Privacy Policy, Cookies Policy and Whistleblower - GRM Institute

Privacy Policy, Cookies Policy and Whistleblower

Privacy Policy

This Privacy Policy explains what information we collect when you visit or use any of Risk Educators Pvt Ltd. (REPL) or it’s brand Global Risk Management Institute (GRMI) websites, services, applications, APIs and content. It also has information about how we store, process, use, share and delete that information.

What We Collect

REPL does not automatically capture any specific personal information (such as name, phone number and e-mail address) from you, that allows us to identify you individually (Personally Identifiable Information – PII). Any and all such information is obtained when you fill either physical or electronic forms, in which you expressly and explicitly provide your PII towards fulfilment of an REPL service to you.

REPL does gather information about you such as your Internet Protocol (IP) address, domain name (if applicable), browser type, operating system, date and time of your visit to an REPL service, and similar analytics information. However, REPL does not attempt any linkage of such analytics data with your identity, unless our systems detect malicious traffic from your end.

In addition, REPL may use 3rd party analytics services (such as Google Analytics) to help us analyses your use of REPL services. Such 3rd parties may have access to the information that we collect through their services.

How We Use Your Information

The purpose of any and all information that we may collect about you, including any PII and other analytics information, is only to provide an improved and more relevant experience – including but not limited to content and user experience personalization – of REPL Services to you and other users of REPL Services.

Retention

REPL, being a higher education institution, indefinitely retains all academic and other relevant non-academic records pertaining to individuals and entities that utilize one or more of REPL Services.

Except for the above, REPL stores your PII (if any) only as long as is strictly needed to provide an improved and more relevant experience of REPL Services to you.

REPL retains aggregated and non-identifying information about how users access and utilize REPL Services, to improve such services.

Sharing

REPL never sells your PII (if any) to any 3rd party. REPL does not share your PII (if any) with any 3rd party without prior explicit consent from you, except when such 3rd party is an investigating law enforcement authority or a court of law with applicable jurisdiction.

Security

REPL makes all reasonable efforts to safeguard your PII (if any), and protect it from loss, misuse, unauthorized access or disclosure, unauthorized alteration, or destruction.

Contact

You can contact REPL at director@grm.institute at any time, to inquire about, examine, update or request for deletion of your PII (if any) that is stored by us.

Cookies Policy

This Cookies Policy explains what cookies are, how REPL uses cookies and how 3rd parties may use cookies when you visit or use any of  REPL websites, services, applications, APIs and content.

What are Cookies

Cookies are small pieces of text that websites and applications send to your browser or app, when you visit them. A cookie is stored as a simple text file in your browser’s storage or app storage. Only the website or the application that sent that cookie will be able to retrieve, read and update it. A cookie helps the website or the application to recognize a returning user, and helps in easing navigation between pages. It helps in storing your preferences, and can help in improving your experience of the website or the application that set it.

Cookies can be transient (“session” cookies) or be stored for longer durations (“persistent” cookies).

How REPL Uses Cookies

When you use one or more of REPL Services, we may place one or more cookies in your browser.

REPL uses cookies to: enable certain functions of the Service(s), to store your preferences with respect to such Service(s), to provide analytics and to enable personalized experience of such Service(s).

REPL may use both session and persistent cookies.

Certain REPL Services require authentication, and hence are essentially dependent on cookies. Such Services are inaccessible without allowing cookies.

3rd Party Cookies

REPL may use 3rd party analytics services (such as Google Analytics) to help us analyses your use of REPL Services. Such 3rd parties may use and set certain cookies for such purposes.

Your Choices

If you wish to delete cookies or instruct your browser to refuse (or implicitly delete) cookies, please consult your browser’s documentation.

Please note that should you delete cookies one or more features of the REPL Services that you access may not function as intended. Also, you may not be able to store your preferences with respect to functions such as display of content, availability of services, or availability of features.

Whistle-blower Policy

REPL & GRMI requires its directors, officers, employees, students, faculty, vendors, customers, interns, and volunteers, [as well as all persons who provide REPL with contracted services] to observe high standards of business and personal ethics in the performance of their duties on the Institute’s behalf.

The Institute is committed to protecting individuals from interference when making a “Protected Disclosure” (see definition below) and from retaliation for having made a Protected Disclosure or for having refused to follow an illegal instruction.

