Privacy Notice
Version 0.2-draft · Effective 2026-11-07
DRAFT: for review by the Data Protection Officer and school administration.
This notice explains how the Test Management System with Decision Support (the "system") handles personal data. It follows the Data Privacy Act of 2012 (Republic Act No. 10173). We wrote it in plain English. If something is unclear, please ask us (see section 11).
1. Who runs the system
- School: University of Perpetual Help System
- Campus: Cauayan Campus
- Contact for privacy questions and requests: [Privacy contact (email / phone / office) - to be set]
- Data Protection Officer (DPO): [Data Protection Officer name - to be set], [Data Protection Officer email - to be set]
The school decides why and how the data in this system is used. In data privacy terms, the school is the personal information controller.
2. Who this notice is about
- Users: Admins, Teachers and Program Heads who log in.
- Students: students whose names are in the class lists and whose answer sheets are checked. Students do not log in and do not have accounts. A teacher or the Admin enters or uploads their details.
- People who write to us through the Contact and Support form.
3. What data we collect
About users (Admin, Teacher, Program Head)
- Full name, username, email address (optional), role and department.
- Your password. It is stored only as a scrambled one-way code (a hash). Nobody, including the Admin, can read your password.
- Your theme choice (light, dark or system), whether you must change your password, and the time of your last login.
- Activity records: when you log in, upload, generate or download a test, approve something, and so on. Each record has the time, your IP address and the type of browser.
- Login attempts: the username typed, the IP address and the time, whether the attempt worked or not. This is used to lock an account after too many wrong passwords.
- Your work: questions you write, tests, tables of specifications, templates and logos you upload.
About students
- Student number, name (last, first, middle), department, section and optional email address.
- Test answers: what the student answered on each item, and the score, percentage, grade and Passed or Failed result.
- Photos of answer sheets taken with a phone or camera. A photo shows the shaded student number, the shaded answers and the student's handwriting.
- Scanner results and flags: how sure the scanner was when reading the sheet, and flags such as "please check this answer" or "these two papers look very similar".
- Statistics made from many students' results, such as how hard a question was. These show no names.
- A private support indicator (Low, Moderate or High) calculated from the student's scores, the trend of the scores, missing papers and failed tests, with suggested actions such as a consultation. It helps the teacher offer support early. It is visible only to the student's teacher and the department's Program Head, never to other students, and it is never used to grade, pass, fail or discipline anyone. The teacher decides what to do with it.
About people who contact us
- Name, email address, the message, and the IP address (used to stop spam).
We do not collect addresses, phone numbers, birth dates, photos of faces, government ID numbers or payment details.
4. Why we use the data
- To let teachers build tests, check answer sheets, record scores and see how a class is doing.
- To help teachers improve questions and tests (item analysis and decision support), and to help them notice early which students may need support.
- To keep the system secure, find problems and show the Admin how the system is used.
- To answer questions and requests sent through the Contact page.
We use the data only for these school purposes. We do not sell it and we do not use it for advertising.
5. Our lawful basis
The law requires a legal reason for using personal data. The school and its DPO must confirm the reasons below before this notice becomes final.
- Users: [TO CONFIRM: e.g. performance of the school's educational function and legitimate interest in running and securing the system]
- Students (names, student numbers, section): [TO CONFIRM: e.g. performance of the school's educational function; legal obligation to keep student records]
- Students (answers, scores, grades, answer sheet photos): [TO CONFIRM: basis to be chosen by the DPO]
- Contact messages: your consent, shown by the box you tick before sending.
A note for the DPO: records about a person's education can count as sensitive personal information under Section 3(l) of the Data Privacy Act, and Section 13 sets stricter conditions for those. Some students are minors. Please decide the basis, and whether parent or guardian consent is needed, before finalizing.
6. Cookies and browser storage
The system uses very little, and only what it needs to work.
| Name | What it holds | Why | How long |
|---|---|---|---|
Cookie TESTSYSTEM_SID | A random session number | Keeps you logged in | Until you close the browser or the session times out after inactivity |
Browser storage ts-theme | Light, dark or system | Opens the page in your chosen theme without a flash of white | Until you clear your browser data |
We do not use advertising cookies, analytics or tracking. All fonts, icons and scripts are served by the system itself, so your browser does not contact outside websites to show these pages.
