ACE Education Ltd has designed a comprehensive strategy to meet contractual data protection requirements recognising industry security standards, while ensuring the confidentiality, integrity, and availability of personal information. This includes the following: 1. Data Classification and Inventory: For all contracts we implement a robust data classification system to identify and categorize personal information based on sensitivity and importance. This includes maintaining a comprehensive inventory of all personal data, including its location, purpose, and access controls. 2. Risk Assessment and Management: We conduct regular risk assessments to identify potential threats and vulnerabilities to personal information. For each project we develop and implement risk mitigation strategies to address identified risks and vulnerabilities. 3. Compliance with Data Protection Laws and Regulations: We stay informed about and comply with relevant data protection laws and regulations in all jurisdictions where we operate. Our Data Protection representative oversees compliance efforts and act as a point of contact for data protection authorities. 4. Security Policies and Procedures: We enforce comprehensive security policies and procedures that cover data access, transmission, storage, and disposal. This includes training for all employees on security protocols and best practices. 5. Access Controls: We implement robust access controls to ensure that only authorized personnel have access to personal information. We use a principle of least privilege to restrict access to the minimum necessary for job functions. 6. Encryption and Data Security: All sensitive personal information is encrypted both in transit and at rest to prevent unauthorized access. We implement secure coding practices to protect against vulnerabilities in applications that process personal data. 7. Incident Response and Reporting: We have developed and regularly test an incident response plan to efficiently address and contain any data breaches or security incidents. We have a clear process for reporting and documenting incidents, ensuring timely notification to affected parties and relevant authorities as required by law. 8. Regular Audits and Monitoring: We conduct regular security audits to ensure compliance with security policies and industry standards. 9. Documentation and Accountability: We maintain detailed documentation of data protection practices, risk assessments, and compliance efforts. We have established clear lines of accountability for data protection within the organization. By outlining these strategies, ACE Education Ltd demonstrates a commitment to meeting contractual data protection requirements and adhering to recognized industry security standards while safeguarding the confidentiality, integrity, and availability of personal information. Annual updates and adjustments to these measures are made to stay abreast of evolving threats and regulatory changes.