain to the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if you didn’t provide it directly.
- Any details and information of automated decision-making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What Forms of ID Will I Need to Provide to Access This?
Learn Africa Plc accepts the following forms of ID when information on your personal data is requested: Passport, driving license, national identity card, permanent voter card.
| Contact details of the Data Protection Officer: | |
|---|---|
| Contact Name: | Adedapo Adeneye |
| Address: | 52 Oba Akran Avenue, Ikeja |
| Email: | dpo@learnafricaplc.com |
| Telephone: | 08028560584 |
Signature: Date:
SIGN OFF:
| ISSUED BY | DATA PROTECTION OFFICER |
|---|---|
| REVIEWED BY | MANAGEMENT TEAM |
| APPROVED BY | THE BOARD, LEARN AFICA PLC |
| REVISION | DATE | DESCRIPTION OF CHANGES | REQUESTED BY |
|---|---|---|---|
| Rev. 1 | February 2024 | In Compliance with Data Protection Regulation Law | Management |
