Admissions Privacy Notice for EU Applicants
Effective date: February 8, 2019
This privacy notice describes how Champlain College Incorporated of 163 South Willard St., Burlington, VT 05401 ("we", "our", "us" or the "College") collects, processes, and protects personal information relating to applicants (as defined below) who are in the European Union; how we use, store, transfer and protect this personal information; and describes your rights in relation to this information. Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified. This privacy notice applies to all personal information we collect or process relating to applicants who are in the European Union, in the context of admissions and throughout the application process. For purposes of this privacy notice, "applicant" means:
- Past and present student applicants;
- Prospective students and recruits who interact with our admissions offices, employees, or associated third parties; and
- Parents, guardians, and other family members of student applicants.
1. Personal Information We Collect And Use
Throughout the application process, we collect personal information about you from a variety of sources, including from you directly (e.g. from your application, or when you contact us or request information), information we generate about you in the course of our relationship with you (e.g. internal notes about your application) and information we collect about you from third parties (e.g. academic transcripts provided by other institutions or third party digital credential services).
Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.
1.1 Information We Collect Directly From You
The categories of information that we collect directly from you include the following:
(a) personal details (e.g. name, date of birth, place of birth, Social Security number or other governmental-issued identification number);
(b) demographic details (e.g. your age, marital status, languages spoken, national origin and current nationality);
(c) citizenship status;
(d) military or veteran status;
(e) contact details (e.g. phone number, email address, postal address or mobile number for yourself, your parents or guardians, and/or other emergency contacts);
(f) account details (e.g. username and password; Common App ID (CAID);
(g) transaction details (e.g. when you submit an application fee or tuition deposit);
(h) communications (e.g. your requests and information provided by you in the form of feedback or complaints about the program, housing, or other matters);
(i) gender identity, if you consent to provide such information by answering an optional question on an admissions application or Residential Life housing form;
(j) financial aid details (e.g. income, assets (such as value of cash, bank accounts or retirement accounts), financial aid applications, scholarship information, tax returns, tax return transcripts, W-2's, information about your or your family's financial situation).
(k) immigration information (for international applicants or students) (e.g. passport and visa information)
(l) information you submit in connection with your application for admission (e.g. your personal essay, writing sample, study proposal, portfolio, academic transcripts, test scores, letters of recommendation, evaluations, application video, disciplinary records, information about prior applications, and information relating to academic dismissals);
(m) employment information (e.g. your resume, work history and job title);
(n) information about your family (e.g. names of relatives who have attended Champlain College);
(o) information about your preferences (e.g. those related to housing and academic and extracurricular activities);
(p) photographs for use in identification; and
(q) emergency contact details (e.g. names of your emergency contacts and their contact information and information about your next of kin).
1.2 Information We Generate About You
In addition, we may generate the following categories of personal information about you in the context of admissions and throughout the course of the application process:
(a) Student identification numbers;
(b) Records of our interactions with you;
(c) Internal notes, including notes about your application, admission decisions, alumni interviews and other admissions interviews;
(d) Acceptance letters and enrollment confirmation; and
(e) Immigration information (for international applicants or students)
1.3 Information We Collect From Other Sources About You
The following are examples of the categories of information we collect from other sources, including, but not limited to, lead generation and marketing companies; educational testing agencies; other academic institutions; and the federal government:
(a) personal details (e.g. name, date of birth);
(b) contact details (e.g. phone number, email address, postal address or mobile number);
(c) details about advertising preferences (e.g. interaction with advertisements online);
(d) application materials (e.g. information you share with us through a third party application provider such as the Common Application)
(e) feedback, recommendations, or evaluations from your teachers or other individuals;
(f) academic details (e.g. academic history or transcripts provided by other institutions or third party digital credential services; testing information; college application history); and
(g) financial aid details we receive from the Department of Education through information you submit via the Free Application for Federal Student Aid (FAFSA) (e.g. income, assets (such as value of cash, bank accounts or retirement accounts), aid requests, tax returns, tax return transcripts, W-2's).
1.4 Sensitive Information We Collect And Use
Some of the categories of personal information that we collect are considered special categories of personal data under European Union law. In particular, we may process the following types of sensitive information:
(a) information about your racial or ethnic origin, if you consent to provide such information by answering an optional question on an admissions application. To the extent we process information revealing racial or ethnic origin, such information is voluntarily disclosed during the application process for purposes of statistical reporting related to diversity. We rely on express consent for such processing.
(b) information about your health, which is either provided by your health care providers (if you authorize such information being provided to us) or obtained from information you provide by answering a questionnaire at the time of enrollment, when applying for study abroad semesters at our campuses in Dublin or Montreal, or as requested by the Health Center (e.g. medical history, physician's report, information about disabilities or related accommodations, information about allergies or dietary restrictions, and health insurance information). To the extent we process health information, we do so to comply with obligations under social protection laws (e.g. to provide disability accommodations) or, where not required by law, to provide medical services under the responsibility of authorized medical professionals or when such processing is necessary to protect the vital interests of you or another person. In some contexts, this information may be processed with your consent;
(c) information about criminal charges and convictions. To the extent we process information about criminal charges and convictions, we do so to comply with our legal obligations, or where not required by law, to serve our legitimate interests.