The principal objective of this Whistleblower Policy is to encourage and enable Institute representatives, without the fear of retaliation, to raise concerns regarding suspected unethical and/or illegal conduct or practices on a confidential and, if desired, anonymous basis, so that the Institute can address and correct inappropriate conduct and actions.

This policy is not intended to be the method for reporting violations of the Institute’s applicable human resources policies, problems with colleagues, co-workers, or supervisors, or for reporting issues related to alleged employment discrimination or sexual or any other form of unlawful harassment, all of which should be handled in accordance with the Institute’s Personnel, Student Conduct Policies  and the PGDRM Manual.  Those policies, found in the Institute Statutes, the Handbook for Administrators, the most current Collective Bargaining Agreements, and the Student Handbook, are designed to address individual grievances and personal complaints.

The Institute will exercise its authority to take whatever action may be needed to prevent and correct activities that are found to constitute wrongful conduct.

Definitions
  1. Wrongful Conduct Concern (“Concern”)

A violation of Institute policies; a violation of applicable local, Haryana State; or the use of Institute property, resources, or authority for personal gain or other non-Institute-related purposes.

  1. Protected Disclosure

Communication about actual or suspected wrongful conduct engaged in by a Institute faculty member, staff member, student worker, volunteer, Staff, Faculty, Customer, vendor or contractor (who is not also the disclosing individual) based on a good faith and reasonable belief that the conduct has both occurred and is wrongful under Institute policies and/or applicable laws. Individuals who are aware of, or have reason to suspect wrongful conduct should report the conduct promptly.

Reporting Concerns

Concerns should be reported either in writing as soon as practicable to any one of the following:

  1. The Dean and Director on Board Mr. Chetan Mathur

director@grm.institute

Handling Reporting Concerns

The Dean office receiving reports shall report them immediately to the Office of Academic Council, Board of Directors or Management as applicable which, in consultation with the Office of Legal Counsel, has the responsibility for investigating concerns and issuing reports to the Board Committee on Audit and Risk Management (“Board Committee”).

Investigations

The Office of the Dean and responsible committee will attempt to notify the disclosing individual (when identity is known) to acknowledge receipt of the reported concern. All reports will be promptly investigated, and appropriate corrective action will be taken when warranted by the investigation. The Office shall determine the scope, manner, and parameters of any investigation and report to the Board Committee and appropriate Institute officers.

Reporting Responsibility

It is the responsibility of all Institute representatives to report, in good faith, concerns they may have regarding actual or suspected activities which my be illegal or in violation of the Institute’s policies with respect to, without limitation, fraud, theft, embezzlement, accounting, or auditing irregularities, bribery, kickbacks, and misuse of the Institute’s accounting or auditing irregularities, bribery, kickbacks, and misuse of the Institute’s assets, as well as any violations or suspected violations of high business and personal ethical standards.

No Retaliation

No Institute representative who in good faith reports a concern shall suffer intimidation, harassment, retaliation, discrimination, or adverse employment consequences because of such report. Any employee of the Institute who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including termination of employment.

Acting in Good Faith

Anyone reporting a concern must act in good faith and have reasonable grounds for believing that the information disclosed may indicate a violation of a law, Institute policy and/or ethical standards. Any allegations that prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

The Institute takes seriously its responsibility to enforce this Policy, and therefore encourages any person reporting a concern to identify him or herself so as to facilitate any resulting investigation. Notwithstanding the foregoing, in reporting a concern, Institute representatives can request that their report be treated in a confidential manner (including that the Institute takes reasonable steps to ensure that the identity of the reporting person remains anonymous).

Concerns will be kept confidential to the extent possible, consistent with the need to conduct a thorough and complete investigation.

Records

The Institute will retain on a strictly confidential basis for a period of seven (7) Years (or otherwise as required under the Institute’s Record Retention and Disposal Policies in effect from time to time) all records relating to any reported Concern and to the investigation and resolution thereof. All such records are confidential to the Institute, and such records will be considered privileged and confidential, subject only to a lawful subpoena or other recognized government authorities.

Distribution

The Institute shall inform and provide a copy of this Policy to all Institute employees, officers, directors, student workers, and all other persons or contractors who provide substantial service to REPL.

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