Privacy and Security Policy

Privacy Policy

  1. Overview

The University is committed to the responsible use of personal information and sensitive information collected from and about its students, faculty, staff, business partners and others who provide such information to the university. This commitment is in accordance with both state and federal regulations concerning the use of sensitive information. Such sensitive information includes information that could be used to cause financial harm or reputational harm to any individual. This policy applies to personally identifiable sensitive information and how it is collected.

  1. Objective / Purpose

The purpose of this policy is to protect the privacy of individuals who have sensitive information stored (either in electronic or paper form) on assets owned by The University, while at the same time providing the University the ability to share this information with authorized entities as required by legitimate academic or business need or by law.

  1. Scope

The Privacy Policy applies to all faculty, staff, students, affiliates, and third-party service providers. This policy is not intended to replace or supersede other existing University policies and procedures relating to the use of maintenance of sensitive information such as those related to FERPA compliance, GLBA compliance, or human subjects research.

  1. Privacy Policy

4.1 Limits on Use of and Access to Sensitive Information

The responsible use of sensitive information requires that the University respect individual privacy, protect against unauthorized access to or use of information, and comply fully with all laws and government regulations in the collection, use, storage, display, distribution and disposal of such information. Authorized uses of sensitive information within the University are limited to uses which a) are necessary to meet legal and regulatory requirements; b) facilitate access to services, transactions, facilities and information; or c) support efficient academic and administrative processes.

Access to sensitive information is limited to:

  • the individual whose information is produced or displayed;
  • a University official or agent of the University with authorized access based upon a legitimate academic or business interest and a need to know;
  • an organization or person authorized by the individual to receive the information;
  • a legally authorized government entity or representative;
  • or other individuals or entities, as allowed by law, for purposes judged to be appropriate or necessary for the reasonable conduct of University business.

4.2 Social Security Numbers

Social Security numbers are always considered confidential and are therefore subject to the limits of use and access described above. In addition, the University will continue to collect and process Social Security Numbers limited only to instances in which that number is required by law or contract or instances where there is a legitimate business or academic need authorized by University administration. This includes, but is not limited to, all enrolled students who are U.S. citizens or permanent residents.

The University, its faculty, staff, and students must abide by all state legal regulations pertaining to Social Security Number protection.

It is against both state law and University policy to:

  • Publicly post or display the Social Security number in any manner;
  • Require an individual to transmit his or her Social Security number over the Internet unless the connection is secure or the number is encrypted; or
  • Require an individual to use his or her Social Security number to access an Internet site unless a unique password or PIN is also required.
  • Print the Social Security number on any card required to access services; or
  • Establish a new process that requires the printing of a Social Security number on any materials that are mailed unless required by other state or federal agency.

4.3 Online Collection of Information

University departments must post a link to the Privacy Policy on any website which collects data about website visitors.

  1. European Union General Data Protection Regulation (EU GDPR) Privacy Notice

5.1 Lawful Basis for Collecting and Processing of Personal Data

The University is an institute of higher education involved in education, research, and community development. In order for the University to educate its students both in class and on-line, engage in world-class research, and provide community services, it is essential, necessary, and the University has lawful bases to collect, process, use, and maintain data of its students, employees, applicants, research subjects, and others involved in its educational, research, and community programs. The lawful bases include, without limitation, admission, registration, delivery of classroom, on-line, and study abroad education, grades, communications, employment, research, development, program analysis for improvements, and records retention. Examples of data that the University may need to collect in connection with the lawful bases are: name, email address, IP address, physical address or other location identifier, photos, as well as some sensitive personal data obtained with prior consent.

For more information regarding the EU GDPR, please review the University’s European Union General Data Protection Regulation Compliance Policy.

Most of the University’s collection and processing of personal data will fall under the following categories:

  1. a) Processing is necessary for the purposes of the legitimate interests pursued by the University or third parties in providing education, employment, research and development, community programs.
    b) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. This lawful basis pertains primarily but not exclusively to research contracts.
    c) Processing is necessary for compliance with a legal obligation to which the University is subject. This lawful basis pertains primarily but not exclusively to compliance with state and federal laws. Examples are providing enrollment data to the US Department of Education and providing employment and payroll data as required by the US Internal Revenue Service.
    d) The data subject has given consent to the processing of his or her personal data for one or more specific purposes. This lawful basis pertains primarily but not exclusively to the protection of research subjects, providing medical and mental health services.

There will be some instances where the collection and processing of personal data will be pursuant to other lawful bases.

5.2 Types of Personal Data collected and why

The University collects a variety of personal and sensitive data to meet one of its lawful bases, as referenced above. Most often the data is used for academic admissions, enrollment, educational programs, job hiring, provision of medical services, participation in research, development and community outreach. Data typically includes name, address, transcripts, work history, information for payroll, research subject information, medical and health information (for student health services, or travel), and donations. If you have specific questions regarding the collection and use of your personal data, please contact the University.

 

If a data subject refuses to provide personal data that is required by the University in connection with one of the University’s lawful bases to collect such personal data, such refusal may make it impossible for the University to provide education, employment, research or other requested services.

Where the University gets Personal and Sensitive Personal Data

The University receives personal and sensitive data from multiple sources. Most often, the University gets this data directly from the data subject or under the direction of the data subject who has provided it to a third party (for example, application for admission to the University through use of the Common App).

 

5.3 Cookies

Cookies are files that many websites transfer to users’ web browsers to enable the site to deliver personalized services or to provide persistent authentication. The information contained in a cookie typically includes information collected automatically by the web server and/or information provided voluntarily by the user. Our website uses persistent cookies in conjunction with a third-party technology partner to analyze search engine usage and web traffic patterns. This information is used in the aggregate to monitor and enhance our web pages. It is not used to track the usage patterns of individual users.

 

  1. Enforcement and Implementation

6.1 Roles and Responsibilities

Each University department/unit is responsible for implementing, reviewing and monitoring internal policies, practices, etc. to assure compliance with this policy.

6.2 Consequences and Sanctions

Violation of this policy may incur the same types of disciplinary measures and consequences as violations of other University policies, including progressive discipline up to and including termination of employment, or, in the cases where students are involved, reporting of a Student Code of Conduct violation.