7. How long we keep data
The table below shows the retention periods. They are placeholders until the school confirms them. Cleanup of old logs, files and images only happens after the Administrator confirms the periods and switches it on.
| Data | What it contains | How long we keep it (PLACEHOLDER) | How it is removed |
|---|---|---|---|
| Login attempts | Username typed, IP address, success/failure, time | 90 days | Rows deleted from the database |
| Activity logs | Who did what and when, IP address, browser type | 24 months | Rows deleted from the database |
| Download logs | Who downloaded which file, IP address, time | 24 months | Rows deleted from the database |
| Contact messages (Resolved or Read only) | Name, email, message, IP address | 12 months | Rows deleted from the database (messages still marked New are kept) |
| Generated files (exports/) | Test papers, answer keys, TOS, class records and reports incl. dashboard PDFs (teacher name; class records and some reports contain student names and scores) | 12 months | File deleted from disk and its record removed; the file is rebuilt if downloaded again |
| Scanned answer sheet images | Photos of student answer sheets (name/ID bubbles, handwriting) | 12 months | Image files deleted from disk; scores and results stay (only Confirmed, Rejected or Rescan sheets) |
| Student records | Name, student number, section, optional email | [TO CONFIRM: period to be set by the school] | Review each school year; deactivate students who left; delete or anonymize on request or after the period the school confirms |
| Exam results and student answers | Answers, scores, grades, flags | [TO CONFIRM: period to be set by the school] | Kept as academic records for the period the school confirms; then anonymized (student link removed) so item analysis stays valid |
| Backups (backups/ folder) | A full copy of the database (all of the above) and, optionally, uploaded files and generated exports | [TO CONFIRM: period to be set by the school] | Automatic backups: only the newest N are kept (Backup & Restore); manual and safety backups stay until the Admin deletes them. Delete old backups, and keep copies on other drives protected like the system itself |
| User accounts | Name, username, email, role, password hash | [TO CONFIRM: period to be set by the school] | Deactivate when the person leaves; delete or anonymize after the period the school confirms (history must keep working) |
8. Who can see the data and who we share it with
- Teachers see their own questions, tests, and the results of their own classes.
- Program Heads see items and tests sent for approval and department-wide summaries.
- Admins manage accounts, students and settings, and see usage reports and activity records.
- We do not share personal data with anyone outside the school. The system is set up to run on the school's own computer or server, with the scanner on the same machine. [TO CONFIRM: confirm hosting: no cloud service or outside company receives the data]
- We may give data to an authority only when the law requires it.
9. How we protect the data
- Passwords are hashed. Accounts lock after too many wrong passwords. Sessions end after a period of inactivity.
- Every page checks the user's role. Teachers cannot open other teachers' private work.
- Forms are protected against forged requests, and the database is accessed in a way that blocks injection attacks.
- Exam files and answer sheet photos are stored in a protected folder and are served only to people allowed to see them.
- Activity is logged so that misuse can be found.
No system is perfectly secure. If a security incident puts your data at risk, the school will tell you and the National Privacy Commission as the law requires.
10. Your rights
Under the Data Privacy Act you have the right to:
- Be informed about how your data is used (this notice).
- Access the personal data we hold about you.
- Correct data that is wrong or out of date.
- Object to the use of your data, or withdraw consent where consent was the basis.
- Erase or block data that is no longer needed, or that is used unlawfully.
- Data portability: get a copy of your data in a common electronic format.
- Claim damages if you were harmed by wrongful use of your data.
Some data, such as official academic records, must be kept by the school for a period set by law. In that case we will explain why we cannot delete it.
11. How to make a request or ask a question
- Use the Contact and Support form and choose Privacy request, or
- Write to the DPO: [Data Protection Officer name - to be set], [Data Protection Officer email - to be set], or contact [Privacy contact (email / phone / office) - to be set].
- Students can also tell their teacher. If the data is wrong, the teacher can correct it or pass the request to the Admin.
We will reply within [TO CONFIRM: number of days set by the school, for example 15 days]. We may ask you to prove who you are before we share or change data.
12. How to complain
If you think your data was handled wrongly, please talk to us first so we can fix it. You also have the right to complain to the National Privacy Commission (NPC) of the Philippines. See privacy.gov.ph for how to file a complaint and for the Commission's current contact details.
13. Changes to this notice
When this notice changes, the version number and effective date at the top change too. Important changes will be announced in the system.