Privacy Policy

The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011

Indian Contract Act, 1872

Companies Act, 2013 (if CSR is involved)

Voluntary Organisation Guidelines

Data privacy obligations for government-linked schemes (e.g., NSDC, MSDE, CSR-funded programs)

---

✅ Privacy Policy

Effective Date: 01-04-2025

Issued by: Manmukh Education Consultancy

Website: www.manmukh.org

---

✅ 1. Introduction

Manmukh Education Consultancy (“MEC”, “we”, “our”, “us”) is a not-for-profit organization Indian Trusts Act, engaged in the promotion of skill-based education, training, and capacity building across marginalized and underprivileged sections of society and many more training cum development programmes, Services & works

This Privacy Policy outlines how MEC collects, uses, stores, discloses, and protects personal and sensitive information of its beneficiaries, donors, partners, staff, volunteers, government bodies, and visitors to its digital and physical platforms.

---

✅ 2. Legal Compliance

This Privacy Policy is framed in accordance with:

Information Technology Act, 2000 (as amended)

SPDI Rules, 2011 under IT Act

Right to Privacy under Article 21 of the Indian Constitution

Guidelines issued under CSR Rules, NGO-DARPAN, MSDE, and other government welfare schemes

Best practices for Voluntary Organizations (VOs)/NGOs per NITI Aayog guidelines

---

✅ 3. What Information We Collect

3.1 Personal Information:

Full Name, Date of Birth, Gender, Photograph, Signature

Father’s/Mother’s/Guardian’s Name

Address (current & permanent), Mobile Number, Email Address

3.2 Sensitive Personal Data or Information (SPDI):

Aadhaar Number / PAN / Voter ID / Ration Card

Bank Account Details (for stipends or reimbursements)

Caste/Category Certificate (if applicable under government scheme)

Educational Certificates

Biometric Data (only if required by authorized program)

Health information (if medical training or insurance is provided)

3.3 Other Data:

Location data (via app/attendance tracking tools)

IP address and device metadata (for website and mobile app)

Feedback, assessment scores, training records

---

✅ 4. Sources of Data Collection

Online application forms on MEC portals or third-party platforms

Offline data collection through camps, training centers, or partner NGOs

Government portals (e.g., NSDC, Skill India, NAPS)

Attendance tracking tools (AEBAS, biometric, QR)

Referrals from CSR or government-linked initiatives

Cookies and analytics via website

---

✅ 5. Purpose of Data Collection

Candidate identification, verification, and enrollment

Government scheme reporting and audits (where required)

Program monitoring and evaluation (M&E)

Issuance of certificates, ID cards, or documentation

Financial processing (stipends, travel allowance, bank transfers)

Partner and donor reporting under CSR Rules, Companies Act, etc.

Legal compliance under contracts, MOUs, and grant agreements

Risk management, fraud detection, and grievance redressal

---

✅ 6. Lawful Basis of Processing

Consent: Explicit written or digital consent from the data subject

Legal Obligation: Under schemes like PMKVY, CSR projects, etc.

Contractual Necessity: MoUs with donor agencies, implementation partners

Legitimate Interest: Training performance tracking, capacity building

Public Interest: Supporting underprivileged and disadvantaged groups

---

✅✅ 7. How We Use the Data

Deliver training, awareness, and employment-readiness programs

Track attendance, performance, and placement (where applicable)

Communicate program updates, alerts, or beneficiary messages

Issue certifications, ID cards, letters, or reports

Conduct internal reviews and third-party audits

Submit utilization certificates and impact reports to funding bodies

---

✅ 8. Information Sharing and Third-Party Disclosure

MEC does not sell or rent your data to anyone.

We may disclose information, strictly on a need-to-know basis, to:

Government departments (e.g., Ministry of Skill Development, NSDC)

CSR and donor companies (as required under funder agreements)

Academic or certifying bodies (for certification)

Payment gateways or banking institutions (for stipends)

Technology partners and data processors (under binding agreements)

All such disclosures are governed by Data Protection Agreements (DPA) and Non-Disclosure Agreements (NDA).

---

✅ 9. Data Storage and Retention

Encrypted cloud-based databases

Secure local servers (with access logs and role-based control)

Locked paper records (only if mandated)

Retention Period:

7 years for financial records (as per audit norms)

5 years for training and beneficiary data (as per CSR and govt. norms)

Until consent withdrawn or legal obligation ends for other records

---

✅ 10. Data Security Measures

SSL encryption for online portals

Role-based access control (RBAC)

Biometric locks and surveillance at physical data centers

Strong password policies for staff and system users

Regular security audits and backups

---

✅ 11. Your Rights

Right to access information held about you

Right to correct or update data

Right to withdraw consent (subject to law)

Right to lodge a complaint with appropriate authority

Right to request deletion of data (subject to audit/legal obligations)

To exercise your rights, email: privacy@manmukh.org

---

✅ 12. Children’s Privacy

We do not knowingly collect data from minors under the age of 12 without parental or guardian consent.

If you believe that a child has provided us personal information without appropriate consent, please contact us immediately.

---

✅ 13. Website and Cookies Policy

Our website may use cookies to improve user experience and site functionality.

By using our website, you agree to our use of cookies.

You may disable cookies through your browser settings.

---

✅ 14. Changes to Privacy Policy

This policy is subject to periodic review.

Updates will be posted on our official website. Users are encouraged to check regularly for changes.

---

✅ 15. Grievance Redressal and Contact

Data Protection Officer (DPO)

Manmukh Education Consultancy

2nd Floor, Gorai Complex, Beside IDBI Bank, Kanke Road, Ranchi, Jharkhand - 834008

Email: privacy@manmukh.org | CC: info@manmukh.org

Phone: 9241957592

Reviewed and Approved by Governing Board of MEC

Policy Version: 1.0

Review Cycle: Annual or As Needed