Privacy Policy

Last updated: June 2026

This policy explains how Zyqual handles personal data in support of Jamaican schools, the Ministry of Education and Youth, the Jamaica Teaching Council, and authorised education-sector users. It is written for transparency and should be read together with any agreement, policy, or lawful instruction issued by your school, the Ministry, JTC, or another authorised public body.

1. Introduction

Zyqual Ltd. ("Zyqual", "we", "our", "us") is committed to protecting the privacy and dignity of educators, administrators, students, parents or guardians, and other individuals whose personal data is processed through the Zyqual platform and related services, including ZyAi and ZyqualSMS.

We aim to comply with the Jamaica Data Protection Act, 2020, applicable regulations and guidance issued by the Office of the Information Commissioner, contractual obligations with education-sector partners, and good information-security practice. This policy is not legal advice.

Depending on the feature and data involved, other Jamaican laws and policies may also be relevant, including education-sector policies and directives, the Child Care and Protection Act where child or student welfare information is involved, the Cybercrimes Act where unauthorised access or misuse of systems is involved, and the Electronic Transactions framework where electronic records, notices, or transactions are used.

2. Who We Are and Our Role

Zyqual Ltd. is an education technology company headquartered in Jamaica. We provide quality assurance, observation, appraisal, reporting, professional-development, and education management tools to authorised schools and education-sector bodies.

Depending on the feature and data involved, Zyqual may act as:

Data processor or service provider: when we host, secure, process, report on, or support records on behalf of a school, the Ministry of Education and Youth, JTC, or another authorised data controller.
Data controller: for Zyqual account administration, platform security, support requests, billing or contractual records, website enquiries, and internal business operations where Zyqual determines the purpose and means of processing.

Education records entered into Zyqual are normally controlled by the originating school, the Ministry of Education and Youth, JTC, or another authorised education-sector body. Zyqual does not claim ownership of those records.

Postal: Junior Technology Centre, Kingston, Jamaica
Phone: +1 876-491-0647
Email: info [at] zyqual.com

3. Information We Collect or Process

Account and identity data: name, official email address, phone number, user role, school, region, parish, account status, authentication and security information.
Professional profile data: position, subjects, grades, qualifications, certifications, appraisal role, professional development, and related career records.
Education and operational records: lesson observations, appraisal instruments, self-assessments, invitations, reports, IPDPs, SWOT records, attendance, enrolment, IEP or student-support records, evidence uploads, notices, and related comments entered by authorised users.
Student and child-related information: information entered by authorised school or Ministry users for educational administration, support, safeguarding, inclusion, attendance, learning, or reporting purposes.
Usage, device, and security data: login events, pages visited, feature use, timestamps, IP address, browser, device, operating system, audit logs, error logs, and security monitoring records.
Communications: support requests, contact forms, emails, training enquiries, feedback, and related correspondence.

4. Why We Process Personal Data

We process personal data for specified education and platform purposes, including to:

provide secure access to Zyqual and verify user roles;
support observations, appraisals, professional growth, school improvement, and reporting;
make relevant records available to authorised school, Ministry, JTC, regional, or national users according to role and lawful purpose;
produce school, regional, and national reports, including aggregated or de-identified indicators where appropriate;
send service, security, access, workflow, and support notifications;
maintain audit trails, investigate misuse, prevent unauthorised access, and protect the platform;
meet legal, contractual, regulatory, public-interest, and education-sector obligations.

5. Legal Basis and Data Protection Standards

The legal basis for processing may include consent, performance of a contract, compliance with legal obligations, legitimate interests, public-interest or official functions, protection of vital interests, and instructions from the relevant data controller. Where consent is used, it must be informed, specific, freely given, and capable of withdrawal where the law permits.

Zyqual designs its platform and procedures around the eight Jamaica data protection standards: fairness and lawfulness, purpose limitation, data minimisation, accuracy, storage limitation, data-subject rights, technical and organisational security measures, and safeguards for cross-border transfers.

6. Who Can Access Data and Why

Access to personal data is based on role, school or organisational scope, and the purpose for access. The examples below describe common access patterns. Actual access can vary by module, role assignment, legal instruction, and institutional configuration.

Party	Typical access level	Purpose
Individual users	Their own account, profile, assigned tasks, observations, appraisals, and records they are authorised to view or complete.	Participation in professional development, appraisal, observation, support, and school workflows.
School leaders and authorised school administrators	School-scoped records for staff, observations, appraisals, invitations, reports, and operational workflows.	School improvement, supervision, support, reporting, and lawful administration.
Regional or Ministry users	School, region, or national records according to assigned permissions; some personal-level records where required for oversight or support.	Quality assurance, monitoring, policy implementation, intervention, and education-sector reporting.
Jamaica Teaching Council or other authorised professional bodies	Records relevant to professional standards, appraisal, certification, registration, professional development, or lawful oversight, where authorised.	Professional regulation, standards, certification, support, or policy functions.
Zyqual support, engineering, and security staff	Limited access required to operate, troubleshoot, secure, audit, or support the platform.	Technical support, incident response, maintenance, security, and service delivery.
Service providers	Limited processing needed for hosting, backups, email, SMS, payment, analytics, monitoring, or other platform services.	Providing services to Zyqual under confidentiality and data-protection obligations.

7. Transparency, Audit Logs, and High-Level Access

Zyqual's policy is that users should know which categories of parties may access their data, the level of access those parties may have, and the purpose for that access. The platform uses role-based access controls, school and region scoping, audit logging, and administrative controls to support this.

