NASBA Sites and Services include features (“AI Features”) that may use generative artificial intelligence to gather and use personal information to provide services or improve their sites, including but not limited to improving data security, preventing fraud or cheating during testing, and providing NASBot services.
a. Basis for Collection and Use
You provide NASBA with most of the data we collect. NASBA collects and uses your personal information generally as follows:
i. By Consent: You are providing clear, voluntary, and specific permission to collect and use your data so that you can use NASBA services.
ii. Contract: Data collection is necessary to make or fulfill a legal agreement with you if you are an exam / license applicant, a licensee, or otherwise have access to NASBA systems or services.
iii. Legal obligation/Public Task: NASBA must collect, process and save your data in their role in performing official duties on behalf of State Boards of Accountancy who have been assigned by law to carry out all CPA licensing and enforcement duties for their state.
iv. Legitimate interests: Some data is needed for NASBA to meet its own operational goals and does not interfere with your rights to maintain the safety and confidentiality of your information.
b. National ID numbers, including passport numbers, driver’s license numbers, and/or social security numbers (collectively “National ID Numbers”), may be used only for verifying your identity and detecting and investigating cheating, infringement of intellectual property rights, breaches of Test-related agreements, fraudulent activity, and compliance with applicable mandatory legal requirements. Access to National ID numbers shall be restricted to employees, agents, service providers and government entities with a need to access them for these purposes, and reasonable efforts shall be made to protect National ID numbers from unlawful disclosure and keep them confidential by maintaining physical, electronic and procedural safeguards that comply with applicable regulations.
c. All other Personal Data may be used for the following purposes:
i. NASBA may receive and access your Personal Data for purposes of facilitating the application process for licensure with the State Boards, investigating any suspected fraudulent or inappropriate activity, including without limitation cheating, infringement of intellectual property rights, violating Test-related agreements, and verifying and tracking your licensure status;
ii. NASBA or the State Boards determining your eligibility to sit for the Test and obtain a CPA license;
iii. NASBA’s administration and operational purposes (e.g., in relation to attendance at exams, communicating results, Test times and other details);
iv. Helping NASBA and the State Boards to track your license status;
v. Verifying compliance with the State Board and NASBA’s Test-taking and application policies;
vi. Backing up records to prepare for events that may make it difficult for NASBA to access original copies of your Personal Data;
vii. Helping NASBA and State Boards comply with contractual, legal or regulatory obligations;
viii. NASBA‘s and the State Boards’ detection and investigation of fraudulent activity; and
ix. NASBA’s reasonable and legitimate business management purposes, including without limitation, the protection of their respective copyright, trade secret, and trademark rights, and the analysis and public release of aggregated and fully anonymized Personal Data.
d. Table 1: Purpose Specifications and Use Limitation.
In the table below, we have set out the purposes, use and legal basis for NASBA to collect and process your information, and the categories of information (as described in the “Information We Collect” section above) used for these purposes. If we wish to process your existing information for a new purpose other than as stated below, we may inform you and provide information surrounding your information’s use.
| General Data Type |
Permissible Use / Purpose
How we use your Personal Data
|
Legal Basis for Collection |
Categories
Specific categories of information used by NASBA for each Data Type.
|
|
1. Candidate Application Data
|
Applications for Examinations and Licensure:
CPAES, CPA Portal: Providing and administering your online account access exam-related materials and information and other services, schedule an examination, and or complete information required to site for an examination or obtain licensure. Facilitating the application process for examination and licensure with State Boards; verifying user’s identity; determining users’ eligibility to sit for tests; verifying user’s educational credentials.
Purposes stated in applicable informed consent agreements.
|
- Performance of contracts with State Boards and Candidates.
- Legitimate Government Purpose to carry out duties on behalf of state government, pursuant to statute.
- Legitimate interest
- Consent, if users are located in India, Canada, Vietnam, or Japan (with respect to Sensitive Personal Data)
|
- Identifiers
- Identity Documents and Images
- Audiovisual Information
- Professional, Educational, or Employment-related Information
- Internet or Other Electronic Network Activity Information
- Demographic Information
- Sensitive Personal Data
|
|
2. Candidate Exam Data
|
Exchanged between NASBA, AICPA, Prometric, State Boards and Candidates for:
Administration and operational purposes (e.g., in relation to attendance at exams, communicating results, test times and other details; communicating with users for Service’s related purposes);
Verifying compliance with the test-taking and application policies; investigating any suspected fraudulent or inappropriate activity, including without limitation cheating, infringement of intellectual property rights, violating test-related agreements, and verifying
Business management purposes, including without limitation, the protection of copyright, trade secret, and trademark rights.
Purposes stated in applicable informed consent agreements.
|
- Performance contracts with State Boards, AICPA, Prometric.
