Sarah Lawrence College GDPR Data Policy

Sarah Lawrence College recognizes the General Data Protection Regulation (GDPR) and the rights of European Union citizens whose information may reside in its data processing systems. The College is actively working towards efforts that show compliance data processing of personal information for these EU citizens. This document contains information that shows the college’s preparedness and efforts towards compliance where personal data is processed for EU Citizens.

Contact

Any specific questions about your data or to exercise your data privacy rights can be addressed to:

Sarah Lawrence College
Data Protection
ITS—Library Lower Level
Bronxville, NY 10708

or

DataProtection@sarahlawrence.edu

Data Subjects

The College identifies “Data Subjects” as any natural person to whom personal data relates. Within the context of the College, the data subjects fall into the following categories:

  • Students (prospective, current, alumni)
  • Employees (applicants, current, past)
  • Other contacts (agents, partners, vendors, etc.)

Personal Data

As defined within the context of GDPR is any data that can be directly or indirectly related to a natural person (data subject). Personal data includes any identifiable personal data that can connect personal data to a data subject e.g. name, citizen ID, phone number, e-mail address, gender, nationality, address, interests, career details, etc.

Sensitive Personal Data

The College may, from time to time, be required to process sensitive personal data. Sensitive personal data includes data relating to medical information, gender, religion, race, sexual orientation, trade union membership, and criminal records and proceedings.

Processing Personal Data

The College shall so far as is reasonably practicable make all efforts to ensure all personal data is:

  • Fairly and lawfully processed
  • Processed for a lawful purpose
  • Adequate, relevant, and not excessive
  • Accurate and up-to-date
  • Processed in accordance with the data subject's rights
  • Secure
  • Adequate precautions and protections in all transfers of data to overseas programs

The Lawful Basis for Processing Data

GDPR requires a lawful basis for processing personal data. The College houses personal data to recognize, process, and communicate with its data subjects of prospective students, current students, prospective employees, current employees, and alumni. The processing of this data is lawful and necessary and falls into one or more of the following categories:

  1. Consent: We use personal information while processing data for communicating with prospective students and prospective employees. While we do not have an implied contract with these data subjects at this point, the data subjects give us their implied consent to communicate with them by completing an application, which is an intent to come to the College. (students, employees)
  2. Contract: We use personal information while processing data that is necessary for the implied contract the college has with the individual e.g.
    • Academic Processing for students,
    • Payroll and financial and tax processing for employees
  3. Legal obligation: We will share personal information with companies, organizations, or individuals outside of the College if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
    • meet any applicable law, regulation, legal process, or enforceable governmental request, e.g. the processing is necessary for the College to comply with the US federal laws, as well as New York State and federal reporting requirements;
    • enforce applicable Terms of Service, including investigation of potential violations;
    • detect, prevent, or otherwise address fraud, security, or technical issues;
    • protect against harm to the rights, property, or safety of the College, our users or the public as required or permitted by law.
  4. Public task: the processing is necessary for the College to perform a task in the public interest or for our official functions as a private college within the State of New York and the USA, and the task or function has a clear basis in law. Examples of these are:
    • Providing student statistical information to the National Student Clearinghouse;
    • IPEDS reporting

Confidential Data

Any information which falls under the definition of personal data and is not otherwise exempt will remain confidential and will only be disclosed to third parties with appropriate consent.

Cookies and Other Technology

Information Gathered Automatically

Unless you take steps to browse the Internet anonymously, Sarah Lawrence College, like most institutions and organizations on the Internet, tracks web browsing patterns to inform understanding of how our sites are being used. Generic information is collected through the use of “cookies,” which are text files placed on your computer, to evaluate usage patterns so that we can improve both content and distribution. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, doing so may prevent you from using the full functionality of all of our websites. The generic information we collect is based on IP address, which is the location of a computer or network.

Some sections of Sarah Lawrence College-owned websites use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users use our sites. The information generated by the cookie about your use of the website includes your IP address. This information will be transmitted to and stored by Google on its servers. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Please visit the following pages for more information on Google Analytics terms of use and Google’s privacy practices.

US Laws of FERPA, GLBA, and HIPAA

The College is also required to protect the personal data with respect to the laws of the United States as well as provide information to state and federal authorities with respect to these laws. The College complies with data requirements under the United States FERPA (The Family Educational Rights and Privacy Act), GLBA (The Gramm-Leach-Bliley Act), and HIPAA (Health Insurance Portability and Accountability Act of 1996)

Data Controller, Data Processors, and External Data Processors

The College acts as a data controller for all the personal data of its data subjects. The data is processed by two parties.

  1. The College acts as its own data processor where on-premise College-owned systems are used to process the College’s data.
  2. In certain cases, data is transferred to external vendors who process the data on the College’s behalf. The College will make every reasonable effort to get its external data processors to comply with this policy.
  3. The College will make every reasonable effort to address all approved changes to personal data requests its internal and external processors.

Rights of Access to Information

Data subjects have the right of access to information held by the College. Any data subject wishing to access their personal data should put their request in writing to the College contact identified above.

  • The College will endeavor to respond to any such written requests within 30 days.
  • The College will need to verify the identity of the data subject making the request.
  • Once the identity of the data subject has been verified, the College will determine if the request can be carried out or if the College has to refuse the request based on current regulations or contract obligations between the data subject and the College.
  • If the request is approved, the request will be processed within the College’s internal and external data processing areas.
  • In case the request is refused, the data subject will be notified as to why the request was denied.

Exemptions

Certain data is exempted from the provisions of the Rights of Access to Information under GDPR. Below are examples of some of the exceptions:

  • National security and the prevention or detection of crime
  • The assessment of any tax or duty
  • Where the processing is necessary to exercise a right or obligation conferred or imposed by law upon the College
  • Data that may violate another person’s privacy

Accuracy

The College will make every reasonable effort to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify the relevant College department of any changes to information held about them.

Data from Minors

The College is committed to protecting the privacy of children. Therefore, the College does not knowingly collect or process data from children under 16 years of age except in compliance with children's online privacy protection law. Accordingly, children under the age of 16 may only use services and programs offered by the College with the permission and supervision of their parents. Additionally, teachers and departments of the College that provide programs and services in the classroom with children under 16 years of age are required to obtain the express consent of such children's parents in compliance with the applicable law, prior to permitting such children to access or use the services or programs.

Compliance and Cooperation with Regulatory Authorities

If an individual believes that the College has not complied with this policy or acted otherwise than in accordance with the GDPR, the person should contact the College at the address above and file their complaint in writing. We will work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the individual rights or transfer of personal data that we cannot resolve with our data subjects directly.

Data Security

We implement appropriate technical and organizational security measures to protect your information when you transmit it to us and when we store it our information technology systems.

Secure Destruction

When data held in accordance with this policy is destroyed, it must be destroyed securely in accordance with best practice at the time of destruction.

Retention of Data

The College may retain data for differing periods of time for different purposes as required by statute or best practices, individual departments incorporate these retention times into the processes and manuals. Other statutory obligations, legal processes, and inquiries may also necessitate the retention of certain data. The College may store some data such as registers, photographs, exam results, achievements, books, works, etc. indefinitely in its archive.

Updates to this Policy

The College may update or change this policy at any time. Your continued use of the College's website and third-party applications after any such change indicates your acceptance of these changes.

Revised: May 25, 2018