Privacy Policy

BioCE Academy: clinical-epidemiology courses platform · Effective 6 October 2026 (previous version 21 September 2026) · ROPA in the programme docs

This policy explains what personal data BioCE Academy at course.bioce.cloud ("BioCE Academy"), and the individual course platforms it links to (including the PGCE programme at pgce.bioce.cloud) (together "the Platform"), collect, why, and how it is handled. The Platform is operated by the Department of Biomedical Informatics and Clinical Epidemiology (BioCE), Faculty of Medicine, Chiang Mai University ("we", "the programme team"). Contact: cecsmedcmu@gmail.com.

1. What we collect

• Google sign-in data. When you sign in with Google we receive your name, your Gmail address and basic profile details. Only personal @gmail.com accounts are accepted, and we require that Google has verified the address. We never see or store your password.
• Enrolment data. Your first name, surname, email, course and cohort, and optionally a phone number and administrative notes, provided by you (for example through an access request) or by the programme team when you are added to the approved-learner list.
• Learning activity. Which lessons you open, video watch sessions (start time and periodic progress signals roughly every 30 seconds, including player state and position), quiz attempts, answers and scores, records of course materials you download, and certificate records.
• Technical and security data. IP address, browser type (user agent), session identifiers, and an append-only audit log of account and administrative actions.

2. How we use it

• To check that you are an approved learner and give you access to your enrolled courses only.
• To show you your own progress and quiz results, and to let the programme team monitor course engagement and produce reports.
• To issue and verify completion certificates.
• To protect course content: videos display, and downloaded PDFs are stamped with, a personal watermark containing your email address, the date and time, and a session code. This deters unauthorised sharing and makes leaked copies traceable to the account that accessed them.
• To keep the Platform secure and investigate suspicious activity.

3. Legal basis

We process personal data under Thailand's Personal Data Protection Act (PDPA, B.E. 2562). Exam records, attendance and other academic records rest on the educational task of the programme and on legitimate interest in running and securing that task, not on consent. A consent basis would let a student withdraw their own exam record. Consent is used only where the law separately requires it (it is not the basis for assessment data).

4. Sharing

• Google LLC provides the sign-in service. Video lessons are played through an embedded YouTube player (youtube-nocookie.com); playback is subject to Google's privacy policy.
• Hosting provider (the independently operated VPS in Singapore) stores the application database.
• Cloudflare sits in front of some surfaces (watchdog / selected hosts) as a CDN and security proxy.
• Mail sender (Resend, when configured) delivers transactional mail from a bioce.cloud identity.
• Programme staff (Super Admin, Admin and Secretary roles) can see learner data needed for administration. The per-paper exam results list (who passed, who has not, who has not sat) can be downloaded as a spreadsheet by an administrator (Admin or Super Admin role), not by a Secretary; hub exports of per-student scores stay Super Admin only. Every download is written to the audit log.
• We do not share personal data with anyone else except where the university or the law requires it.

5. Retention

Activity, enrolment, exam and attendance records are kept for the duration of your enrolment plus one academic year. Certificate records and their verification codes are retained so certificates stay verifiable. Audit-log rows are append-only. Audit-log IP addresses are truncated at 12 months; the rest of the row stays for accountability.

6. Your rights

You may ask us to access or correct your personal data, or to delete it where deletion does not conflict with academic-record obligations. Email cecsmedcmu@gmail.com from your registered Gmail address.

7. Security

The Platform is served exclusively over HTTPS. Every request is authorised on the server, learner and administrator roles are separated, original course materials are stored privately and never publicly accessible, and administrative actions are recorded in an append-only audit log.

8. Changes

If this policy changes, the updated version will be posted on this page with a new effective date.

9. Controller and processor

The data controller is the Faculty of Medicine, Chiang Mai University / the PGCE programme. The processor is the bioce.cloud operator (independently hosted). A data-processing agreement is required and not yet signed.

10. Cross-border transfers

The Platform is hosted on a VPS in Singapore, outside cmu.ac.th and CMU Account. Some request traffic also passes through Cloudflare.

11. Data-subject requests and breach notice

PDPA requests and breach notice: cecsmedcmu@gmail.com.

12. Exam-integrity monitoring

During a high-stakes exam the Platform may record leave-count / close-book integrity signals. That is behavioural monitoring for exam integrity, announced here. Extending it needs a DPIA and a further announcement first.

13. Analytics aggregation

Hub analytics are aggregates by default. Drill-down is admin-tier. Hub exports of per-student scores are Super Admin only and audit-logged; the exam results list of one paper (section 4) can be downloaded by an administrator (Admin or Super Admin) and is audit-logged too. Cells with n<5 are suppressed in published aggregates.