Where JTC, Ministry, regional, national, SuperAdmin, or other high-level users access personal-level records outside a routine workflow, Zyqual aims to record who accessed the information, when it was accessed, and the purpose or business reason where the system captures that reason. Where required by law, contract, institutional policy, or enabled platform workflow, Zyqual will provide user notifications, access notices, or audit visibility. Some access may be recorded in audit logs rather than sent as an individual notification, especially for routine reporting, support, security, or legally restricted investigations.

Schools may maintain a permanent institutional administrator account linked to the school's official email address for continuity, recovery, and authorised school administration. This protects the school if a principal, administrator, or other named staff member leaves. Day-to-day access to personal records should normally be carried out through named user accounts. Use of an institutional school account for sensitive or personal-data access may be subject to additional controls, such as MFA, password rotation, purpose capture, audit logging, and notification or audit visibility where required or enabled.

8. Sharing and Disclosure

We do not sell personal information. We disclose personal data only when there is an authorised purpose, including:

to the relevant school, Ministry, JTC, regional, or national education authority according to role and lawful purpose;
to authorised colleagues, appraisers, observers, supervisors, or administrators within configured workflows;
to service providers who process data for Zyqual under contractual confidentiality and data-protection obligations;
to comply with law, regulation, court order, lawful public-authority request, audit, investigation, or enforcement requirement;
to protect rights, safety, platform security, and the integrity of education records.

9. Security Measures

We use technical and organisational safeguards designed to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage. These include role-based access controls, authentication controls, audit logging, encryption in transit, backup and recovery practices, security monitoring, staff access limits, incident response procedures, and regular review of platform controls.

No system can be guaranteed 100% secure. Users must keep passwords confidential, use authorised accounts only, and report suspected unauthorised access immediately.

10. Data Retention and Disposal

We retain personal data only for as long as necessary for the purposes described in this policy, to provide the platform, to comply with school, Ministry, JTC, contractual, audit, public-record, education-record, and legal requirements, and to protect rights or investigate misuse. Where data is no longer required, it will be deleted, anonymised, archived, or disposed of in accordance with applicable law, controller instructions, and approved retention schedules.

11. Data Subject Rights

Under the Jamaica Data Protection Act, data subjects have rights that may include the right to be informed, access personal data, request correction, restrict processing, withdraw consent where processing depends on consent, object to certain processing, and object to decisions based solely on automated processing where applicable.

Some rights may be subject to exemptions, lawful restrictions, retention duties, or the role of the relevant school, Ministry, JTC, or other data controller. To exercise a right, contact your school or relevant data controller, or email Zyqual at info [at] zyqual.com and we will help route the request appropriately.

12. Children and Student Data

Zyqual is primarily designed for authorised education-sector staff. Student or child data is entered by authorised users for educational administration, support, safeguarding, inclusion, attendance, learning, or reporting purposes. Schools, the Ministry, JTC, or other authorised bodies remain responsible for ensuring that student data is entered and used lawfully and fairly.

13. Cookies and Similar Technologies

We use cookies and similar technologies to keep users signed in, secure sessions, remember preferences, prevent misuse, and understand platform performance. See our Cookie Policy for details.

14. International Transfers and Service Providers

Some hosting, backup, email, SMS, support, monitoring, or other service providers may process data outside Jamaica. Where personal data is transferred outside Jamaica, Zyqual applies safeguards such as contractual obligations, access controls, security measures, and assessment of the protection available in the receiving jurisdiction, subject to the instructions and obligations of the relevant data controller.

15. OIC Registration, Data Protection Officer, DPIAs, and Regulatory Cooperation

Where Zyqual acts as a data controller and is required to do so, we intend to register and maintain registration with the Office of the Information Commissioner (OIC), appoint a Data Protection Officer where required, maintain appropriate Data Protection Impact Assessment records, and cooperate with lawful regulatory requests.

As at this policy update, the OIC has publicly advised that registration for the current registration year is temporarily paused while its online registration portal is upgraded. Zyqual will continue preparing and maintaining the information required for registration and will complete or renew registration when the OIC portal is available and Zyqual is required to do so. See the OIC's registration advisory and Register of Data Controllers.

16. Breach and Incident Notification

If a security breach or contravention affects or may affect personal data, Zyqual will support the relevant data controller and, where Zyqual is the data controller, report to the Information Commissioner within the time required by law after becoming aware of the breach. Affected data subjects will be notified where required, including information about the nature of the breach and steps taken or proposed to reduce harm.

17. Automated Processing and AI Features

Zyqual may include analytics or AI-assisted features to support reporting, lesson planning, curriculum analysis, professional development, or school improvement. These tools are intended to support human judgement. Where a decision significantly affects a data subject, authorised users should not rely solely on automated processing without appropriate human review, context, and lawful authority.

18. Complaints

You may contact Zyqual, your school, the Ministry, JTC, or the relevant data controller with privacy concerns. You may also contact the Office of the Information Commissioner in Jamaica if you believe your data-protection rights have not been respected.

19. Changes to This Policy

We may update this Privacy Policy as the platform, law, regulations, or education-sector requirements change. Material changes will be posted on this page and, where appropriate, communicated by email, in-platform notice, or another reasonable method.

20. Contact Us

For privacy questions, requests, or concerns, email info [at] zyqual.com or call +1 876-491-0647.