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    General Privacy Policy

    Responsible office
    Information Technology Services
    Responsible party
    AVP Institutional Planning & Effectiveness, AVP for Advancement Services, and Information Security Engineer
    Last revision
    May 2018
    Approved by
    The Cabinet
    Approval date
    May 2018
    Effective date
    May 2018
    Last review
    January 2019
    Additional references
    Advancement Privacy Notice; 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

    Website

    What we collect and why

    Colorado College (CC) collects information from individuals or entities when they access any CC website.  Information that is collected from this contact is the contactor’s IP address, date and time of the website access along with the web pages(s) visited.  In addition, CC may also collect any information that it receives from your web browser, including browser type and version, and operating system.  This information helps us understand aggregate uses of our site, track usage trends and improve our services.

    Cookies

    Cookies are pieces of data 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.

    Security

    Colorado College is committed to ensuring the security of your information. We have put in place reasonable physical, technical and administrative safeguards designed to prevent unauthorized access to or use of the information collected online.

    Sharing your information

    We will not share your information with third parties except:

    • as required by law;
    • as necessary to protect Institute interests;
    • as necessary to further research efforts pursuant to approvals from appropriate data stewards and the IRB https://www.coloradocollege.edu/other/irb/ ; and/or
    • with service providers acting on our behalf who have agreed to protect the confidentiality of the data.

    Links to other websites

    Colorado College’s website may contain links to other websites not affiliated with the college. CC is not responsible for the privacy practices of these other sites. We encourage you to read the privacy statements of other sites for assurance that their practices safeguard your privacy.

    Legal Notice

    Notwithstanding any language to the contrary, nothing contained herein constitutes nor is intended to constitute an offer, inducement, promise, or contract of any kind. The data contained herein is for informational purposes only and is not represented to be error free. Any links to non-CC information are provided as a courtesy. They are not intended to nor do they constitute an endorsement by Colorado College of the linked materials.

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

    Lawful Basis for Collecting and Processing of Personal Data

    Colorado College (CC) is an institute of higher education involved in education, research, and community service and development.  In order for CC to educate its students, engage in research, and provide community services, it is essential, necessary, and Colorado College 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, field, and study abroad education, grades, communications, employment, applied research, development, program analysis for improvements, and records retention. Examples of data that Colorado College 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 on privacy related to development activities, please read [link to Advancement’s policy]

    For more information regarding the EU GDPR, please review Colorado College’s EU General Data Protection Regulation Compliance Policy.

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

    • Processing is necessary for the purposes of the legitimate interests pursued by Colorado College or third parties in providing education, employment, research and development, and community programs.
    • 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.
    • Processing is necessary for compliance with a legal obligation to which Colorado College is subject.
    • 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.

    Types of Personal Data collected and why

    Colorado College 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, athletics or travel), and donations. If you have specific questions regarding the collection and use of your personal data, please contact privacy@coloradocollege.edu

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

    Where Colorado College gets Personal and Sensitive Personal Data

    Colorado College (CC) receives personal and sensitive personal data from multiple sources. Most often, CC 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 Colorado College through use of the Common App).

    Individual Rights of the Data Subject under the EU GDPR

    Individual data subjects covered by Colorado College’s EU General Data Protection Regulation Compliance Policy [insert link here] will be afforded the following rights:

    • information about the controller collecting the data
    • the data protection officer contact information
    • the purposes and legal basis/legitimate interests of the data collection/processing
    • recipients of the personal data
    • if Colorado College intends to transfer personal data to another country or international organization
    • the period the personal data will be stored
    • the existence of the right to access, rectify incorrect data or erase personal data, restrict or object to processing, and the right to data portability
    • the existence of the right to withdraw consent at any time
    • the right to lodge a complaint with a supervisory authority (established in the EU)
    • why the personal data are required, and possible consequences of the failure to provide the data
    • the existence of automated decision-making, including profiling
    • if the collected data are going to be further processed for a purpose other than that for which it was collected

    Note: Exercising of these rights is a guarantee to be afforded a process and not the guarantee of an outcome.

    Any data subject who wishes to exercise any of the above-mentioned rights may do so by emailing a request to privacy@coloradocollege.edu 

    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.

    Security of Personal Data subject to the EU GDPR

    All personal data and sensitive personal data collected or processed by Colorado College under the scope of the Colorado College EU General Data Protection Regulation Compliance Policy [link to be inserted here] must comply with the security controls and systems and process requirements and standards of the college’s Information Security Policy https://www.coloradocollege.edu/basics/welcome/leadership/policies/information-security-policy

    We will not share your information with third parties except:

    • as necessary to meet one of its lawful purposes, including  but not limited to,
    • its legitimate interest,
    • contract compliance,
    • pursuant to consent provided by you,
    • as required by law;
    • as necessary to protect Colorado College’s interests;
    • with service providers acting on our behalf who have agreed to protect the confidentiality of the data.

    Data Retention

    Colorado College keeps the data it collects for the time periods specified in the Records Policy: Retention and Disposition of Records https://www.coloradocollege.edu/basics/welcome/leadership/policies/records-policy-retention-and-disposition-of-records

    Procedures

    None

    Definitions

    None