2. How We Use Your Personal Information And The Basis On Which We Use It
We use your personal data in connection with admissions and throughout the application process for the following purposes:
- Considering your application for admission and financial aid. Our basis for doing so is the performance of the pre-contractual relations we have with and to serve our legitimate interests in selecting a diverse and qualified student body;
- Contacting you about our academic programs, events, related opportunities, or other updates about Champlain College, including sending you Champlain College newsletters and publications. This processing is necessary to serve our legitimate interests in marketing and student outreach. Where required by law, we will obtain your consent before sending you marketing communications.
- Personalizing marketing communications. We may use your personal data to learn about your interests and preferences so that we can personalize the marketing messages and other content we provide to you. This processing is necessary to serve our legitimate interests in providing you more relevant content and communications. When required by law, we will obtain your consent before sending you marketing communications.
- Identifying students, including creating a student identification card that includes your photo. This processing is necessary to serve our legitimate interests in keeping our campus and associated facilities safe and secure;
- Communicating with applicants, parents or legal guardians throughout the application process. This processing is necessary to serve our legitimate interests in responding to applicant requests and efficiently managing the application process;
- Responding to emergencies, such as contacting you or your family or legal guardians in the event of an incident. This processing is necessary to serve our legitimate interests in supporting the health and wellbeing of our students;
- For purposes of program planning and development. This processing is necessary to serve our legitimate interests in the efficient management and administration of our academic programs and extracurricular activities;
- Keeping our campus and associated facilities safe and secure. This processing is necessary to serve our legitimate interests in protecting our students, property, and facilities;
- Complying with legal obligations to which we are subject, including to defend your and our rights in legal proceedings and to cooperate with regulators and law enforcement, governmental or competent bodies. This processing is necessary to comply with legal obligations and to serve our legitimate interests in complying with the laws to which we are subject; and
- Keeping our records accurate and up-to-date. This processing is necessary to comply with legal obligations and to serve our legitimate interests in efficient management and administration. We may also anonymize your personal information in such a way that you may not reasonably be re-identified by us or any other company, and use this anonymized information for any other purpose.
3. How And When We Share Your Personal Information
We share your personal information with third parties under the following circumstances:
- With each other: Champlain College Incorporated and Champlain College Dublin Limited share personal information with each other for the purposes set forth above. To the extent we collect information in person in Europe, we may share personal information about you with other Champlain College personnel located at our campus in the United States or elsewhere.
- Service providers and business partners: we share your personal information with our service providers and academic or business partners that perform services for us. For example, we may partner with other companies or entities to provide services for you in relation to our academic programs, such as learning management system providers, information technology providers, and enrollment management providers.
- Where required by law: we share your personal information with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
- In the context of a transaction: we share your personal information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal information to use it in a manner that is consistent with this Privacy Notice.
4. Your Rights Over Your Personal Information
Where applicable under local law, you may have certain rights regarding the personal information we hold about you. These may include the rights to access, correct, delete, restrict or object to our use of, or receive a portable copy in a usable electronic format of your personal information. You also may have a right to lodge a complaint with your local data protection or privacy regulator. We encourage you to contact us at the contact information set forth below to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Where you have provided your consent to any use of your personal information, and where applicable under local law, you can withdraw this consent at any time. Please note that we may require additional information from you in order to honor your requests. If you would like to discuss or exercise any rights you have under law, please contact us at the contact information set forth below.
5. Information Security And Storage
We implement physical, technical, and organizational security measures designed to safeguard the personal information we process through the Services. These measures are aimed at providing on-going integrity and confidentiality for your personal information. We evaluate and update these measures on a regular basis. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. We retain your personal information for as long as we have a relationship with you. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations. We also retain records to investigate or defend against potential legal claims. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the information.
6. International Data Transfer
Your personal information may be transferred to, stored, and processed in a country (such as the United States), that is not regarded as providing the same level of protection for personal information as the laws of your home country. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information. For more information on the appropriate safeguards in place and to obtain a copy of such safeguards, please contact us at the contact information set forth below.
7. Contact Us
Champlain College Incorporated is the controller responsible for the personal information we collect and process. We are represented in the European Union by Champlain College Dublin Limited. If you have questions or concerns regarding the way in which your personal information has been used, please contact our Data Privacy Officer at firstname.lastname@example.org We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the appropriate data protection authority. Contact information for the EU data protection authorities can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
8. Changes To The Policy
We may modify or update this privacy notice from time to time. If we make any revisions that materially change the ways in which we process your personal information, we will notify you of these changes before applying them to that personal information.