- Legitimate government interest
- Consent, if users are located in India, Canada, or Vietnam
|
- Identifiers
- User Data
- Internet or Other Electronic Network Activity Information
- Biometric Data
- Geolocation Data
- Sensitive Personal Data
- AI Data including real-time audio and video recordings administered by AI of candidates physical movements during the testing event.
|
| 3. Licensee Data |
Exchanged between NASBA, State Boards, and Public for use by Accountancy Licensee Database (ALD); CPA Verify and CPE Audit Service;
NASBA may also serve as a repository for licensee data to be accessed by State Boards.
Purposes stated in applicable informed consent agreements.
|
- Contract Performance
- Legitimate Government Purpose;
- Public Safety and Welfare;
|
- Identifiers
- Identity Documents and Images
- Geolocation Data
- Professional, Educational, Employment, or License Information
- Sensitive information if authorized by licensee.
|
| 4. Employee Access: NASBA, State Boards, Prometric, AICPA, Contractors, Consultants |
Employees of NASBA, State Boards, AICPA, Prometrics and other Third-Party providers access Candidate and Licensee Personal Data. To allow access NASBA may collect employee personal data.
Purposes stated in applicable informed consent agreements.
|
- Contract Requirement
- Public Safety and Welfare
- Meeting state, federal, international data security requirements
|
- Employee Identifiers
- Employee User Data
- Internet or Other Electronic Network Activity Information
- Geolocation Data
|
|
5. All Users
NASBA Backup Data
|
Backing up records to prepare for events that may make it difficult for NASBA to access original copies of your Personal Data |
- Performance of a contract
- Legitimate interest
- Vital interest
- Consent, if you are located in India, Canada, Vietnam, or Japan (with respect to Sensitive Personal Data)
|
- Identifiers
- Financial Information
- Audiovisual Information
- Professional, Educational, or Employment-related Information
- Demographic Information
- User Data
- Internet or Other Electronic Network Activity Information
- Geolocation Data
- Sensitive Personal Data
|
| 6. Purchaser Data |
Processing payment transactions |
- Performance of a Contract
- Consent, if users are located in India, Canada, or Vietnam
|
- Identifiers
- Financial Information
- User Data
- Internet or Other Electronic Network Activity Information
- Geolocation Data
|
| 7. General User Data – Site Improvements |
Use of all NASBA Sites and Services:
Improving services, including to understand how you access and use our services to ensure technical functionality of our Sites,
To prevent or investigate security breaches or other potentially prohibited activities,
To develop new products and services, and analyze your use of our Sites, including your interactions with applications or services made available, linked to, or offered through our Sites.
|
- Consent, if you are in India, Canada, or Vietnam
- Legitimate interest
|
- Identifiers
- User Data
- Internet or Other Electronic Network Activity Information
- Geolocation Data
|
| 8. General User Data -- Marketing |
To communicate with users, either directly or through one of our service providers, for: marketing, research, to provide email updates, or other promotional purposes, via email, notifications or other messages, consistent with any permissions users may have communicated to us. |
- Consent, if users are in India, Canada, or Vietnam
- Legitimate Interest
|
- Identifiers
- User Data
- Internet or Other Electronic Network Activity Information
- Geolocation Data
|
| 9. Deidentified and Anonymized Data |
Industry and public reporting, such as through our Candidate Performance Book.
|
- Consent, if users are in India, Canada, Vietnam, or Japan (with respect to Sensitive Personal Data)
- Legitimate interest
|
Deidentified and Anonymized Versions of the following:
- Identifiers
- Professional, Educational, or Employment-related Information
- Demographic Information
- User Data
- Geolocation Data
- Sensitive Personal Data
|
e. Legitimate Interests
Where NASBA relies on legitimate interests as the basis for collecting and processing your personal information, we carry out a balancing exercise taking into consideration your reasonable expectations of Privacy, your request for NASBA services, and NASBA’s responsibilities to validate identities, assess risk, and prevent, detect, protect or defend against, or respond to security incidents, identity theft, fraud, harassment, malicious, deceptive, or illegal activities.
We therefore, ensure your rights as an individual are not impacted unnecessarily.
We consider that it is reasonable for us to collect and process your Personal Data for the purposes of our legitimate interests when, on balance, (a) we process your Personal Data only so far as is necessary for such purpose, and your rights and freedoms do not outweigh such purposes, and (b) it can be reasonably expected for us to process your Personal Data in this way. In most cases, the information is being processed for your benefit as an exam or license Applicant, Licensees, or State Boards employee or contractor, as well as NASBA’s obligations as stated herein. For example, we have a legitimate interest in processing Personal Data where we need the information to:
- Provide you the ability to take the licensing exams;
- Provide assistance to your State Board that enables your licensure;
- Respond to your inquiries or to send you information; and
- We would be unable to provide our services without processing your information.
f. Withholding Consent
You have the right to withhold your consent for NASBA to collect, process and use your Personal Data as described in this Privacy Policy. However, if you withhold your consent, depending on the purpose of the data collection, you may not be able to sit for the examinations, submit your application to a state board, obtain licensure, obtain required licensee audits, register your CPE credits or perform your duties as an employee of NASBA, State Boards, AICPA, Prometric, Contractor or Consultant. If you have questions about withholding consent to certain specific data, please contact NASBA or your State Board for further information.