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College-wide Policies

Advancement Privacy Notice Policy

Responsible office
Advancement
Responsible party
Vice President for Advancement
Last revision
May 2018
Approved by
The Cabinet
Approval date
May 2018
Effective date
May 2018
Last review
May 2018
Additional references
General Privacy Policy and EU General Data Protection Regulation Compliance Policy

Scope

All financial and administrative policies involving community members across campus are within the scope of this policy. If there is variance between departmental expectations and the common approach described through college policy, the college will look to the campus community to support the spirit and the objectives of college policy.

Policy

Colorado College takes seriously its duty to protect personal information.  This privacy notice explains how CC handles and uses the personal data we collect on our former students, parents of current and former students, and our past, current, and future supporters specifically for fundraising and alumni and family relations activities.

Philanthropic support and the engagement of alumni and families has long fueled the success of Colorado College.  Developing a better understanding of our alumni and supporters allows us to keep in touch with you, in order to keep you apprised of news of the college, to provide services to you, and to identify ways in which you may wish to engage with Colorado College.

What Information is Collected?

  • Contact information – home and business addresses, phone numbers, email addresses, and social media contact information
  • Demographic information – names, titles, gender, birth and death dates, and ethnicity1
  • Student information obtained from college records, including degree details, student activities, awards, and involvement in athletics
  • Employment information including company names, job titles, and industry information
  • Family information, including spouse’s name, children’s names and sometimes birthdates, and familial relationships
  • Donor information, including giving history with Colorado College. We might also obtain information from publicly available sources to give an insight into your philanthropic interests and ability to support Colorado College.
  • Engagement information, including alumni/parent activities, event attendance, volunteer interests, committee participation, awards and honors, attitudes and preferences, responses to surveys, and records of communication from us to you and vice-versa

How is information Collected?

  • Self-provided via mail, phone, e-mail, online, or in person
  • Event or activity registrations
  • Admission, student, and employment records held by Colorado College
  • US Postal records
  • Information you have made publicly available on social media, such as a job change
  • Publicly available data through our own research or from third parties

How is Information Used?

  • To send you communications, including the alumni magazine and updates about the college
  • To conduct surveys
  • To provide alumni services
  • For data enrichment and cleansing to ensure that we have accurate contact information for you
  • To conduct research to help us better understand our alumni, donors, and potential donors
  • For internal record keeping so as to keep a record of your relationship with us, including any preference changes
  • To segment marketing and communication
  • Directory services allowing authorized alumni to search through a network to identify alumni with whom they would like to connect. Data used to facilitate these experiences may include name, class year, degree, major, student activities, city/state/zip, email address, phone number, and information that you may choose to make available through social networks.   For more information about directory services, visit

https://www.coloradocollege.edu/ccnetworkfaq/

https://cctigerlink.com/

https://ourcc.coloradocollege.edu

To opt-out of directory services please email records@coloradocollege.edu

  • To use IP addresses to identify the location of our users in response to malicious activity and forensic analysis

Who Has Access to Information?

Access to information in the Advancement database is limited to college employees whose positions require it and is granularly defined based on job role.  Information contained within the database is also made available to volunteers, faculty members, staff, and administrators working in an official capacity to further Colorado College’s fundraising and alumni relations mission.

Information from the database may be shared with companies who provide a business service related to the mission of the Advancement Division (e.g. data-processing consultants, direct-mail vendors, marketing and merchandise firms, and alumni benefit offers).  The vendor must agree to use the information only for the purposes intended. The college requires third parties to protect personally identifiable information as part of the service contract or through a confidentiality agreement.

Colorado College may share the following information with other colleges or universities seeking the location of alumni with degrees from both Colorado College and the requesting institution: full name, address, telephone number and email address; degree and date of degree awarded by Colorado College; major field of study; and employer address and telephone number.

When Colorado College receives requests for contact information from an outside individual, information will not be directly shared with requestor.  However, staff may offer to make contact with the constituent (unless the constituent is coded as “no contact”) and, with the permission of the requestor, will provide the requestor’s contact information.

Aggregate data which does not identify specific individuals or their personal information may be shared with funders, government organizations, peer institutions, and other groups. 

Donor information may be shared with funders at the discretion of the vice president for advancement (e.g., list of top donors to satisfy terms of charitable grant).

The college may share or transfer information in its database to comply with financial audit procedures; to respond to a judicial process; to comply with state, federal or local laws; or to provide information to law enforcement agencies to the extent required by law.

 Please see https://www.coloradocollege.edu/basics/welcome/leadership/policies/advancement-database-usage for more information on the college’s policy on Advancement Database Usage.

The European Union General Data Protection Regulation (GDPR) Privacy Information

Most of the processing of personal data for the purposes set out above will fall under the college’s pursuit of our legitimate interests.  The college will seek consent from our European residents for the specific purposes of directory services and email, phone, and text communications that are considered direct marketing.  There may be some instances where the collection and processing of data will be pursuant to other lawful bases.

The accuracy of your personal information is important to us.  You have the right to request a copy of the personal information we hold about you and to have inaccuracies corrected. We will retain your data indefinitely in support of your lifelong relations with the College or until you request us to do otherwise, at which point we will continue to maintain a core set of personal data to ensure that we do not contact you inadvertently in the future, to maintain your academic record for archive purposes, and to maintain financial records for accounting purposes.  Where you have provided your consent for our use of your personal information, you always have the right to withdraw your consent at any time.  You may object to the processing of your personal data, on legitimate grounds, except if otherwise permitted by law.  If you wish to access, amend, or request that we delete any information about you or restrict its processing, you may contact us at records@coloradocollege.edu .  Please note that exercising of these rights is a guarantee to be afforded in process and not the guarantee of an outcome.

For more information about the College’s EU General Data Protection Regulation Policy, please click here.

Data Controller

The Data Controller for the purposes of GDPR is Colorado College.  Please direct questions or requests to privacy@coloradocollege.edu

 

[1] In compliance with GDPR, Colorado College does not maintain information about ethnicity for European Union residents without explicit consent.

Procedures

None

Definitions

None